Crypto ATM / kiosk operator in Russia

Bank of Russia (Central Bank of the Russian Federation): Establishes AML regulations for financial institutions, supervises compliance, issues and revokes licenses based on AML adherence, and provides guidance on AML best practices. The Bank also proposes crypto-specific rules and maintains registration of digital financial asset operators.

Rosfinmonitoring (Federal Financial Monitoring Service): Russia's lead agency for combating money laundering and terrorist financing. It analyzes financial transactions, ensures institutional compliance with AML/CFT standards and Federal Law No. 115-FZ, and enforces Enhanced Due Diligence requirements.

Federal Tax Service of Russia: Handles tax-related compliance, requiring individuals and organizations to report cryptocurrency holdings and transactions exceeding certain thresholds (notably 600,000 rubles).

Exchanges: Licensed entities with Russian legal status (crypto exchanges, brokers, fiduciary managers) are required. Banks and brokers can obtain crypto exchange licenses via a simplified notification process tied to existing financial permits, subject to prudential requirements set by the Bank of Russia.

Payment Processors/Exchangers: Exchangers (for crypto-fiat or crypto-crypto conversions) require inclusion in the Bank of Russia's register. Those with monthly turnover ≥3.5 million rubles can serve users directly; below that, they must use licensed intermediaries. Platforms without Russian licenses are illegal.

Exchanges and exchangers with monthly turnover ≥3.5 million rubles can serve users directly, while smaller ones must use licensed intermediaries; all must be licensed or registered with the Bank of Russia. (https://forklog.com/en/the-end-of-shadow-trading-russias-forthcoming-crypto-market-rules/; https://crypto.news/russia-clears-draft-laws-to-tighten-crypto-trading-and-limit-retail-participation/)

Mandatory licensing for intermediaries: Covers digital exchanges, custodial services, trading platforms, and DFA operators; banks, brokers, and securities firms can provide services after authorization.

Criminal liability for unlicensed operations: Entities organizing digital currency circulation without Bank of Russia approval face fines ($1,300–$13,000), up to 4–7 years imprisonment, or forced labor; applies to exchanges and large operators.

Registration as DFA operators: Russian banks/exchanges must register with Bank of Russia, which maintains the registry and supervises operations.

Compliance with KYC, competency tests for retail (via intermediaries), and reporting thresholds (e.g., transactions >600,000 RUB/year to tax authorities).

Retail limits: Annual purchases capped at 300,000 RUB (~$3,700–$3,800) via one intermediary; requires knowledge test. Qualified investors (e.g., high income >20M RUB/year, finance master's) face no limits.

Prohibitions: No domestic payments with crypto; reporting mandatory for large transactions. International trade exception since 2024.

Local Presence: Entities must have Russian legal status; foreign platforms without licenses are prohibited for domestic operations.

2020 Law on Digital Financial Assets (DFAs): Legalizes crypto transactions but prohibits use as payment for domestic goods/services; mandates reporting of transactions over 600,000 rubles to tax authorities.

2024 Law: Permits digital currency payments in international trade to bypass sanctions, creating an exception to the domestic ban.

Rosfinmonitoring (Federal Financial Monitoring Service): Handles anti-money laundering (AML) and counter-terrorism financing (CFT); monitors transaction data from crypto providers.

Bank of Russia (Central Bank of Russia): Primary regulator; proposes/implements rules, supervises financial institutions, registers digital financial asset (DFA) operators, establishes experimental regimes, and bans domestic crypto payments.