The three-tier model of the crypto market: how the new law and EU sanctions are changing the rules of the game in Russia
The adoption of the law "On Digital Currencies and Digital Rights," combined with the 21st package of European Union sanctions, creates two fundamentally different but complementary development vectors for the Russian digital asset market. As a result, a unique "hybrid" model is emerging, combining a regulated banking circuit for legal operations and a decentralized segment for cross-border and protected transactions.
The new regulatory act establishes the legal status of cryptocurrencies and regulates their circulation, mining, and use in foreign trade settlements. Key provisions of the document permit the ownership, acquisition, disposal, and mining of digital currencies, and also allow their use in settlements with non-residents. At the same time, domestic settlements in cryptocurrency remain prohibited.
The most interesting consequence of the law is the formation of a three-tier market infrastructure. Each tier will be occupied by participants with different sets of licenses and infrastructure capabilities.
Three Tiers of the New Infrastructure
The first tier — existing exchange platforms: the Moscow Exchange and the St. Petersburg Exchange. They have established infrastructure, valid licenses, and well-functioning clearing mechanisms. It is logical to assume that they will be the first to receive permits to organize trading in digital currencies.
The second tier — financial brokers with a client base, Bank of Russia licenses, and data storage infrastructure. Key players here are Sber, T-Investments, BCS, Finam, and VTB. It is predicted that banks will create subsidiary structures for working with cryptocurrencies, or new legal entities under the control of well-known financial groups will enter the market.
The third tier is allocated to exchangers and the OTC segment. Requirements for business reputation and AML/CFT procedures effectively exclude the legalization of "gray" exchange offices. This means the market will be cleared of dishonest intermediaries.
Sber holds a special position — it is the only participant present on all three tiers simultaneously. Its infrastructure and legislative framework were developed in parallel, giving the bank a tremendous advantage. Sber's head, German Gref, confirmed at the St. Petersburg International Economic Forum in June 2026 the bank's intention to conduct the full range of operations, "including exchanging fiat currency for cryptocurrency."
External Vector: Sanctions Pressure
The 21st EU sanctions package has, for the first time, affected the digital financial asset sector on such a large scale. The inclusion of crypto operators in the sanctions list was a precedent-setting step. However, as practice shows, the Russian market demonstrates resilience developed over the previous 20 packages. Expected directions of transformation include a shift in activity to DEX and P2P platforms, growth of stablecoins, an increase in operations through friendly jurisdictions, and the development of the digital financial assets market.
The combined effect of the two vectors forms that very "hybrid" model: on one hand, a legal institutional environment with key beneficiaries in the form of the Moscow Exchange, St. Petersburg Exchange, and leading financial brokers; on the other, a decentralized segment for protected and cross-border transactions.
My expert conclusion: Retail cryptocurrency holders in Russia gain a civilized circuit for fiat exit and lending but lose anonymity in the legal sector. External pressure will stimulate the development of decentralized solutions and friendly jurisdictions, which in the long term could make the Russian crypto market one of the most technologically flexible in the world.