282-FZ closes the informal route into the Russian crypto market and opens a formal one. A foreign exchange, custodian or information-system operator cannot itself hold the licence — Art. 41(1), Art. 43(1) and Art. 44(1) each require the operator, digital depositary or exchange organisation to be a business entity established under Russian law. What follows is a genuine build decision: incorporate in Russia and go through the Bank of Russia register, partner with an existing licensed Russian player, or wait. We help foreign groups make that decision on facts, not on hope for a licence the law does not yet let anyone promise.
What we do
- Options assessment: a side-by-side comparison of (a) incorporating a Russian entity and applying to the Bank of Russia register as an exchange operator, digital depositary or information-system operator; (b) a partnership or white-label arrangement with an existing licensed Russian broker or exchange; (c) the narrower foreign-organiser-of-trading status available to brokers in cases the Bank of Russia defines (Art. 34(7)); and (d) the ExFR/experimental-regime channel for narrower use cases;
- Entity and capital planning: what a Russian exchange organisation needs — minimum own funds of RUB 15 million (Art. 44(3)), a Russian legal entity structure (Art. 41(1), Art. 43(1), Art. 44(1)), and primary and backup technical infrastructure located in Russia (Art. 43(6), Art. 44(4));
- Register application support: preparing the documentation package for Bank of Russia register inclusion, including the two-year transitional qualification period for management experience requirements (Art. 55(16)-(17));
- Conflict-of-interest and internal governance documents: the internal policies operators and depositaries are required to maintain (Art. 41(11), Art. 43(8));
- Honest flagging of the open question: the Bank of Russia has not yet published the list of jurisdictions barred from holding shares in a Russian exchange operator, depositary or information-system operator (Art. 55(20)) — we tell you where your group’s jurisdiction currently stands relative to what is publicly known, and what changes if the act comes out against you.
How it works
- Scoping call on your group structure, target activity (exchange, custody, information system) and expected volume.
- We deliver the options memo comparing incorporation, partnership and ExFR routes, with a rough cost and timeline for each.
- If you choose to build, we move into entity formation, capital and infrastructure planning, and register application drafting as a separate, staged engagement (typically 6-12 months).
- If you choose to partner, we identify and vet candidate licensed Russian counterparts and structure the arrangement.
What we don’t do
We do not promise register inclusion or a licence to a foreign-owned group before the Bank of Russia publishes the Art. 55(20) jurisdiction list — anyone who tells you otherwise is guessing at a rule that does not exist yet. We do not treat the Art. 34(7) foreign-organiser-of-trading route as generally available; it applies in cases the Bank of Russia defines, and no such act has been issued. We do not quote a fixed capital or infrastructure cost beyond the RUB 15 million statutory minimum, because the detailed adequacy and technical-infrastructure norms are delegated to Bank of Russia acts not yet published (Art. 41(7)-(10), Art. 43(3)-(5), Art. 44(3), (5)).
Who this is for
- Foreign exchanges, custodians and payment platforms evaluating a genuine Russian market entry rather than continued informal access;
- Groups whose current Russian volume is at risk from the 30 June 2027 deadline and want a licensed path rather than an exit;
- Investors and management teams who need a defensible build-vs-partner-vs-wait decision for their own board before committing capital.
FAQ
Can our foreign parent company hold the Russian licence directly?
No. Art. 41(1), Art. 43(1) and Art. 44(1) all require the licensed entity itself to be established under Russian law. A foreign parent can own the Russian entity, subject to the shareholder jurisdiction question in Art. 55(20).
Is our jurisdiction going to be on the barred list?
No one can say yet — the act has not been published. We track Bank of Russia rulemaking under our regulatory watch subscription and flag it the day it appears; see our law breakdown for the current state of play.
How long does the register application actually take once we’re ready to file?
There is no established practice yet — the register is new. We build the timeline into the options memo based on the transitional deadlines in Art. 55 (documents due by 1 September 2027 for transitional participants) rather than promising a fixed processing time.
Is partnering with a licensed Russian broker faster than building our own entity?
Usually yes for market access, though it means sharing economics and depending on their licence status. We lay out both paths with real trade-offs in the options memo rather than defaulting to one.
What if we decide market entry isn’t worth it?
That is a legitimate outcome of the options assessment. If you decide to wind down instead, that is a separate managed-exit engagement, distinct from this one.
Pricing
Options assessment and comparative memo: pricing on request, scoped after the initial call on your group structure and target activity. Entity formation, licensing and register application support: staged engagement over 6-12 months, retainer basis; detailed pricing depends on the Bank of Russia capital and infrastructure acts still pending. Regulatory watch subscription covering the Art. 55(20) jurisdiction list and related acts: from USD 300 per month.
Get started
Send a short description of your group structure and target Russian activity to law@vfs.consulting or use the contact form. We reply within one business day under NDA.
