Mikhail Uspenskiy

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Stablecoins and DFAs

Legal support for projects involving digital financial assets and stablecoins: DFA issuance, non-standard tokenisations through hybrid DFAs on open blockchains, and the use of stablecoins in settlements. A practice shaped both by public expertise and by work on the relevant regulation.

Issuance

DFA issuance

Structuring an issue of digital financial assets: choosing an information-system operator, constructing rights under the asset, issue documentation, and supporting placement.

Hybrid

Hybrid DFAs on open networks

Non-standard tokenisations that connect the Russian DFA regime with circulation on open blockchains. One of the most complex and least explored structuring directions in the market.

Settlements

Stablecoins in settlements

Legal assessment and structuring of stablecoin use, including cross-border settlements. See Cross-border settlements in cryptocurrency.

Regulation

Regulation in 2026

Law No. 282-FZ set a new regulatory contour, including provisions on stablecoins. Full briefing — on the page of Law No. 282-FZ.

Questions

Common questions

How do DFAs differ from cryptocurrency?
DFAs are digital rights issued in information systems under Russian law, with a defined obligated person. Digital currency has no obligated person. The distinction is fundamental: the instruments have different legal regimes, taxation and permitted operations.
What are hybrid DFAs on open networks?
Constructions in which an asset is issued within the Russian DFA regulatory perimeter but technologically circulates on an open blockchain. Such solutions combine legal certainty with open-network liquidity, yet require careful structuring.
Can a non-standard asset be tokenised?
As a rule, yes: the DFA regime allows a wide spectrum of constructed rights. The key question is a correct legal description of the right underlying the token and the choice of a suitable information system.
Is it lawful to settle in stablecoins with foreign counterparties?
Legal mechanisms exist for cross-border settlements; their frame is set by the relevant legislation. The permissible construction depends on the parties’ status and the nature of the deal — a matter for individual structuring; more on the page on cross-border settlements.
What did Law No. 282-FZ change for stablecoins?
The statute included provisions affecting stablecoin circulation within the overall regulation of digital currencies and digital rights. A full briefing is on the page /crypto-law.
Who may issue DFAs?
Issuance is effected through information-system operators entered in the Bank of Russia register. Choosing an operator for the issuer’s task is part of structuring the issue.
Is a DFA issue suitable for raising finance?
Yes, DFAs are used as a fundraising instrument alongside classical ones. Suitability depends on the issuer’s profile, target investors and the economics of the issue.
Where does work on a DFA project begin?
With a legal review of the business task: which asset or right is tokenised, who the investors are, what liquidity is sought. The outcome is a legal architecture for the issue and a roadmap.
Next

Cross-border settlements — practice area; the statutory framework — Law No. 282-FZ. Complex mandates with Parallax.

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