Custodial wallet / SaaS in Russia

Custody Providers: Specialized digital depositories must be licensed or registered in the Bank of Russia's register to maintain records of cryptoasset rights and register wallets. They face restrictions like no lending of client assets and no liability for blockchain malfunctions or issuer blocks.

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

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

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).

AML/KYC: Implied through mandatory intermediary routing, de-anonymization procedures, transaction monitoring, and tax reporting. Retail users must pass a Bank of Russia competency test; residents report foreign wallets/transactions to tax authorities.

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

Custodial service providers, including banks like Sberbank, must comply with prudential requirements; Sberbank proposed custody services to the central bank, treating crypto assets similarly to bank deposits with mechanisms for freezing suspicious assets. (https://www.binance.com/en/square/post/27079019931473)

Digital depositories are required to maintain records of rights to cryptoassets, register wallets, and face restrictions like prohibiting lending of client coins to others. (https://forklog.com/en/the-end-of-shadow-trading-russias-forthcoming-crypto-market-rules/)

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.

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.

Comprehensive bill “On Digital Currency and Digital Rights” for State Duma submission: Covers licensing, caps, infrastructure: Detailed in .

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.

Simplified process for banks/brokers: Existing financial institutions may use a "notification process" tied to current banking licenses, rather than full standalone applications.

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.

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

Proposed 2026 Framework (to be adopted 2026, retail implementation by July 1, 2026): Legalizes buying/selling digital currencies and stablecoins as monetary assets for retail/qualified investors under tests/caps; allows licensed financial firms (exchanges, brokers) to offer services; permits purchases abroad via foreign accounts with tax reporting; prohibits privacy coins.

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.

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.