Russia Issues First Licenses for Legal Crypto Exchanges and Digital Depositaries

The Bank of Russia issued the first licenses on October 6 to five organizations, marking the country’s first formal step toward bringing crypto activity out of the shadows. For high-risk payment providers, the important part is not the headline number but the operating model: who can touch crypto, who can custody it, and which domestic rails will now sit between users and the blockchain.

1. Five organizations received the first licenses: VTB, Sberbank, AO “Woltari” (Web3Tech Group), “Atomize” (part of “T-Technologies”), and LLC “Oblacnaya infrastruktura” (ultimate beneficial owners not disclosed). In addition, four players — VTB, “T-Invest Lab” (part of “T-Technologies”), LLC “Zephyr,” and LLC “Sistema-Crypto” — were registered as crypto exchanges.
2. Under the new law “On Digital Currency and Digital Rights” dated September 1, digital depositaries are Russian legal entities that keep records of digital currency or digital rights, handle transfers of digital currency, and provide access to identifier addresses where digital currency is recorded. They can open accounts for both Russian and foreign persons, but they come with capital requirements: at least 250 million rubles, 100 million rubles for organizations that only keep records of crypto, and no less than 50 million rubles for other digital depositaries.
3. Individuals in Russia who want to invest in crypto assets will have to pass testing. For non-qualified investors, the law also introduces a cap on the maximum size of the portfolio, but the exact threshold is not set in the law and will be determined by the Bank of Russia. There is also a yearly limit of 300k per one professional market participant.
4. Within Russia, investors will be able to store cryptocurrency and make transactions only through crypto wallets opened inside the domestic infrastructure. Cold and non-custodial wallets are available only to participants in foreign economic activity. Operations with cryptocurrency outside Russia are not regulated by Russian law, and the domestic restrictions do not apply to them.
5. The infrastructure is set up as a cascading, two-tier model similar to the securities depository system. The upper-tier digital depository is the infrastructure player that records digital currencies and digital rights, opens nominee-holder accounts for lower-tier depositaries, and manages crypto keys and blockchain interaction. The lower-tier digital depository is a bank or broker: it records its clients’ rights to digital currencies but does not hold them directly on-chain, instead opening a nominee-holder account with the upper-tier depository.

One detail worth watching for payment operators: the law does not force a hard split between upper-tier and lower-tier digital depositaries, and direct clients of a digital depository can be both individuals and legal entities — though private individuals are only meant to access lower-tier depositaries. For banks, the article’s own read is blunt: this is an unprofitable setup, useful mainly as part of a product strategy inside a banking group tied to Russia’s digital-currency market.