Russia -- Licensing Requirements Regulatory Overview

Russia operates a mandatory licensing regime for cryptocurrency intermediaries, including exchanges, custody providers, and related services, rather than a mere registration system. All domestic crypto transactions must occur through these licensed entities, with unlicensed operations facing administrative fines and potential disqualification for up to 2 years.[1][2][5][7]

Required Licenses by Service Type

• 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.[3][4]
• 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.[3][1][2][5]
• 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.[3][1]

Traditional banks and brokers can provide these services under their existing licenses plus specific prudential compliance.[2][4][5]

Key Requirements

• Capital: Not explicitly detailed in available sources; prudential requirements apply to banks/brokers, varying by turnover and operations (e.g., for exchangers).[3][4]
• 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.[1][3][5][7]
• Local Presence: Entities must have Russian legal status; foreign platforms without licenses are prohibited for domestic operations.[3][5]

Only Bank of Russia-approved highly liquid cryptocurrencies (excluding anonymous ones) are permitted for retail; qualified investors face fewer limits.[1][3][5]

Application Process

The process involves obtaining licenses from the Bank of Russia (Central Bank) or inclusion in its register, with banks/brokers using a notification pathway. Specific steps are outlined in draft bills like “On Digital Currency and Digital Rights,” submitted to the State Duma. Details include compliance with prudential norms, knowledge assessments for users, and infrastructure setup (e.g., for depositories).[1][2][3][4][7]

Regulatory References

• Draft bills on digital currencies/digital rights, approved by government and introduced by Ministry of Finance (Minfin): Channel trades through intermediaries; no direct URL in sources, referenced via [2].
• Bank of Russia register for exchangers/depositories and prudential rules: Licensing/notification for exchanges; competency tests: Implicit in [3][4].
• Comprehensive bill “On Digital Currency and Digital Rights” for State Duma submission: Covers licensing, caps, infrastructure: Detailed in [3].

Note: Regulations stem from late 2025/early 2026 drafts (e.g., Constitutional Court ruling Jan 2026); full enactment status may evolve, as sources describe forthcoming rules without confirming final laws.[3] No comprehensive crypto-specific regime was in place pre-2026 per older overviews.[9] Specific application forms/URLs unavailable in results; consult Bank of Russia or Minfin directly (e.g., cbr.ru, minfin.gov.ru).