Remote VASP serving residents in Russia

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

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.

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.

Bank of Russia register for exchangers/depositories and prudential rules: Licensing/notification for exchanges; competency tests: Implicit in .

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).

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.

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

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.

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/)

Bank of Russia approves "highly liquid" cryptos for retail and enforces via registry maintenance.

Adoption and effective date: No adoption or effective date; Russia's FATF suspension requires it to still meet standards in theory, but no evidence of legislative action specific to the Travel Rule for VASPs exists in available data.