Russia’s New Rules for Cross‑Border Bitcoin Payments: What Businesses Need to Know
David Wallace 12 August 2025 24

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Cross‑border crypto payments in Russia are now permitted under a limited pilot regime that began in September 2024. If you run a company that trades with China, India, or any other market outside the Russian Federation, this change could open a cheaper, faster path for moving money. The new framework revolves around Federal Law No 221‑FZ, a three‑year experimental program that lets approved legal entities settle invoices with Bitcoin (BTC), Ethereum (ETH), Tether (USDT) and a few other tokens. Below is a practical guide that walks you through what the law means, how to get on board, and what to watch out for.

TL;DR - Quick Takeaways

  • Only companies approved for the cross‑border crypto pilot can use Bitcoin, Ethereum, or Tether for overseas settlements.
  • All transactions must flow through a certified digital‑asset platform operator approved by the Bank of Russia.
  • Domestic crypto use remains illegal; the pilot covers only international payments.
  • High‑frequency traders need to qualify as "highly qualified investors" (assets>100millionRUB or income>50millionRUB).
  • The pilot runs until 2027; a permanent regime may follow depending on compliance results.

Why the Shift Happened

Moscow’s economy has been under intense Western sanctions since February2022. Traditional correspondent banking routes dried up, pushing businesses to look for alternative settlement methods. In September2024, amendments to Federal Law On Digital Financial Assets (No259‑FZ) officially authorized the use of crypto‑tokens for cross‑border trade, but only under a tightly controlled experimental framework - Federal Law No221‑FZ. President Putin’s compromise directive framed crypto as a geopolitical tool rather than a domestic monetary experiment.

Legal Backbone: The Two Core Laws

The regulatory architecture rests on two statutes:

  1. Federal Law No259‑FZ (Digital Financial Assets) - establishes the definition of digital assets, licensing for exchanges, and AML/KYC obligations.
  2. Federal Law No221‑FZ (Pilot Programme for Cross‑Border Crypto Payments) - creates a three‑year sandbox that allows approved legal entities to settle foreign trade invoices with approved cryptocurrencies.

Both laws require participation through a certified digital‑asset platform operator. These operators act as conduits, performing AML screening, transaction logging, and reporting to the Central Bank.

Which Cryptocurrencies Are Allowed?

At launch, the pilot lists four assets:

  • Bitcoin (BTC) - the most liquid and widely accepted.
  • Ethereum (ETH) - useful for smart‑contract‑enabled trade finance.
  • Tether (USDT) - a stablecoin pegged to USD, favoured for price stability.
  • A Russian‑backed stablecoin (still under development) linked to the ruble.

Domestic‑only tokens, including the Digital Ruble, are prohibited for any payment purpose until a separate rollout starts in 2026.

How to Join the Pilot - Step‑by‑Step

  1. Determine Eligibility: Your entity must be a registered Russian legal person engaged in export‑oriented trade. The Ministry of Finance screens applicants for compliance history and financial stability.
  2. Apply through a Certified Platform: Choose one of the six approved platform operators (e.g., CryptoBridge, FinTechGate). The operator will forward your application to the Bank of Russia for final approval.
  3. Obtain ‘Qualified Investor’ Status (if required): For firms intending to hold crypto balances longer than 30days or trade derivatives, you must qualify as a “highly qualified investor” - assets>100millionRUB or annual income>50millionRUB.
  4. Integrate the Platform’s API: Most operators provide RESTful APIs for transaction creation, status monitoring, and automated KYC checks. Implement the API in your ERP or accounting system to avoid manual errors.
  5. Run a Test Settlement: The pilot mandates a sandbox transaction (usually 0.001BTC) to verify AML filters and reporting pipelines.
  6. Go Live: After passing the sandbox, you can start real settlements up to the cap set by the regulator (initially 2billionRUB per month per entity).

Every settlement must include a detailed invoice reference, purpose of payment, and the counter‑party’s BIC/IBAN equivalent for crypto (the “CCO” code). The platform logs the transaction in a central ledger that the Central Bank can audit in real time.

Market Impact So Far

Market Impact So Far

Official statistics released in March2025 show that cross‑border crypto‑facilitated trade hit 1trillionRUB in value. Energy firms are the biggest adopters - Russian oil exporters invoicing Chinese buyers have moved roughly 300millionUSD of BTC and USDT through the pilot. The A7 Group, a conglomerate partially owned by a sanctioned bank, publicly confirmed using USDT to settle $45million of equipment imports to India.

Despite the surge, domestic holdings remain modest. Roughly $25billion in digital assets is held by Russian residents, most of which sits on foreign exchanges because there is no licensed domestic exchange yet.

Compliance Hurdles & Risks

Even with a pilot, the compliance burden is heavy:

  • AML/KYC Scrutiny: The Bank of Russia requires real‑time monitoring for suspicious patterns. Failure can trigger criminal liability under the March2025 draft amendment.
  • Reporting Obligations: Every transaction must be reported within 24hours via the platform’s reporting API. Late filings attract fines up to 0.5% of the transaction value.
  • Technical Integration: Legacy ERP systems often lack crypto‑ready modules, necessitating custom development or third‑party middleware.
  • Counter‑Party Risk: While the pilot secures the Russian side, the foreign partner must also use a compliant platform, limiting your choice of counterparties.
  • Regulatory Uncertainty: The pilot expires in 2027. If the Central Bank decides not to extend or formalize the regime, all crypto settlements could become illegal overnight.

Future Outlook - What’s Next?

Analysts expect three possible trajectories after 2027:

  1. Full Adoption: The pilot proves successful, and the government codifies a permanent cross‑border crypto settlement regime, possibly widening the asset list to include more stablecoins.
  2. Limited Roll‑out: Only strategic sectors (energy, metallurgy) keep access, while most firms return to traditional banking channels.
  3. Regressive Clamp‑Down: If AML breaches rise, the Central Bank could suspend the pilot and tighten sanctions‑evading mechanisms.

In any case, the next step for businesses is to cement internal processes now, so a policy shift won’t catch you off guard.

Quick Comparison: Domestic vs. Cross‑Border Crypto Use

Key differences between domestic and cross‑border crypto usage in Russia
Aspect Domestic Use Cross‑Border Pilot Use
Legal Status Prohibited for payments Allowed for approved legal entities
Permitted Assets None for payment purposes BTC, ETH, USDT, Ruble‑stablecoin
Counter‑Party Requirement Not applicable Both sides must use certified platform operators
Reporting Frequency N/A Within 24hours per transaction
Risk of Criminal Liability High for any crypto transaction Low if operating inside pilot limits

Getting Started Checklist

  • Confirm your company qualifies as an export‑oriented legal entity.
  • Choose a certified platform (compare fees, API support, AML tools).
  • Prepare AML/KYC documentation for both your firm and major counterparties.
  • Develop or acquire ERP integration for the platform’s API.
  • Run the mandatory sandbox transaction and adjust internal controls.
  • Set up a compliance calendar for 24‑hour reporting deadlines.

Frequently Asked Questions

Can any Russian company start using Bitcoin for overseas payments?

No. Only companies that have been approved under Federal Law No221‑FZ and are operating through a certified digital‑asset platform can settle cross‑border invoices with Bitcoin or the other listed tokens.

What happens if a transaction is flagged by AML systems?

The platform must suspend the transfer and file a suspicious activity report with the Bank of Russia within 48hours. The company could face a fine or, in repeated cases, criminal prosecution.

Do I need to become a ‘highly qualified investor’ to use the pilot?

Not for basic invoice settlement. However, if you want to hold crypto assets for longer than 30days or trade derivatives linked to those assets, you must meet the investor‑qualification thresholds (assets>100millionRUB or annual income>50millionRUB).

Is the pilot limited to a specific amount of crypto per transaction?

Yes. The initial cap is 2billionRUB worth of crypto per month per entity, with the possibility of a modest increase after a mid‑pilot review.

Will the Digital Ruble be usable for cross‑border payments?

Not yet. The Digital Ruble is slated for domestic payments only, with a phased rollout beginning September2026 for large enterprises. Cross‑border use would require a separate amendment.

Staying ahead of the regulatory curve is no longer optional for Russian exporters. By integrating the pilot’s workflow now, you lock in a resilient payment channel that can survive sanctions and provide predictable cash flow. Keep an eye on the 2027 review - the next few years will decide whether crypto becomes a permanent fixture in Russia’s international trade toolbox.