Russia's crypto market is being structured into three levels: a new architecture for digital assets
The adoption of the law "On Digital Currencies and Digital Rights," combined with the 21st EU sanctions package, is shaping a fundamentally new model for the Russian digital asset market. This refers to a "hybrid" structure where a legal banking circuit for fiat operations coexists with a decentralized segment for cross-border and protected transactions. This is not just a regulatory initiative — it is a strategic restructuring of the entire ecosystem.
What the new law establishes
The State Duma has adopted a regulatory act that officially establishes the legal status of cryptocurrencies and regulates their circulation, mining, and use in foreign trade settlements. The key provisions of the document are available in the parliament's electronic database. The law permits the ownership, acquisition, disposal, and mining of digital currencies, and also allows their use in settlements with non-residents.
At the same time, domestic settlements in cryptocurrency within Russia remain prohibited. Thus, a three-tier model for organizing the circulation of digital currencies is being formed, where each tier requires a different set of infrastructure and licenses from participants.
Three tiers of the new infrastructure
First tier — existing exchange platforms. The Moscow and St. Petersburg exchanges have established infrastructure, valid licenses, and well-functioning clearing mechanisms. It is logical that they will be the first to receive permits to organize trading in digital currencies.
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. They will become the conduits for retail investors into the legal crypto segment.
Third tier — exchangers and the OTC segment. Requirements for business reputation and AML/CFT procedures virtually 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 position — it is the only participant present on all three tiers simultaneously. Its legislative framework and infrastructure were developed in parallel, giving the bank a unique competitive advantage.
External vector and Sber's position
Sber's CEO German Gref stated at the St. Petersburg International Economic Forum in June 2026 the bank's intention to perform the full range of operations, including exchanging fiat currency for cryptocurrency. This confirms Sber's ambitions to become the central node of the new system.
The second vector is external sanctions pressure. The 21st EU sanctions package has affected the digital financial asset sector on such a large scale for the first time, and the inclusion of crypto operators in the sanctions list has become a precedent-setting step. This creates risks for infrastructure oriented towards the European jurisdiction and stimulates the flow of activity to decentralized and friendly platforms.
The Russian market demonstrates resilience developed over the previous 20 packages. Expected directions of transformation include a shift to DEX and P2P, growth of stablecoins, an increase in operations through friendly jurisdictions, and the development of the digital financial assets (DFA) market.
My expert assessment: We are witnessing the formation of a unique "hybrid" model, where the institutional segment (Moscow Exchange, SPB Exchange, leading brokers) will provide legal fiat entry and lending, while the decentralized segment will provide protection from sanctions risks. For retail holders, this means the emergence of a civilized circuit for exiting into fiat, but with continued access to international exchanges and hardware wallets. The key risk is potential pressure on infrastructure oriented towards Europe, which will accelerate migration to friendly jurisdictions.