Mikhail Uspenskiy

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Cross-border settlements in cryptocurrency

The Digital Currencies and Digital Rights Act (No. 282-FZ of 04.08.2026) legalised the use of digital currency in foreign-trade settlements — and required businesses to rebuild accounting, the contractual base and banking relationships. The practice covers the full loop: from choosing a settlement model to reflecting transactions in accounting and tax records.

Core

Stablecoins and accounting

Core competence — building a complete tax and accounting system for importers and exporters that use digital currencies and dollar stablecoins in settlements. The methodology covers the timing of income and expense recognition, foreign-exchange differences, documentary support for tax authorities, and correct reflection of the fiat–digital currency–goods chain. A separate focus is the legal basis for lawful circulation of dollar stablecoins, prepared well before the current wave of regulation.

Contracts

Contractual framework

Contractual constructions for settlements via payment agents and direct: clauses on the moment an obligation is performed, allocation of FX risk, compliance with currency law and the digital-currency statute.

Compliance

Supporting bank compliance

Banks routinely ask crypto-transaction participants for the economic rationale of deals, sources of funds and business-model detail. Preparing responses to such requests, packs of supporting documents, and preventive alignment of the operating model with compliance requirements.

Questions

Common questions

Is it lawful to settle in cryptocurrency under foreign-trade contracts?
Yes. Settlements in digital currency under foreign-trade contracts have been legalised — first under an experimental regime, and with the Digital Currencies and Digital Rights Act on a permanent footing. The key condition is compliance with requirements for settlement participants and correct documentation of transactions.
Can one pay for imports in USDT?
Dollar stablecoins formally fall under digital currency of foreign issuers, so settlements in them are possible but require careful legal packaging: from choosing an intermediary counterparty to readiness to justify the transaction to the bank.
How to reflect stablecoin settlements in accounting?
There is no single standard yet — accounting policy has to be built from general norms. In practice one fixes the moment digital currency is recognised, valuation rules, foreign-exchange differences and document flow. Building such an accounting system is one of the practice’s core services.
Do taxes arise when settling in cryptocurrency for goods?
Yes. Transfer of digital currency in payment is treated as its disposal with corresponding tax consequences; the foreign-trade transaction itself is accounted for in parallel. Correct setup avoids double economic taxation of a single deal.
What to do if a bank requests explanations of cryptocurrency transactions?
Respond — the requests are lawful and ignoring them is risky. A prepared pack: economic rationale, contractual base, sources of funds, description of the business model. Preventive preparation of such materials removes most questions before they arise.
Must one report foreign crypto assets and wallets?
The duty to report wallets arises on 1 May 2027 — 270 days from the official publication of companion Law No. 283-FZ (04.08.2026). Forms and reporting procedure are still being developed, but the deadline is fixed: a documented asset history should be prepared in advance, without waiting for the forms.
How do settlements via a payment agent differ from direct ones?
An agency model shifts operational work with digital currency to an intermediary, but requires verification of its status and contractual protection of the principal. A direct model gives control but raises requirements for own accounting and compliance. The choice depends on volumes and deal structure.
Which jurisdictions are realistic today for crypto settlements with Russia?
In practice — primarily CIS countries; regulators expressly allow continued settlement cooperation with some of them. The specific scheme depends on the goods group, participating banks and the sanctions landscape.
Where to start moving to digital-currency settlements?
Start with diagnostics: analysis of contracts, banking relationships and the accounting model, after which a roadmap is built — contractual framework, accounting policy, compliance pack. Typical time to stand up the system is several weeks.
Next

Complex settlement mandates are delivered by the agency team Parallax. Legal context — in the law briefing No. 282-FZ; related practice area — exchange licensing.

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