Is a licence required for cryptocurrency exchange in Russia?
With the Digital Currencies and Digital Rights Act in force, exchange services must be included in the Bank of Russia operator register. A licensing transition period runs until 1 July 2027.
What happens to exchanges that do not join the register?
Activity outside the register after the transition period will be unlawful — from blocking to liability of management. Special offences are also being prepared: draft Arts. 171.6 (unlawful mining) and 171.7 of the Criminal Code (unlawful organisation of digital-currency circulation), and Art. 15.29.1 of the Code of Administrative Offences. A legalisation strategy is best set before the regulator begins enforcement.
What requirements apply to an exchange operator?
The core requirements are set by Law No. 282-FZ itself: a business entity formed under Russian law; own funds of at least RUB 15 million for non-credit organisations (Art. 44); internal control and risk-management systems (Art. 47); requirements for governing bodies and founders (Arts. 49–50); admission to activity through the Bank of Russia (Art. 52); membership in a specialised SRO (part 9 of Art. 18). Detail is set out in Bank of Russia regulations issued in stages.
Must an exchange join an SRO?
Yes, but the duty does not arise at once: while no specialised self-regulatory organisation exists, there is nowhere to join. As soon as the first NPO obtains exchange SRO status, the entire market must join within 90 days. For the first two years such SROs are not subject to the requirement to cover at least 26% of the market — status can be obtained with a small membership. Establishing the first SRO is a distinct strategic opportunity for industry leaders.
How long does entry into the register take?
A realistic horizon is several months: preparing corporate structure and documentation, filing the dossier, engaging with the regulator. Early preparation before secondary rules are finalised shortens the timeline at exit.
Can a foreign company obtain operator status?
The law requires a business entity under Russian law; for foreign groups the solution is structuring through a Russian operating company with a carefully designed ownership chain.
What should an exchange do with an existing client base in the transition period?
Operations can continue, but processes should be rebuilt in parallel for future requirements: updating client contracts, identification procedures, internal policies. A properly managed transition preserves the client base without stopping the business.
How do the operator register and bank requirements relate?
Banks already request confirmation of counterparties’ status on crypto transactions, often ahead of the register itself. A legally sound position allows responses to such requests during the transition period as well.
Does regulation extend to private sales and P2P?
The law sets a numerical threshold: sales of digital currency above RUB 3.5 million put the seller into the status of an organisation carrying out exchange, with all register consequences (Art. 18). One-off deals below the threshold remain in the private sphere; systematic activity is assessed by a set of indicators.
Where to start legalising an exchange business?
Start with an audit: the current model is matched against statutory requirements, a gap map is formed and a plan to close gaps prioritised by risk. Then — documents, procedures, dossier.
