Gaps in the Regulation of Cryptocurrency Circulation in Russia
Entering 2026, Russia remains one of the few CIS countries without comprehensive regulation of cryptocurrency circulation. On the one hand, transactions with cryptocurrency 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 several reasons why further postponing the regulation of cryptocurrency circulation is no longer possible.
The first reason is the significant growth of the grey exchange market. Most buy and sell transactions are carried out through unsupervised P2P exchange using the accounts of nominee individuals, so-called money mules ("droppers"). This has led to a surge in fraud schemes and an inflow of dirty money into the P2P segment, which in turn has triggered mass freezes of bank accounts under anti-money laundering legislation (Federal Laws No. 115-FZ and No. 161-FZ).
The second reason is that miners, the only fully legal participants in cryptocurrency circulation in the country, have no legal way to sell the cryptocurrency they mine within Russia. The absence of official exchanges and exchangers forces Russian miners to sell their output abroad (for example, through infrastructure in Belarus and other jurisdictions) or to resort to the grey exchange market.
The third reason is the lack of legal status for stablecoins. This legal uncertainty deprives stablecoin holders of judicial protection and clear tax rules. The lack of status also raises tax questions, for example whether transactions with stablecoins are subject to VAT.
The fourth reason is the FATF (Financial Action Task Force) assessment of whether regulation meets high standards for anti-money laundering and countering the financing of terrorism (AML/CFT). It should be noted that the lack of regulation of crypto exchangers, exchanges and custodians contradicts 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 cryptocurrency regulation in Russia?
Grey crypto exchange: risks, mass account freezes and the fight against money mules
Crypto exchanges and exchangers in Russia have no legal status. As a result, public demand for cryptocurrency transactions is met through informal channels: exchanger websites without a legal entity, chats and bots for P2P trading.
The main type of transaction is P2P with settlement through banks. This widely relies on the accounts of third parties: money mules who provide their bank cards for a commission. As a result, banks flag suspicious transactions and apply blocking measures under Federal Law No. 115-FZ. Both mule accounts and accounts of ordinary citizens accidentally drawn into "triangle" schemes (where a payment passes through a third party) are frozen.
Moreover, for persons accidentally drawn into a triangle, a second ground for blocking arises: signs of fraudulent transactions under Federal Law No. 161-FZ. The cryptocurrency seller's details are then entered into the Bank of Russia database of cases and attempts of transactions carried out without the client's voluntary consent.
Mass bank account freezes have become an inevitable part of cryptocurrency transactions due to the total lack of control over the P2P market.
Beyond account freezes, 2025 saw stronger criminal prosecution. Previously, money mules often got away with administrative penalties, but since the summer of this year criminal liability has been introduced under Article 187 of the Russian Criminal Code, "Unlawful circulation of means of payment". For example, in Surgut a fraud group converted criminal proceeds into cryptocurrency through a network of mules and moved them abroad; as a result, three defendants were arrested and a case was opened under Part 5 of Article 187 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 on individuals involved in shadow transactions and promptly cut off their access to financial services.
Simply put, a single database of money mules will appear, and the Central Bank will require banks to enter data into it (to this end, it has been reported that all citizens' bank accounts are to be linked to their taxpayer identification numbers (INN) for more accurate client identification).
Legalisation of mining: first results and unresolved issues
On 1 November 2024, the 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 around a hundred infrastructure operators.
The register also allows miners to submit monthly reports on the amount of cryptocurrency mined. The exact amount of taxes paid by miners has not yet been disclosed, but the value of cryptocurrency mined in the first three quarters of 2025 was around RUB 32,000,000,000. At the same time, a number of issues remained unresolved in 2025.
Foreign persons mining on equipment located in Russia. The law does not directly state whether foreign companies may mine in Russia or obtain resident miner status, for example by establishing a permanent establishment for tax purposes.
Cloud mining is not regulated, meaning cases where Russian citizens rent capacity abroad or, conversely, foreigners use Russian mining farms remotely. Such services fall outside the legal framework: it is unclear how to account for income from cloud mining and who is required to report to the Federal Tax Service.
"Grey" equipment. A significant share of ASIC devices was imported into the country through grey schemes without full payment of customs duties at a time when mining was unregulated. As a result, the devices are operating but are formally outside the law, and their owners are reluctant to declare them for fear of fines for customs violations. According to market participants, thousands of miners remain in the shadows. In 2025 the state acknowledged the problem: the Ministry of Finance announced its readiness for a one-off amnesty for previously imported mining equipment.
Problems selling mined cryptocurrency. Miners were given the legal right to mine, but not a mechanism to sell what they mine inside the country. Miners are forced to use foreign exchanges and exchangers. Moreover, in its methodology for determining the exchange value of cryptocurrencies, the Federal Tax Service refers only to foreign platforms, since there is no domestic market. In practice, many miners open companies or accounts in friendly jurisdictions (Belarus, Kazakhstan, etc.) where selling cryptocurrency is permitted. The result is a strange paradox: you can mine crypto, but you practically cannot sell it inside the country.
The legal vacuum around stablecoins
The situation with stablecoins deserves special attention. 2025 showed how ambiguous their status is under Russian law, and until 2024 stablecoins had no status in legislation at all.
In 2024, legislators introduced the concept of "foreign digital rights" (FDR), which indirectly covers stablecoins backed by foreign currency or other assets. Within the country, such FDRs may circulate only if qualified as digital financial assets (DFA), which is quite possible given the nature of stablecoins.
However, under Bank of Russia Directive No. 7036-U, FDRs admitted to circulation in Russia must have an issuer only from a "friendly" state, 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 court practice. Because stablecoins lack legal status, a simple case to recover a debt of 1,000 USDT went all the way to the Constitutional Court. The essence of the problem was that the creditor's claims against the debtor were dismissed because lower courts misclassified the legal status of USDT, equating it with digital currency. At the Constitutional Court hearings in November it was stated directly that USDT is not a digital currency. However, no final court decision specifying what exactly USDT is has yet been issued.
The lack of recognition of stablecoins also complicates tax accounting. Only digital currency is exempt from VAT, and there are no special rules for FDRs. Accordingly, USDT transactions between two Russian tax residents could theoretically be taxed as transactions with 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 is legal, but there are no legal mechanisms for selling mined cryptocurrency within Russia, the activities of exchanges and exchangers are unregulated, and the status of stablecoins and the tax consequences of transactions with them remain uncertain.
Under these conditions, cryptocurrency circulation shifts into the informal P2P segment, increasing the risks of fraud, use of money mules, bank account freezes and criminal prosecution. The absence of comprehensive regulation perpetuates legal uncertainty for crypto market participants and prevents the development 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 objectives and the specifics of your business.
Sources
- 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";
- Federal Law No. 115-FZ of 07.08.2001 "On Countering the Legalisation (Laundering) of Criminally Obtained Income and the Financing of Terrorism";
- Federal Law No. 161-FZ of 27.06.2011 "On the National Payment System";
- Criminal Code of the Russian Federation No. 63-FZ of 13.06.1996;
- 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".