The new framework mandates that retail investors pass suitability tests to access “most liquid” assets, with annual purchase caps set at 300,000 rubles per intermediary. Qualified investors face no such volume limits, provided they meet specific testing requirements. To operate, exchanges must join a self-regulatory organization and maintain at least 15 million rubles in equity. Existing providers have until July 1, 2027, to align with these registration requirements.
Despite domestic restrictions, the law carves out explicit exceptions for foreign trade settlements. Russian businesses struggling with international payment channels due to sanctions may use digital assets for cross-border transactions. However, these operations remain subject to international compliance scrutiny, as the U.S. Treasury maintains that its sanctions regime applies to virtual currency just as it does to traditional fiat transfers. The Bank of Russia is currently drafting the technical standards for asset records and trading operations that will govern the market rollout.

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