The Russian digital asset market is entering a new era. The adoption of the law "On Digital Currencies and Digital Rights," combined with the 21st EU sanctions package, is creating a unique "hybrid" structure that will divide the industry into three clearly defined levels. This is not just a regulatory initiative — it is a fundamental restructuring of the entire ecosystem.
The new regulatory act establishes the legal status of cryptocurrencies, allowing their ownership, acquisition, disposal, and mining, as well as permitting their use in foreign trade settlements with non-residents. However, domestic settlements in cryptocurrency within the Russian Federation remain prohibited. The key point is that the law forms a three-level infrastructure for the circulation of digital currencies, where each level requires participants to have a different set of licenses and infrastructure capabilities.
Three levels of the new architecture
The first level consists of existing exchange platforms. The Moscow Exchange and the Saint Petersburg Exchange have established infrastructure, valid licenses, and well-tuned clearing mechanisms. In my assessment, they will be the first to receive permits for organizing digital currency trading.
The second level consists of financial brokers with a client base, licenses from the Bank of Russia, and data storage infrastructure. Sber, T-Investments, BCS, Finam, and VTB are the key players in this tier. They will act as a bridge between traditional finance and crypto assets.
The third level consists of exchangers and the OTC segment. The requirements for business reputation and AML/CFT procedures here effectively exclude the legalization of "gray" exchange offices. The predicted scenario is the creation of subsidiaries by banks or the entry of new legal entities into the market under the control of well-known financial groups.
Sber holds a special place — it is the only participant present at all three levels simultaneously. Its infrastructure and legislative framework were developed in parallel, giving it a tremendous competitive advantage.
External vector and the effect of sanctions
The 21st EU sanctions package has affected the digital financial asset sector on such a large scale for the first time. Including crypto operators in the sanctions list is a precedent-setting step that creates risks for infrastructure oriented towards European jurisdiction and stimulates the flow of activity to decentralized and friendly platforms.
The combined effect of two vectors — internal legalization and external pressure — forms a "hybrid" model. On the one hand, a legal institutional environment is being created, where the beneficiaries are the Moscow Exchange, SPB Exchange, and leading financial brokers. On the other hand, external pressure has for the first time deliberately targeted crypto operators, stimulating a shift to DEX, P2P, and stablecoins.
My expert conclusion: Retail holders receive a civilized framework for fiat exit and lending, but their activity in the decentralized segment will only grow. The Russian market demonstrates resilience developed over 20 previous sanctions packages, and this "hybrid" model is not a temporary phenomenon but a new reality. The key trend is the parallel existence of a banking circuit for legal operations and a decentralized segment for cross-border and protective transactions.