Russia's Virtual Asset Trading Law Takes Effect: 300,000 Ruble Annual Cap Proposed for Non-Qualified Investors

Russian Federal Law No. 282-FZ, the Law on Digital Currency and Digital Rights, came into force on September 1 local time, with the exception of some provisions. The Bank of Russia has proposed guidelines that would allow non-qualified individual investors, after passing a test, to buy highly liquid virtual assets up to a maximum of 300,000 rubles per year per intermediary. Qualified individual investors must also pass a test, but face no restrictions on instruments or amounts. The new market infrastructure includes virtual asset exchange operators and digital depositories that record ownership rights, and trading through brokers, asset managers and organized trading platforms is also permitted. The same requirements that apply to virtual assets apply to foreign stablecoins as well. However, paying for goods or services with virtual assets inside Russia remains prohibited. Import and export companies may use virtual assets in cross-border settlement either through intermediaries or directly through wallets. By contrast, Russian residents trading virtual assets abroad must use foreign bank accounts, and moving virtual assets purchased in Russia overseas must go through a regulated intermediary. Under the accompanying Law No. 283-FZ, Russian residents must, as a rule, report to the tax authorities their virtual asset transactions conducted using identification addresses not managed by a digital depository. The relevant reporting provisions take effect on May 2, 2027, and the specific reporting procedures will be set by the Russian government in consultation with the central bank. Market participants are subject to a transition period through July 1, 2027 to obtain licenses and put their operations in order, so the entry into force of the law and the point at which the market is fully operational do not coincide.