Entering 2026, Russia remains one of the few CIS countries without comprehensive regulation of cryptocurrency circulation. On the one hand, cryptocurrency transactions are not prohibited in the country; on the other, the activities of crypto exchangers and exchanges are unregulated, stablecoins and a number of other crypto assets have no legal status, and taxation has not been fully worked out.

2025, in turn, exposed a number of reasons why further delay in regulating cryptocurrency circulation has become impossible.

The first is the significant growth of the grey exchange market. Most purchases and sales take place via unsupervised P2P exchange using the accounts of front persons — "drops". This has led to a surge in fraud schemes and an influx of dirty money into the P2P segment, which in turn has caused mass blocking of bank accounts under anti-money laundering legislation (Laws No. 115-FZ and No. 161-FZ).

The second is that miners — the only fully lawful participants in cryptocurrency circulation in the country — have no legal way to sell the cryptocurrency they mine within Russia. The lack of official exchanges and exchangers forces Russian miners to sell what they mine abroad — for example, through infrastructure in Belarus and other jurisdictions — or to turn to the grey exchange market.

The third is the lack of a legal status for stablecoins. This legal uncertainty deprives stablecoin holders of guaranteed judicial protection and clear tax rules. The lack of status also raises tax questions — for example, whether transactions in stablecoins are subject to VAT.

The fourth is the FATF (Financial Action Task Force) assessment of whether regulation meets high anti-money laundering and counter-terrorist financing (AML/CFT) standards. Recall that the lack of regulation of crypto exchangers, exchanges and custodians runs contrary to FATF recommendations.

Clearly, the regulator needs to take every possible measure to create comprehensive and transparent regulation of cryptocurrency circulation; otherwise the consequence will be inclusion on the grey list.

Why are these reasons so important, and what are the real consequences of the lack of regulation of cryptocurrency circulation in Russia?

Grey crypto exchange: risks, mass blocking and the fight against drops

Crypto exchanges and exchangers in Russia have no legal status. Public demand for cryptocurrency transactions is therefore met through informal channels: exchanger websites without a legal entity, and P2P trading chats and bots.

The main type of transaction is P2P with settlement through banks. Third-party accounts are widely used for this — "drops" who provide their bank cards for a fee. As a result, banks flag suspicious transactions and apply blocking measures under Law No. 115-FZ. Both drops' accounts and those of ordinary citizens accidentally caught up in "triangle" schemes (where a payment passes through a third party) are blocked.

Moreover, for persons accidentally caught up in a triangle, a second ground for blocking arises — signs of fraudulent transactions under Law No. 161-FZ. The cryptocurrency seller's details are then added to the Central Bank's database of cases and attempts of transactions made without the client's voluntary consent.

Mass bank blocking has become inevitable in cryptocurrency transactions because the "P2P market" is completely uncontrolled.

Besides blocking, 2025 saw stepped-up criminal prosecution. Drops used to get off with administrative measures, but since this summer criminal liability has also been introduced under Article 187 of the Criminal Code ("Unlawful circulation of means of payment"). For example, in Surgut a fraudulent group converted criminal proceeds into cryptocurrency through a network of drops and moved them abroad; as a result, three suspects were arrested and a case was opened under Article 187(5) of the Criminal Code.

In its Financial Market Development Strategy for 2026–2028, the Bank of Russia announced the creation of an "Antidrop" information system by 2027. The system will allow banks to share information about individuals involved in shadow transactions and quickly block their access to financial services.

Put simply, there will be a single database of drops into which the Central Bank will require banks to enter data (to this end, it is reportedly planned to link all citizens' bank accounts to their taxpayer numbers to identify clients more accurately).

Legalisation of mining: first results and unresolved issues

On 1 November 2024, a law legalising cryptocurrency mining came into force. 2025 was a test year for the registers of miners and mining infrastructure operators. The results were encouraging: by October 2025 the register already listed 1,364 miners and about a hundred infrastructure operators.

The register's functionality can also be used to file monthly reports on the amount of cryptocurrency mined. The exact amount of tax received from miners has not yet been disclosed, but the value of cryptocurrency mined in the first three quarters of 2025 was about RUB 32,000,000,000. At the same time, a number of issues remained unresolved in 2025.

Whether foreign persons can mine on equipment located in Russia: the law does not expressly determine whether foreign companies may mine in Russia or obtain resident miner status, for example by setting up a permanent establishment.

Cloud mining is not regulated — when Russian citizens rent capacity abroad or, conversely, foreigners use Russian farms remotely. Such services fall outside the legal framework: it is unclear how income from cloud mining should be accounted for and who must report to the tax authority.

"Grey" equipment. A significant share of ASIC devices was brought into the country through grey schemes without full payment of customs duties at a time when mining was unregulated. As a result, the devices operate but are formally outside the law, and their owners are reluctant to declare them for fear of fines for breaching customs rules. According to market participants, thousands of miners remain in the shadows. In 2025 the state acknowledged the problem: the Ministry of Finance said it was ready to grant a one-off amnesty for previously imported mining equipment.

Problems selling what has been mined: miners have been given the legal right to mine but no mechanism for selling what they mine within the country. Miners are forced to use foreign exchanges and exchangers. Moreover, the tax authority's methodologies for determining the exchange value of cryptocurrencies refer only to foreign platforms, since there is no domestic market. In practice, many miners set up companies or accounts in friendly jurisdictions (Belarus, Kazakhstan, etc.) where the sale of cryptocurrencies is permitted. The result is a strange paradox: you can mine crypto, but you can practically never sell it within the country.

The legal vacuum around stablecoins

The situation with stablecoins deserves special attention. 2025 showed how ambiguous their status is in Russian law — and until 2024 stablecoins had no status in legislation at all.

In 2024, legislators introduced the concept of "foreign digital rights", which indirectly covers stablecoins backed by foreign currency or other assets. Within the country, such foreign digital rights can circulate only if they qualify as digital financial assets — which, given the nature of stablecoins, is entirely possible.

However, under Bank of Russia Directive No. 7036-U, foreign digital rights admitted to circulation in Russia must have an issuer from a "friendly" state only, which effectively makes it impossible for 99% of the most popular stablecoins to enter domestic circulation.

The consequences of this legal vacuum have shown up in case law. Because stablecoins have no legal status, a simple case to recover a debt of 1,000 USDT went all the way to the Constitutional Court. The problem was that the lower courts refused the creditor's claims against the debtor by wrongly classifying USDT as a digital currency. At the Constitutional Court hearings in November, it was stated outright that USDT is not a digital currency. However, no final decision stating exactly what USDT is has yet been issued.

The lack of recognition of stablecoins also complicates tax accounting. Only digital currency is exempt from VAT; there are no special rules for foreign digital rights. Accordingly, USDT transactions between two Russian tax residents could in theory be taxed like ordinary goods, creating a risk of additional tax assessments for market participants.

Conclusion

At the end of 2025, the Russian crypto market remains in a grey zone: mining has been legalised, but there are no legal mechanisms for selling mined cryptocurrency in Russia, the activities of exchanges and exchangers are unregulated, and the status of stablecoins and the tax consequences of transactions in them remain uncertain.

In these conditions, cryptocurrency circulation is moving into the informal P2P segment, increasing the risks of fraud, the use of drops, bank account blocking and criminal prosecution. The lack of comprehensive regulation perpetuates legal uncertainty for crypto market participants and prevents the emergence of a transparent infrastructure for its circulation.

If you carry out cryptocurrency transactions, mine or use stablecoins and need to assess the related legal, tax and compliance risks, the C Cases team can offer a solution tailored to your needs and the specifics of your business.

Sources

1. Federal Law No. 259-FZ of 31.07.2020 "On Digital Financial Assets, Digital Currency and Amendments to Certain Legislative Acts of the Russian Federation";
2. Federal Law No. 115-FZ of 07.08.2001 "On Countering the Legalisation (Laundering) of Criminal Proceeds and the Financing of Terrorism";
3. Federal Law No. 161-FZ of 27.06.2011 "On the National Payment System";
4. Criminal Code of the Russian Federation No. 63-FZ of 13.06.1996;
5. Bank of Russia Directive No. 7036-U of 10.01.2024 "On Requirements for Foreign Digital Rights That May Be Admitted to Circulation as Digital Financial Assets".