282-FZ does not ban digital currency settlement in Russian foreign trade — it carves it out. Art. 1(6)-(7) exempts the use of digital currency and digital rights as a means of payment under foreign trade contracts between residents and non-residents from the general prohibition, and Art. 18(5) and Art. 30-31 set the conditions. For exporters and importers already settling in USDT with Russian counterparties in a legal grey zone, the law gives a route to do it properly — but only through the right contract clauses, the right intermediary, and the right paperwork for the bank on the other side.
What we do
- Contract clauses: drafting or reviewing the payment mechanism in your foreign trade contract so the digital currency settlement falls squarely within the Art. 1(6)-(8) exemption, including the agency-model structure the law contemplates for the paying party;
- Choice of authorised organisation or ExFR channel: identifying which transitional “authorised organisation” or liquidity provider under the experimental legal regime (ExFR, extending the 259-FZ framework) can process your settlement, given that these participants retain their status only until they file for the Bank of Russia register — deadline 1 September 2027 (Art. 55(1), (3), (5));
- Bank-side confirmation package: the documentation a Russian correspondent bank or your counterparty’s bank will ask for to process the underlying fiat leg or confirm the transaction is lawful, covering currency-control reporting for the underlying contract;
- AML/CFT positioning: mapping your settlement flow against the identification and disclosure obligations that apply to intermediaries (Art. 37 for nominee/authorised holders; general AML referrals to Federal Law 115-FZ), so the structure survives a compliance review on either side of the border;
- Legal opinion in English: a written opinion confirming the settlement structure fits the foreign-trade exemption, for your own board, auditors or the counterparty’s bank.
How it works
- You send us the contract (or its draft) and a description of the settlement flow — currency, intermediary, counterparty bank.
- We map it against Art. 1(6)-(8), Art. 18(5) and Art. 30-31 and flag anything that falls outside the exemption.
- We draft the clauses and identify the authorised organisation or ExFR channel that can process the settlement.
- You receive the legal opinion and bank-facing documentation package to move the transaction forward.
What we don’t do
We do not structure settlements designed to disguise a payment as something other than what it is, and we do not work with counterparties who cannot pass ordinary sanctions and AML screening. We do not promise a specific bank will accept the settlement — banks retain discretion, and Art. 21 requires them to refuse transfers to unauthorised recipients regardless of how the contract is drafted. We do not guarantee ExFR programme approval or timing: these regimes are approved by the Bank of Russia case by case, in coordination with Rosfinmonitoring and the FSB, and there is no established practice yet on how long that takes.
Who this is for
- Exporters and importers trading with Russia from China, Turkey, the UAE, India and CIS countries who currently settle informally in USDT or other digital currency;
- Trading houses and logistics companies structuring new contracts that anticipate digital currency settlement;
- Correspondent banks and payment intermediaries in friendly jurisdictions asked to process the fiat leg of such a deal and needing a legal basis to point to;
- Compliance teams needing to know, before the deal closes, whether a proposed structure survives a later audit.
FAQ
Is crypto settlement for Russian trade actually legal now, or only from some future date?
The foreign-trade exemption in Art. 1(6)-(7) is already part of the law and takes effect with it on 1 September 2026; it is not one of the provisions deferred to 2027. What is still being worked out by the Bank of Russia is the detail of which authorised organisations and ExFR programmes can process it at scale.
Do we need a Russian-licensed exchange to do this?
Not necessarily. The exemption runs through the foreign trade contract itself and the authorised organisation/ExFR channel, not through a general-purpose digital currency exchange licence — but the two tracks can overlap depending on your volume and setup.
What happens after 1 July 2027 when Art. 21 and Art. 30(1) take effect?
Those provisions target payments to unauthorised recipients and require residents to work through licensed intermediaries generally — they do not repeal the foreign-trade exemption, but they raise the bar for who can sit in the chain. A structure that relies on an unregistered counterpart is more exposed after that date.
Can you also confirm that a specific inbound request from a Russian bank or authority about our settlement is genuine?
Yes — that is a related but separate service; see our law enforcement and authority request verification desk.
How long does the whole structuring process take?
A straightforward single-contract review with existing counterparties typically takes 2-3 weeks from receiving the contract to delivering the opinion; identifying and onboarding a new authorised organisation or ExFR channel takes longer and is scoped separately.
Pricing
Deal structuring, including contract clause review and the English-language legal opinion: pricing on request, scoped after we see the contract and settlement flow. Ongoing settlement support once a structure is in place: retainer, pricing on request. For background on the law’s foreign-trade provisions, see our breakdown of 282-FZ.
Get started
Send your contract (or a description of the intended settlement flow) to law@vfs.consulting or use the contact form. We reply within one business day under NDA.
