In 2026, Russian regulators plan to directly oversee users' crypto wallets and require them to share their private keys with the government.
In a special edition of "Deconstruction," Andrey Tugarin, founder of GMT Legal, explained how legal trading in Russia will change and where to relocate your business if you decide to leave.
ForkLog (FL): With the new bill "On Digital Currency," are we really saying goodbye to P2P trading in Russia?
Andrey Tugarin (A. T.): The bill is already in existence; the jokes are over, and work is actively being done behind closed doors. In its current form, P2P trading—transfers to unfamiliar people—will definitely disappear.
This gray market has grown tremendously due to the isolation of Russian banks. Now, everything will be highly limited and under strict control, and arbitrage opportunities will completely vanish.
FL: They want to rebuild the market from scratch and introduce digital depositories. What powers will they have?
A. T.: These will be custodians through which asset storage, wallet administration, and transactions will occur. Any organizer of crypto transactions in Russia will have to connect to such a depository.
Users will be able to store cryptocurrencies abroad, but to sell them legally in Russia, they will need to transfer assets to a local exchange, which can only operate through the digital depository's infrastructure.
FL: So, users will have to share their private keys with this new entity?
A. T.: There will be quasi-storage: access keys to the wallet will be held by both the user and the depository. To withdraw funds, mutual consent from both parties will be required.
If the depository, at the direction of the Central Bank, disapproves of the destination exchange, it can simply block the transaction. Average users are unlikely to open such wallets, but legitimate businesses will have to.
FL: Why is the regulator opting for such strict control measures?
A. T.: The regulator does not always understand the business and technical aspects of cryptocurrencies, which leads to most problems. The industry has been operating in a gray area for five years, and any new restrictions understandably cause discontent.
However, there is a significant upside—transparent and clear rules will emerge. Exchanges will no longer operate on shaky grounds and will be able to legally justify their status to banks and government agencies.
FL: What role will traditional banks play in the new system?
A. T.: Banks, as credit institutions, will not integrate into the crypto market; their role will be strictly to monitor fiat flows. They will need to restructure compliance and assess clients' crypto transactions for suspicious activity.
At the same time, a bank can create a separate legal crypto exchange or broker within its holding. However, the Central Bank requires a conservative approach to digital assets, assessing maximum risk.
FL: One provision of the law states that trading will only be allowed with top coins that have a history of five years. Why limit the selection so much?
A. T.: This restriction applies only to public trading and is aimed at unqualified investors. The regulator is demonstrating concern to prevent people from buying dubious assets and losing their capital.
Qualified investors, miners, and OTC transactions for banks will not be subject to these limits. They understand the risks and can work with any available assets.
FL: Meanwhile, anonymous coins are banned for everyone. Should one urgently sell Monero and Zcash?
A. T.: There is no need to sell, and one shouldn't panic over every new restriction. Yes, it will be illegal to work with such assets within the Russian legal framework.
The law prohibits their circulation in the country, but no one can stop you from storing them on foreign platforms. However, the list of banned coins will likely expand, so keep that risk in mind.
FL: Will users need to report every cryptocurrency transfer abroad to the government?
A. T.: No new reporting requirements are being introduced for ordinary users. Their obligation remains the same: to submit a 3-NDFL declaration if they have received actual income from a transaction.
However, Russian legal exchanges will be required to provide KYC data and information about your transactions to the government. Thus, details about your transfers will still reach the regulator through the platforms themselves.
FL: Will the limit of 300,000 rubles per year for ordinary users' investments remain?
A. T.: The concept of limiting will definitely remain; it is already embedded in the approaches of the Bank of Russia. However, the specific amount is not included in the text of the bill.
The limit for "non-qualified" investors will be established by separate regulatory acts from the Central Bank. Whether they will keep it at 300,000 or change the figure is a matter of further technical adjustments.
FL: What requests do technology and Web3 companies most frequently bring to you?
A. T.: The main question from businesses is: "Are we doing everything legally?" Founders want to understand how to launch innovations without facing fines in a specific jurisdiction.
We analyze their business model, select the right licenses, and build legal payment solutions. Our goal is to make the project a legitimate player within strict regulatory frameworks.
FL: Where is it currently safe for IT companies and crypto businesses to relocate?
A. T.: There is no universal place; it all depends on where it is possible to operate with Russian roots today. For an easy start, many choose the Seychelles, Panama, or Costa Rica, while the popular Emirates are currently overloaded.
Among neighboring countries, Belarus and Kyrgyzstan are performing well with clear and transparent regulations. The choice of jurisdiction is assembled like a constructor based on specific goals, budget, and the willingness of banks to open accounts for you.
FL: How can one effectively separate Russian and international business structures to avoid sanctions?
A. T.: There should be absolutely no legal or operational connection between them. If the same owner manages both companies, it can be easily traced and creates a sanction risk.
Everything must be separated: from intellectual property and the composition of founders to website design. Technically, this can be resolved by creating separate versions of the platform, where the Russian structure operates only within Russia, while the international one serves the entire world.
FL: What is the most costly mistake founders make when opening a legal entity abroad?
A. T.: They often forget to submit a notification about the controlled foreign company to the Russian tax authorities. This is a very simple document, but ignoring it leads to fatal consequences.
The fine is 500,000 rubles for each year of non-notification. If you forget about your foreign company for three years, you could face a fine of one and a half million rubles for nothing.
FL: The main advice for entrepreneurs in 2026.
A. T.: If you feel that there are no obvious solutions in the legislation and everything is falling apart—don’t panic. A state of constant legal uncertainty is absolutely normal for innovative businesses.
Don’t wait for crystal-clear laws to start acting. You can work successfully with this uncertainty; you just need to rely on knowledgeable specialists.
The conversation has been shortened. Full podcast episode:
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