Crypto: Russia restricts personal wallets, but preserves international payments

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A non-custodial, or non-custodial, wallet allows the user to control their private keys without entrusting custody to a platform. Conversely, a depository service keeps these elements on behalf of its clients and intervenes in the execution of their operations.

Vladimir Chistioukhin indicates that the use of personal wallets by Russian investors was the subject of discussions during the preparation of the text. The authorities ultimately ruled out their direct use for investment, citing in particular the prevention of money laundering and the maintenance of state control.

The measure therefore concerns the modalities of access to these wallets from the infrastructure supervised by Russia. It does not mean that the central bank recovers the private keys already held by users.

The manager also specifies that a transfer from a Russian depository wallet to a foreign depository wallet remains possible. The funds can then join a non-custodial wallet. This possibility clearly distinguishes the system from a general ban on keeping your own cryptocurrencies.

The regulations thus favor intermediaries identified at the entry and exit points of the Russian system. On October 29, the Bank of Russia also announced the registration of the first self-regulatory organization of digital custodians and cryptocurrency exchange operators.

For cross-border payments, the position is explicit: the use of non-custodial wallets is authorized, says Vladimir Chistioukhine. The central bank therefore distinguishes between resident investment and international settlement operations.

This distinction gives the actors concerned more latitude in organizing their payments. However, it does not allow us to conclude that any international transaction escapes other regulatory obligations, nor that all investors have the same direct access to personal portfolios.

At the same time, Moscow is developing the digital ruble, another form of currency that is based on the Bank of Russia platform. Since September 1, 2026, the largest banks must allow its use. The acceptance obligation also concerns their corporate clients with annual turnover of more than 120 million rubles, subject to the exceptions provided for.

This system does not, however, constitute a mandatory replacement for crypto wallets. The central bank specifies that individuals remain free to open or not an account in digital rubles and to choose between the different forms of national currency.

Russian policy thus organizes different access depending on usage: supervised intermediaries for investment and an exception for international regulations. Control concerns authorized circuits and their operators, without giving the State technical control of all private keys.

Machine-translated from French