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Who Will Control Russians' Private Keys? Analyzing the New Crypto Law

Russian regulators will require users to share private keys with the government starting in 2026, reshaping the crypto landscape.

James Park
March 25, 2026 2 min read
Who Will Control Russians' Private Keys? Analyzing the New Crypto Law

Starting in 2026, Russian authorities will mandate that cryptocurrency users share their private keys with the government, fundamentally altering the landscape of digital asset management in the country.

In a recent discussion, Andrey Tugarin, founder of GMT Legal, outlined the implications of the new legislation titled "On Digital Currency." He emphasized that peer-to-peer (P2P) trading will essentially be eliminated, as the law will impose stringent regulations on crypto transactions.

Tugarin noted that the current gray market, which thrived due to the isolation of Russian banks, will face severe restrictions and oversight. With the introduction of digital depositories, all crypto transactions must go through these custodians, requiring users to consent to share access keys with these entities.

Under the new framework, individuals will still have the option to hold cryptocurrencies abroad, but any attempt to sell these assets within Russia will necessitate transferring them to local exchanges operating through the digital depository system. This arrangement means that both users and custodians will hold keys to wallets, and any withdrawal will require mutual agreement.

The rationale behind such stringent controls, according to Tugarin, stems from regulators' limited understanding of cryptocurrency. While there are concerns about the lack of clarity in the existing framework, Tugarin pointed out that the new legislation could lead to greater transparency and stability for exchanges seeking legitimacy with banks and regulatory bodies.

Regarding the role of traditional banks, Tugarin explained that they will primarily focus on monitoring fiat transactions rather than integrating into the crypto market. Although banks may establish separate legal crypto exchanges, they will need to adhere to a cautious approach due to the perceived risks associated with digital assets.

The law also stipulates that trading will be restricted to well-established cryptocurrencies with at least five years of history, a move aimed at protecting unqualified investors from potential losses. However, qualified investors and institutional players will not face these limitations, allowing them to engage with a broader range of assets.

While anonymous cryptocurrencies like Monero and Zcash will be banned for trading within Russia, users can still hold them on foreign platforms. Tugarin advised against panic selling, as the list of banned assets may expand in the future.

In terms of compliance, ordinary users will not face new reporting obligations for transactions abroad, but legal exchanges must provide detailed transaction data to the government. The annual investment limit for non-qualified investors is expected to remain, although the specific amount is yet to be determined by the Central Bank.

Tugarin’s insights reflect a broader concern among businesses about navigating the evolving regulatory landscape. He recommends that companies assess their legal standing and ensure compliance to avoid penalties, particularly when relocating operations abroad. Popular jurisdictions for such moves include the Seychelles, Panama, and Costa Rica, as well as neighboring countries like Belarus and Kyrgyzstan, which offer clearer regulations for crypto businesses.

As entrepreneurs prepare for the impending changes, Tugarin advises them to remain adaptable and seek expert guidance in a climate of legal uncertainty. He cautions against overlooking regulatory requirements, such as notifying tax authorities about controlled foreign companies, which can lead to hefty fines if ignored.