End of Shadow Exchange? What Will Be the New Rules for the Crypto Market in Russia - ForkLog: cryptocurrencies, AI, singularity, future

# End of shadow trading? What will be the new rules for the crypto market in Russia

A comprehensive bill “On Digital Currency and Digital Rights” is being prepared for submission to the State Duma of the Russian Federation. Among other things, it stipulates licensing of market participants, introduces limits for non-qualified investors, and procedures for de-anonymization.

ForkLog discussed with lawyers and market participants the controversial aspects of future regulation. In this article, we explain why keys to Bitcoin wallets will have to be shared with a digital depository and how the government plans to monitor every crypto transaction within the country.

Contents of the Bill

The text of the document is still undergoing final inter-agency approvals and has not yet been made publicly available.

Current discussions are based on statements from agencies and leaks in the media. It is also known that it is based on the December 2025 concept presented by the Central Bank. In it, the regulator again emphasized the high risks of cryptocurrencies and the danger of complete loss of invested funds.

The bill proposes to recognize digital currencies as monetary assets. They can be bought and sold but not used for settlements within Russia.

Separation of investors and limits

Different investor categories will be required to pass risk understanding tests, but access to operations will be granted under separate conditions.

Non-qualified participants will be able to purchase the most liquid cryptocurrencies up to 300,000 rubles per year through a single intermediary. The limit is used as a guideline and is still under discussion.

“Qualified” investors will be allowed to buy any cryptocurrencies except anonymous ones, without volume restrictions.

Licensing and infrastructure

Only licensed participants with the status of Russian legal entities—cryptocurrency exchanges, brokers, and trust managers—will be able to conduct operations with cryptocurrencies domestically.

Specific requirements are planned for exchanges and specialized digital depositories included in the Central Bank’s register. Their tasks will include accounting for rights to crypto assets and wallet registration.

Depositories will also face restrictions on free disposal of coins. For example, they cannot lend out assets to other users. They will also be exempt from liability for client funds in cases of token issuer blocking funds or blockchain malfunctions not compliant with Russian law.

Exchange operators will be subject to rules depending on transaction volume. If turnover reaches or exceeds 3.5 million rubles per month, exchanges can work directly with users. For lower volumes, services must serve clients only through legal intermediaries—exchanges or brokers. External trade contracts are not included in this limit.

The bill obliges crypto exchanges to compensate clients for damages from fraudulent operations, aligning their responsibility level with traditional financial organizations.

Turnover of CFA and other Russian digital rights is proposed to be permitted on public blockchains, whereas previously they were only available in closed banking systems.

De-anonymization and control

All legal platforms will be required to implement KYC/AML procedures. This will allow regulators to track transaction chains in real time and identify links to suspicious addresses. The law does not specify a single compliance service (e.g., “Transparent Blockchain”).

User information and transaction data must be transmitted to the Federal Tax Service and law enforcement agencies upon official request or automatically when risk filters trigger.

Anonymous cryptocurrencies like Monero or Zcash are prohibited.

The Central Bank’s concept mentioned that residents could buy cryptocurrencies abroad via foreign accounts. Assets could be transferred abroad through Russian intermediaries, but such operations would need to be reported to tax authorities. However, these provisions are not included in the current draft.

What does this change in current regulation?

Currently, cryptocurrencies in Russia are recognized as property; with the new bill, they will also be defined as a currency value for foreign trade settlements.

Russian citizens are still allowed to own and mine cryptocurrencies under the new rules. Businesses and individual entrepreneurs can use them in experimental legal regimes for international trade.

The mechanisms for legal circulation and trading outlined in the new bill form a full-fledged but isolated domestic market. The government intends to control every transaction, effectively blocking infrastructure for P2P deals within the country.

Activities of any intermediary platforms without a Russian license will be considered illegal. For ordinary users, this means they cannot legally withdraw funds to fiat via P2P services without risking account blocks.

One of the most controversial points states that assets outside addresses-identifier will not be protected by Russian courts.

However, according to the Constitutional Court decision of January 20, 2026, cryptocurrencies, regardless of storage location, are recognized as property and are subject to judicial protection even without declaration.

In practice, protecting “gray” assets remains very difficult: owners will have to prove not only ownership of the address but also the legality of the funds’ origin. Declaring income from cryptocurrencies remains the main tool to simplify this process and avoid issues with banks when legalizing assets.

Legal expert comment

Andrey Tugarin, founder of GMT Legal, emphasized to ForkLog that the article about the impossibility of considering undeclared digital currency as subject of legal dispute has already been recognized as unconstitutional and will not remain in the final version of the document.

“This provision was copied into the new bill verbatim. It indicates that the authors simply approached this part inattentively, and nothing more. There is no mention in the new bill of depriving rights to cryptocurrencies on custodial or non-custodial wallets,” he explained.

Operation complications

The most controversial aspect, according to the lawyer, concerns the management of crypto wallets by digital depositories. The document proposes a quasi-custodial storage model: half of the access keys will be held by the depository, and the other half by the owner. To execute any transaction, both signatures will be required.

“This approach breaks the usual market mechanisms and greatly complicates the free disposal of one’s own cryptocurrency. Due to the extreme inconvenience of this mechanism, the most heated debates are currently about the proposed storage methods,” he noted.

Exceeding limits

No penalties are provided for non-qualified investors exceeding limits. Tugarin states that only licensed Russian intermediaries are responsible for monitoring purchase volumes, as they process transactions. Platforms are obliged to keep records, so a “non-qualified” investor simply cannot buy more than 300,000 rubles worth of crypto per year.

“The buyer himself is not responsible for exceeding the limit, so no new sanctions in the Administrative Code or Criminal Code are planned. Operations exceeding the limit will be blocked automatically at the intermediary level. The only scenario where questions might arise is if the investor tricks a licensed platform into executing a transaction beyond the set amount,” he added.

Taxes

The bill does not impose strict tax requirements on operations in foreign jurisdictions. However, any licensed intermediary within Russia will inevitably perform automatic data exchange with the Federal Tax Service.

“Reporting to government agencies—either routinely or upon request—is organized seamlessly, relieving the user from having to declare each transaction manually,” the lawyer explained.

Tax obligations for Russians may arise even without converting to fiat. Profitable trades solely between different cryptocurrencies on a Russian exchange could be recognized as taxable income.

Tugarin notes that this approach is currently used by miners—they record primary income at the moment of coin extraction minus expenses, and when selling the appreciated asset, they pay tax on the exchange rate difference.

“The regulator could similarly apply this to ordinary investors. If a trader actively trades digital assets without converting to rubles and by year’s end shows a net profit relative to initial investments, this profit will need to be declared to tax authorities. Once comprehensive regulation is fully implemented, this type of fiscal control seems most realistic,” he concluded.

Liquidity

Russian crypto platforms will have to seek liquidity independently, and a legal solution, according to Tugarin, could be involving licensed exchanges as market makers:

“The scheme could work through creating unified cross-border structures. For example, a company with an existing foreign license opens a legal branch inside Russia and transfers liquidity from abroad to the local market.”

The lawyer emphasized that inability to work directly with most global platforms due to sanctions does not necessarily mean a shift to the “gray” zone—legal connections are possible.

“Moreover, the market expects gradual easing of restrictions, which will only expand options for liquidity sourcing over time. This is a realistic scenario,” he said.

What does the market think?

Among the challenges are potential mandates for digital depositories to act as custodians. The last point would isolate non-custodial wallets, forcing Russian exchanges to automatically flag any transactions involving them as high-risk.

However, BitOK CEO Dmitry Machihins considers such fears premature and doubts the regulator will take such radical measures. He believes asset storage should remain a user’s exclusive right, otherwise the state risks achieving the opposite effect.

“If you strictly limit crypto users, there’s a risk they will completely abandon legal infrastructure in favor of circumvention schemes,” he warned.

Machihins also considers fears of isolation from global compliance systems exaggerated. He believes existing localized AML solutions from specialized analytics firms are sufficient for full AML checks, similar to their own service.

A hot topic remains the discussed limit of 300,000 rubles for non-qualified investors. High compliance costs, data storage, and reporting could negatively impact the profitability of retail exchanges.

Commenting on this, Exved CEO Sergey Mendeleev urged not to jump to conclusions before the final text is published. He said that in draft versions he reviewed, this strict threshold has already been removed.

“Of course, such a restriction is crazy and will simply destroy the legal market. I see no point in even seriously discussing it,” he summarized.

For crypto exchange aggregators like BestChange, a key issue is possible blocking by Roskomnadzor for advertising illegal services. Platforms will have to decide whether to hide shadow services from Russian users and how to retain their audience under strict P2P restrictions.

BestChange analyst Nikita Zuborev confirmed readiness to act within the law and, if necessary, restrict access for Russian IPs. The company has experience with this—previously, the aggregator successfully applied such measures to avoid court claims from the Central Bank. However, technically implementing a total ban is very difficult.

“Neither we nor regulators have the ability to precisely determine a user’s location if they connect through secure channels or foreign corporate gateways,” the expert notes.

He also believes that the scale of market upheaval depends directly on the final implementation of the law. If most existing exchanges are allowed to operate as legal agents, the business structure will not change significantly—platforms will simply change liquidity providers.

The aggregator plans to retain Russian users through an integrated crypto risk assessment service and by developing its own educational portal.

What about other countries?

Unlike the isolated domestic market being formed in Russia, other jurisdictions are integrating digital assets into the broader financial system and creating incentives for the industry.

European Union

The EU has adopted the MiCA regulation, which introduces unified rules for service providers, allowing licensed companies from one member state to operate across all 27 countries.

Regulators do not limit purchase volumes for citizens, and non-custodial wallets have legal status, though transactions with them are subject to AML monitoring.

United States

US authorities focus on accessibility. The launch of crypto ETFs has helped integrate digital assets into traditional finance.

The GENIUS Act, passed in summer 2025, legalized stablecoins as a payment instrument, and the proposed Clarity Act in the Senate aims to establish uniform rules for exchanges.

These measures are not about restricting trading but creating a protected legal environment for capital.

UAE

The Emirates’ strategy aims to develop a global infrastructure for international crypto companies.

There is no personal income tax on digital asset investments for residents. Licensed operators and other legal entities pay a 9% corporate tax if their annual income exceeds 1 million dirhams (~$270,000).

Since November 2024, all transactions with tokens are fully exempt from VAT.

Additionally, the jurisdiction offers tax residency to crypto company owners, making it one of the most attractive in the world for large capital and professional market participants.

Conclusion

The main legislative framework is planned to be prepared by July 1, 2026, after which the Bank of Russia will issue clarifying regulations. According to the Central Bank and Ministry of Finance roadmaps, the transition period for the market will last exactly one year.

The next step in 2027 is expected to be the introduction of administrative and criminal liability for illegal activities of intermediaries in the crypto market, similar to the banking sector.

Regulation will ultimately transform cryptocurrencies from a free exchange tool into a transparent investment asset comparable to stocks or bonds.

A likely development vector is the creation of “white lists” of crypto addresses and legal gateways for external settlements.

Ordinary users will have to choose between working with licensed brokers protected by the state and moving into the “gray” zone. Using P2P and non-custodial wallets will allow bypassing limits on amounts but will complicate asset recovery in case of theft or blocking.