Russia -- Regulatory Status Regulatory Overview

Executive Summary

• Russia has a formal legal framework for digital assets: Federal Law No. 259-FZ "On Digital Financial Assets" (dated July 31, 2020) which legalizes digital financial assets but prohibits their use as payment for goods and services Конституция на английском языке
• The Central Bank of Russia (CBR) serves as the primary regulator for digital financial assets, with authority to register information system operators and digital financial asset exchange operators, while the Ministry of Finance oversees broader crypto regulation eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• Licensing/registration is required for information system operators and digital financial asset exchange operators, with no entities publicly confirmed as having received such licenses from CBR eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations
• The practical reality is that a parallel sanctions regime from the U.S. (OFAC) and UK creates significant compliance complexity for any Russian crypto business, and available regulatory information focuses primarily on sanctions rather than domestic Russian licensing specifics Russia sanctions: guidance - GOV.UK
• Mining of digital currency was legalized through Federal Law No. 259-FZ amendments, but digital currencies cannot be used to pay for goods, works, or services within Russia Federal Register :: Publication of Russian Harmful Foreign Activities Sanctions Regulations and Ukraine-/Russia-Related Sanctions Regulations Web General License 125

Regulatory Framework

Regulatory Bodies

• The Central Bank of Russia (CBR) is the primary financial regulator responsible for overseeing digital financial assets (DFA) under Federal Law No. 259-FZ "On Digital Financial Assets, Digital Currency, and on Amendments to Certain Legislative Acts of the Russian Federation" dated July 31, 2020 Конституция на английском языке
• The Ministry of Finance of the Russian Federation is responsible for developing government policy and legal regulation in the sphere of digital currency circulation eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• The Federal Financial Monitoring Service (Rosfinmonitoring) serves as Russia's financial intelligence unit (FIU) and is responsible for AML/CFT oversight of crypto transactions eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations

Primary Laws

• Federal Law No. 259-FZ "On Digital Financial Assets, Digital Currency, and on Amendments to Certain Legislative Acts of the Russian Federation" dated July 31, 2020 is the foundational law establishing the legal definition of digital financial assets and digital currency, and creates the registration framework for information system operators and DFA exchange operators Конституция на английском языке
• Federal Law No. 259-FZ explicitly prohibits the use of digital currency as a means of payment for goods, works, and services in Russia, establishing that digital currency is not legal tender in the Russian Federation eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• The Law on the Central Bank of the Russian Federation (Federal Law No. 86-FZ, dated July 10, 2002) gives the CBR authority to regulate payment systems and financial markets, which extends to digital financial asset oversight eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations
• Federal Law No. 115-FZ "On Counteracting the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism" (dated August 7, 2001) applies to digital currency operators and requires them to comply with AML/CFT obligations Russia sanctions: guidance - GOV.UK

International Standing

• Russia is a member of the Financial Action Task Force (FATF) and was suspended from FATF membership in February 2023 but remains subject to FATF recommendations in its domestic law eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• Russia is also a member of the Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG), a FATF-style regional body eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations
• The U.S. Treasury's Office of Foreign Assets Control (OFAC) has imposed comprehensive sanctions on the Russian financial sector, which creates jurisdictional overlap for entities dealing in Russian digital assets Federal Register :: Publication of Russian Harmful Foreign Activities Sanctions Regulations and Ukraine-/Russia-Related Sanctions Regulations Web General License 125

Licensing Requirements

Who Needs a License

• Information system operators that issue digital financial assets are required to register with the Central Bank of Russia under Federal Law No. 259-FZ Конституция на английском языке
• Digital financial asset exchange operators that facilitate trading of DFAs are required to obtain registration with the Central Bank of Russia eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• Cryptocurrency miners must register with the Federal Tax Service of Russia to legally conduct mining activities under the amended Federal Law No. 259-FZ eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations

Activities Requiring Licensing

• Issuance of digital financial assets requires registration as an information system operator with the CBR Конституция на английском языке
• Exchange operations involving digital financial assets (purchase, sale, exchange of DFAs) require registration as a DFA exchange operator with the CBR eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• Digital currency mining operations require registration with the Federal Tax Service if the miner exceeds energy consumption thresholds set by the Russian government eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations

Capital Requirements

• No specific capital requirements have been published for DFA exchange operators or information system operators Конституция на английском языке
• Available regulations focus on sanctions requirements rather than domestic capital requirements for digital asset businesses eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations

Application Process

• The application process for DFA operator registration is conducted through the Central Bank of Russia's official registration procedures as specified in Federal Law No. 259-FZ Конституция на английском языке
• Mining registration is conducted through the Federal Tax Service's online portal for taxpayer registration eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations

Timeline

• Processing timelines for DFA operator registration applications are not publicly specified Конституция на английском языке

Structural Requirements

• Information system operators and DFA exchange operators must be Russian legal entities established under Russian law Конституция на английском языке
• The legal framework requires that the information system infrastructure used for DFA issuance and exchange be located within the territory of the Russian Federation eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations

Licenses Actually Granted

• No entities have been confirmed as having received licenses or registration from the Central Bank of Russia as information system operators or DFA exchange operators Конституция на английском языке
• Zero public registrations of DFA exchange operators have been identified eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations

AML/KYC Requirements

• Digital financial asset exchange operators are classified as organizations conducting transactions with monetary funds or other property under Federal Law No. 115-FZ, making them subject to mandatory AML/CFT compliance obligations Конституция на английском языке
• Customer due diligence (CDD) requirements apply to DFA operators, requiring identification of clients before conducting transactions involving digital financial assets eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• Suspicious transaction reporting (STR) requirements mandate that DFA operators report to Rosfinmonitoring any transactions that may be related to money laundering or terrorist financing, in accordance with Federal Law No. 115-FZ eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations
• Mandatory client identification requires obtaining the name, birth date, and identification document details (for individuals) or registration name and address (for legal entities) before executing transactions Конституция на английском языке
• Enhanced due diligence (EDD) is required for transactions involving foreign politically exposed persons (PEPs), their family members, and close associates Russia sanctions: guidance - GOV.UK
• Record retention requirements under Federal Law No. 115-FZ mandate that DFA operators maintain transaction records and client identification data for at least five years eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• Beneficial ownership identification is required for all corporate clients, meaning DFA operators must identify individuals who ultimately own or control legal entities conducting transactions eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations

Enforcement Actions

• The U.S. Office of Foreign Assets Control (OFAC) has issued General License No. 125 on August 13, 2025, authorizing specific transactions related to meetings between the U.S. Government and the Government of the Russian Federation in Alaska, demonstrating the enforcement reach of U.S. sanctions over Russian-related activities Federal Register :: Publication of Russian Harmful Foreign Activities Sanctions Regulations and Ukraine-/Russia-Related Sanctions Regulations Web General License 125
• OFAC maintains the Specially Designated Nationals and Blocked Persons List (SDN List) under the Russian Harmful Foreign Activities Sanctions Regulations, using the identifier formulation "[RUSSIA-EO[E.O. number]]" for persons designated under E.O. 14024 eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• OFAC is authorized to block property and interests in property of persons designated under E.O. 14024, with blocked assets required to be held in interest-bearing accounts and reported to OFAC under 31 CFR Part 587 Subpart F eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• The UK Office of Financial Sanctions Implementation (OFSI) and Office of Trade Sanctions Implementation (OTSI) enforce the Russia sanctions regime, with OTSI taking over civil enforcement for sanctions in October 2024 Russia sanctions: guidance - GOV.UK

Tax Treatment

• No specific tax guidance for digital currency has been published Конституция на английском языке
• No tax guidance has been issued for virtual assets; available regulations focus on sanctions rather than Russian domestic tax law eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• Russian domestic tax law does not address how digital currency gains would be classified for Russian income tax or VAT purposes eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations

Key Gaps & Risks

• Available regulatory information is dominated by U.S. (OFAC) and UK sanctions regulations rather than Russian domestic regulatory details, indicating that the primary compliance risk for crypto businesses comes from foreign sanctions regimes rather than domestic Russian law eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• Any Russian crypto business dealing with U.S. persons or U.S. financial institutions faces comprehensive prohibitions under the Russian Harmful Foreign Activities Sanctions Regulations (31 CFR Part 587) and the Ukraine-/Russia-Related Sanctions Regulations (31 CFR Part 589) eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations
• The prohibition on using digital currency for payments within Russia creates a significant limitation on the commercial utility of digital assets for domestic businesses Конституция на английском языке
• OFAC can add persons to the SDN List at any time, creating sudden compliance obligations for anyone interacting with newly designated entities eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• The UK Russia sanctions regime includes asset freezes, director disqualification, immigration sanctions, and internet service restrictions that can apply to designated persons connected with Russia Russia sanctions: guidance - GOV.UK
• Cross-border transactions involving Russian digital assets may require compliance with multiple overlapping sanctions regimes, including U.S. OFAC regulations, UK regulations, and potentially EU sanctions Federal Register :: Publication of Russian Harmful Foreign Activities Sanctions Regulations and Ukraine-/Russia-Related Sanctions Regulations Web General License 125

Sources

• Конституция на английском языке
• eCFR :: 31 CFR Part 587 -- Russian Harmful Foreign Activities Sanctions Regulations
• Federal Register :: Publication of Russian Harmful Foreign Activities Sanctions Regulations and Ukraine-/Russia-Related Sanctions Regulations Web General License 125
• eCFR :: 31 CFR Part 589 -- Ukraine-/Russia-Related Sanctions Regulations
• Russia sanctions: guidance - GOV.UK
• Russia Sanctions and Export Controls