Russia’s Federal Law No. 282-FZ “On Digital Currencies and Digital Rights” enters into force on 1 September 2026 and phases in through 2027. For foreign crypto exchanges, payment providers and custodians with Russian users, two dates matter most: 30 June 2027, the deadline after which unlicensed systematic trading of digital currency becomes illegal even for residents (Art. 55(28)), and 1 July 2027, when Art. 21 and Art. 30(1) take effect — residents must transact only through licensed intermediaries, and Russian banks must block transfers to “unauthorised recipients” and to foreign payment service providers named on a Bank of Russia list. We help foreign platforms work out, in plain English, what this means for their specific business and what to do before the clock runs out.
What we do
- Regulatory impact memo: a 10-15 page assessment in English of exactly what changes for your business — whether your current model falls under the “exchange operator” activity test (systematic trades above RUB 3.5 million/month, Art. 18(1)-(2)), whether your marketing or offers to Russian users are now restricted (Art. 1(9), (11), (12)), and your exposure to the Art. 21 blocking mechanism;
- Bank of Russia list-risk review: how the Art. 21 register of “unauthorised recipients” and foreign payment service providers works, what triggers inclusion, and how banks will apply the block to transfers and card transactions;
- Action plan to the deadlines: a sequenced plan against 30 June 2027 and 1 July 2027 covering your options — apply for the Bank of Russia register, partner with a licensed Russian intermediary, restructure how you serve Russian clients, or wind down that part of the business in an orderly way;
- Advertising and offer review: whether your marketing addressed to Russian users triggers the prohibitions on advertising digital currency as a means of payment or on public offers to exchange it for securities;
- Regulatory watch subscription: tracking future Bank of Russia acts — including the still-unpublished list of jurisdictions barred from holding shares in a Russian exchange operator or depositary (Art. 55(20)).
How it works
- Intake call to map your current touchpoints with Russian users: trading, custody, payments, advertising, referral channels.
- We draft the regulatory impact memo against the specific articles that apply to your model, with a risk rating for each activity.
- We walk through the options with you — register, partner, restructure or exit — and their rough cost and timeline.
- You decide; if you want to proceed with any option, it becomes a separate, scoped engagement.
What we don’t do
We do not promise a Bank of Russia register entry or a licence — the act listing barred shareholder jurisdictions under Art. 55(20) has not been published yet, and no foreign group can be pre-cleared against a rule that does not exist. We do not advise on routing payments through third parties to sidestep Art. 21 after 1 July 2027 — that is precisely the workaround the law was built to close. We do not quote penalty amounts: 282-FZ itself creates no administrative or criminal offences, and the implementing amendments to the Code of Administrative Offences have not been adopted. Every memo states plainly which points rest on the current text and which depend on acts the Bank of Russia has not yet issued.
Who this is for
- Foreign crypto exchanges and OTC desks with Russian retail or corporate users;
- Payment service providers processing transfers that touch Russian bank accounts or cards;
- Custodians and wallet providers holding digital currency or digital rights for Russian clients;
- Compliance and legal teams who need a defensible, dated position before their board or regulator asks for one.
FAQ
We have no Russian legal entity — does 282-FZ even apply to us?
The law does not need to reach you directly to affect you: Art. 21 obliges Russian banks to block transfers to foreign recipients they suspect of unauthorised digital currency activity, and Art. 30(1) restricts what Russian residents may legally send you. The practical effect lands on your Russian user base regardless of where you are incorporated.
What happens if we do nothing before 30 June 2027?
Systematic trading with Russian residents above the RUB 3.5 million/month threshold becomes unlawful for the counterparty, and from 1 July 2027 banks are required to block related transfers. In practice this cuts off your Russian volume rather than exposing you personally, but it happens abruptly unless you plan for it.
Can we just wait for the Bank of Russia acts before doing anything?
You can wait to file for the register, but the advertising and offer restrictions in Art. 1 already apply, and the transitional window in Art. 55 for filing documents runs to 1 September 2027 — leaving it late narrows your options rather than removing risk.
Is this a one-off report or ongoing coverage?
The memo is a one-off deliverable. Because the law’s most consequential provisions (the shareholder jurisdiction list, capital and infrastructure norms, transaction limits) are delegated to acts the Bank of Russia has not yet published, most clients pair the memo with our monthly regulatory watch subscription. Related exposure on inbound authority requests is covered separately by our authority requests to brokers and payment services desk.
Pricing
Regulatory impact memo: from USD 2,500, delivered in English within 10 business days of the intake call. Regulatory watch subscription: from USD 300 per month, delivered as a monthly English-language digest of Bank of Russia and government acts issued under Art. 55(20), Art. 31, Art. 34 and related experimental legal regime programmes. Action plans and options assessments beyond the memo are quoted after intake — pricing on request. Background on the law itself is in our article-length breakdown of 282-FZ.
Get started
Send a short description of how your platform touches Russian users to law@vfs.consulting or use the contact form. We reply within one business day with our standard mutual NDA and a scoped proposal.
