Previously, the principal rules governing cryptocurrency were established by Federal Law No. 259-FZ dated 31 July 2020, «On Digital Financial Assets, Digital Currency and Amendments to Certain Legislative Acts of the Russian Federation». It defined digital currency and digital financial assets and prohibited companies and individuals from accepting cryptocurrency as payment for goods, works, and services.
The new law establishes a more detailed regulatory framework. It sets out rules for the purchase, sale, and holding of cryptocurrency; the operation of exchange offices and other intermediaries; mining and transactions involving foreign digital instruments. At the same time, certain practical requirements will be established subsequently by the Bank of Russia.

1. Official cryptocurrency exchange offices will be introduced. Organizations entered in the Bank of Russia's register will be permitted to exchange rubles for cryptocurrency and vice versa. Cryptocurrency exchange offices will be subject to a minimum own-funds requirement of 15 million RUB and stringent security requirements. Users will be able to verify an exchange office against the official register before entering into a transaction.
2. Cryptocurrency may be held through specialized depositories. These organizations will record clients' digital assets and confirm their ownership. Their function is broadly comparable to the record-keeping function of a conventional securities depository.
3. Transactions will become more transparent to the authorities. Intermediaries will be required to verify clients, record transactions, and comply with anti-money laundering requirements. As a result, it will become extremely difficult to buy or sell cryptocurrency anonymously.
4. Restrictions will be introduced for certain purchasers. Non-qualified investors will be permitted to purchase the most liquid cryptocurrencies after passing a test and within a limit (no more than 300,000 RUB per year through a single intermediary; the limit is set by the Bank of Russia). Qualified investors will also be required to pass a test but will be able to acquire cryptocurrencies without a monetary limit.
5. A list of cryptocurrencies admitted to trading will be introduced. The Bank of Russia will determine which digital currencies may be purchased through the regulated Russian infrastructure. This does not mean that other cryptocurrencies will be completely prohibited, but access to them may be restricted. BTC and ETH are expected to be among the leading assets on the list.
6. The operation of professional intermediaries will become subject to licensing. Companies that regularly exchange cryptocurrency, hold it for clients, or manage it in the interests of clients will be required to obtain permission and comply with the Bank of Russia's requirements.
7. The rules will also apply to foreign platforms and wallets. Holding cryptocurrency on a foreign exchange or in a personal wallet is not prohibited. However, owners will shortly be required to notify the Federal Tax Service (the relevant procedure is being developed by the Bank of Russia and the Government), record the acquisition cost and transaction history, particularly when transferring assets into the regulated Russian environment.
8. The prohibition on payment for goods and services will remain in place. Cryptocurrency will not become legal tender in Russia. Businesses will continue to be prohibited from accepting Bitcoin, USDT, or other digital currencies from Russian customers as payment for goods, works, services, rent, or subscriptions.
9. Separate rules will remain in place for international settlements. Russian residents will be able to use digital currency in foreign trade transactions. However, an ordinary transfer to a foreign supplier will not automatically be permitted: the transaction must also comply with applicable currency-control requirements.
«Cryptocurrency may be used for international settlements, both for imports and exports, and in respect of a broad range of economic goods,» Mikhail Uspenskiy
explains.
10. The Bank of Russia will establish the detailed rules. The law itself sets out general principles.
Limits, testing procedures, detailed requirements for exchange offices and depositories, asset-custody rules, the list of available cryptocurrencies and many other matters will be addressed in separate regulatory instruments issued by the regulator. The Government, the Federal Security Service (FSB), and a number of other authorities will participate in developing these instruments.

«The rules governing the reporting of foreign cryptoassets are still under development, which means that there is no immediate requirement to declare all foreign digital currency. In addition, certain reporting concessions have been introduced for individuals who are currency residents but not tax residents of the Russian Federation. A related tax bill is also expected to be adopted to clarify a number of tax-accounting rules, particularly the procedure for recognizing expenses for individuals' income tax purposes,» Mikhail Uspenskiy says

Once the new rules enter into force, cryptocurrency may be purchased or sold in the following ways:

• Through a licensed broker. A broker will be able to purchase digital currency pursuant to the client’s instructions. The broker will verify the purchaser’s identity and comply with the Bank of Russia’s requirements.
• Through a licensed exchange office. Organizations will be permitted to officially exchange rubles for cryptocurrency and vice versa. To operate, they will be required to be included in the Bank of Russia’s register.
• On organized trading platforms. Certain digital currencies may be admitted to trading on Russian platforms. The Bank of Russia will determine the list of assets and the conditions. BTC and ETH are expected to top the list.
• Through small P2P transactions. A P2P transaction is a direct purchase of cryptocurrency from another individual. The purchaser transfers rubles to a bank account, while the seller transfers the asset to a wallet. Such transactions involve heightened risk. If a transfer appears to be connected with suspected fraudulent activity, the bank may suspend the transfer and request supporting documents. This segment is unlikely to survive after the transitional period.
• Through a foreign exchange. Holding and purchasing cryptocurrency through foreign accounts is not prohibited. Tax obligations, however, continue to apply. Reporting on ownership will also be introduced in the near future.
• Under the foreign economic activity (FEA) regime. Exporters and importers may purchase and use cryptocurrency directly for certain settlements with foreign counterparties. Such transactions are subject to special rules and must be conducted through authorized participants. The requirement to register the FEA contract remains in effect.

Under the new law, the following will be prohibited:

• Settlements in cryptocurrency for goods, services, works, or other consideration within Russia;
• Settlements in cryptocurrency for rent or other consideration within Russia;
• Advertising relating to the organization of cryptocurrency circulation must not contain guarantees or promises regarding the future effectiveness of the activity (investment returns), including guarantees or promises based on actual historical performance.

For most entrepreneurs, the new law does not prohibit dealing with cryptocurrency, but it changes the rules governing its circulation.

An individual entrepreneur may own, purchase, and sell cryptocurrency in accordance with applicable law. However, an individual entrepreneur may not accept cryptocurrency as payment for goods, works, or services within Russia. Where an individual entrepreneur uses digital assets for investment purposes or participates in transactions permitted by law, particular care should be taken with the documentation of such transactions and compliance with tax obligations.

Fundamentally, nothing changes for companies: cryptocurrency does not become legal tender. It may not be used for settlements with Russian customers or suppliers. At the same time, the law provides for the development of regulated infrastructure — licensed intermediaries, digital depositories, and trading organizers — through which most lawful digital-currency transactions are expected to be conducted in the future.

Self-employed individuals will likewise be prohibited from accepting cryptocurrency as payment for their services.

For businesses engaged in foreign economic activity, the law may create additional opportunities. It preserves the possibility of using digital currency in certain foreign trade transactions and under special legal regimes. Before using cryptocurrency for international settlements, the business should verify whether the specific transaction falls within the applicable rules.

The law regulates the circulation of cryptocurrency as property, but does not recognize it as a means of payment. Cryptocurrency may not be accepted:

• for goods;
• services;
• performed works;
• rent;
• subscriptions;
• as any other consideration;
• in an online store.

Tax obligations arise when the holder sells an asset, exchanges it at a gain, receives cryptocurrency through mining, and in other similar circumstances.

When cryptocurrency is sold, tax is calculated on the income received. The acquisition cost may be recognized as an expense where supporting documents are available.
For example, an individual purchases cryptocurrency for 500,000 RUB and later sells it for 650,000 RUB. Provided the expense is properly documented, the taxable base will not be the full sale proceeds but the difference of 150,000 RUB.
Without supporting documents, the tax authorities may disallow the acquisition cost as a deductible expense. It is therefore important to retain bank statements, exchange reports, agreements, and transaction records.

The accounting treatment depends on the holder’s status, the applicable tax regime, and the nature of the transaction. The purchase, sale, exchange, and mining of an asset may be accounted differently.
The use of special tax regimes (the simplified tax system, USN) for mining is expressly prohibited.
Before commencing transactions, it is advisable to determine:

• what income and expenses arise;
• the exchange rate to be used to convert the value into rubles;
• which documents substantiate the transaction;
• whether related expenses may be recognized.

For large or recurring transactions, it is preferable to agree in advance on the accounting treatment with an accountant, tax adviser, or lawyer.

The following documents may be useful to substantiate transactions:

• the purchase agreement or purchase order;
• an exchange, broker, or exchange-office report;
• a bank statement;
• information on the transaction date and exchange rate;
• wallet addresses;
• transaction hashes;
• evidence of fees and commissions;
• documents evidencing mining expenses.

The more complete the transaction history, the easier it will be to demonstrate the origin of the asset and calculate the tax correctly.

If your business already uses cryptocurrency or plans to work with digital assets, it is advisable to prepare for the new rules in advance:

• verify whether your transactions fall within those permitted by law;
• monitor the emergence of licensed intermediaries or offers to purchase digital assets from existing banks and brokers;
• retain documents evidencing the origin of digital assets and the transaction history;
• monitor the adoption of secondary legislation by the Bank of Russia, as these instruments will determine many of the practical rules governing the market.

Despite its considerable scope, the bill largely remains a framework instrument. Detailed procedures, requirements applicable to market participants, and procedures for carrying out specific transactions must be established by regulatory acts of the Bank of Russia. Accordingly, after the law is adopted, businesses should monitor not only the final text of the law but also subsequent guidance and clarifications issued by the regulator.

«Following the adoption of the principal law, „On Digital Currency and Digital Rights“ amendments to tax legislation and related areas are also expected in order to harmonize the new digital regulatory framework,» says Mikhail Uspenskiy.

Assuming that cryptocurrency has been completely banned
That is not the case. Owning, purchasing, holding, and selling digital currency remains permitted. The prohibition concerns payment for goods and services in cryptocurrency in Russia.
Accepting cryptocurrency from Russian customers
Bitcoin may not be accepted in payment for goods, works, rent, or services within Russia.
Recognizing any cryptocurrency as a Digital Financial Asset
Digital financial assets and cryptocurrency are different instruments. A digital financial asset has an issuer and a specific obligation toward its holder. Digital currency, by contrast, has a decentralized network of miners.
Holding assets only on a foreign centralized exchange
An account may be blocked, and the exchange itself may be flagged by AML screening services for sanctions-related risk. Transaction reports and supporting records should therefore be saved on a regular basis.
Ignoring the risks of P2P transactions
Bank transfers used to purchase cryptocurrency by card or through the Fast Payments System (FPS) will be blocked with increasing frequency and stringency and are expected to disappear after the transitional period.
Using a personal wallet for company assets
This makes it difficult to establish who owns the cryptocurrency. Corporate and personal assets should always be kept separate.
Forgetting about taxes
A sale or exchange of cryptocurrency may give rise to taxable income even if the assets remain on an exchange, are not converted into fiat currency, and are not transferred to a bank account.

«The most common mistakes are the absence of documents confirming the lawful acquisition of the cryptoasset, inadequate tax accounting, and the failure to assemble in advance a complete source-of-funds package for the bank’s compliance function,» Mikhail Uspenskiy explains.

Does the new law prohibit cryptocurrency?
No. It establishes rules governing its purchase, sale, holding, and exchange. However, cryptocurrency still may not be used to pay for ordinary goods and services within Russia.
Is it permitted to purchase Bitcoin?
Yes. The purchase and ownership of Bitcoin are not prohibited. The rules governing transactions through the Russian infrastructure, however, will depend on the Bank of Russia’s regulations.
Is it permitted to accept cryptocurrency from customers?
No, where the transaction concerns payment for goods, works, or services within Russia. From foreign customers in the context of foreign economic activity, however, it may be permitted.
Is tax payable on a sale of cryptocurrency?
Yes, if the transaction generates income. The acquisition cost must be supported by documentary evidence.
May an individual entrepreneur own cryptocurrency?
Yes. An individual entrepreneur may purchase, hold, and sell it. However, digital currency may not be used to accept payment from Russian customers. There are no obstacles to foreign cryptocurrency settlements where permitted by the applicable rules.
Is it permitted to hold cryptocurrency on a foreign exchange?
There is no express prohibition. However, the holder must comply with Russian tax rules and subsequently report to the Federal Tax Service.
How does cryptocurrency differ from the digital ruble?
Cryptocurrency is not Russia’s national currency and generally has no single issuer. The digital ruble is issued by the Bank of Russia and has the same value as the ordinary ruble.
How do digital financial assets differ from cryptocurrency?
A digital financial asset is issued by a specific organization on a Russian blockchain under a Bank of Russia license. Such an asset evidences the holder’s right to receive money or other property. Ordinary cryptocurrency generally does not involve such an obligation.
What rules will be introduced later?
The Bank of Russia is expected to establish requirements for intermediaries, procedures for maintaining registers, asset-custody rules, client-access conditions, and other practical requirements.