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Who gets Russians’ private keys? Dissecting the draft crypto law

A lawyer unpacks Russia’s draft crypto law and wallet controls in a Deconstruction special.

25.03.2026 ForkLog

In 2026 Russia’s regulators want to exert direct control over users’ crypto wallets and make them share their private keys with the state.

In a Deconstruction special, Andrey Tugarin, founder of law firm GMT Legal, explains what legal trading in Russia will look like and where to relocate a business if you decide to leave.

ForkLog (FL): With the new “On Digital Currency” bill, is P2P trading in Russia really over?

Andrey Tugarin (A. T.): The bill exists; the jokes are over; work on it is well under way behind closed doors. In its current guise—transfers to strangers’ bank cards—P2P trading will definitely vanish.

This grey market ballooned because Russia’s banks were isolated. Now everything will be tightly capped and policed; arbitrage and spread-hunting will disappear.

FL: Regulators want to rebuild the market from scratch and introduce digital depositories. What will they do?

A. T.: They are custodians through which asset storage, wallet administration and transactions will run. Any organiser of crypto trading in Russia will have to connect to such a depository.

Users may keep crypto abroad, but to sell it legally in Russia they will have to route assets into a local exchange. That exchange, in turn, may operate only via a digital depository’s infrastructure.

FL: So users will have to share their private keys with this new entity?

A. T.: It will be quasi-custody: both the user and the depository will hold keys to the wallet. Moving funds will require joint consent.

If, at the Bank of Russia’s direction, the depository dislikes the destination exchange, it will simply block the transaction. The mass user is unlikely to open such wallets; lawful businesses will be forced to.

FL: Why is the regulator opting for such tight controls?

A. T.: The regulator does not always grasp the business and technical side of crypto; hence many of the problems. The industry has been in a grey zone for five years, so new curbs understandably annoy.

There is a big upside: clearer, transparent rules of the game. Exchanges will stop operating on sufferance and will be able to justify their status to banks and the state.

FL: What role will traditional banks play in the new system?

A. T.: Banks, as credit institutions, do not slot into the crypto market; their job is to police fiat flows. They will retool compliance and assess clients’ crypto deals for suspicion.

A bank can, within its holding, set up a separate licensed crypto exchange or broker. But the Bank of Russia demands a conservative approach to digital assets, treating them as maximum risk.

FL: One provision of the law states that only top coins with at least a five‑year track record may be traded. Why narrow the menu so sharply?

A. T.: This applies only to public trading and only to non‑qualified investors. The regulator is signalling care: it does not want people buying random junk and losing their savings.

Qualified investors, miners and banks’ OTC deals are exempt. They understand the risks and may work with any available assets.

FL: Privacy coins are banned for everyone. Should one urgently dump Monero and Zcash?

A. T.: No need to dump, and there is no point panicking at every new restriction. Yes, within Russia’s legal perimeter you will not be able to work with such assets.

The law bans their circulation domestically, but nothing stops you from holding them on foreign platforms. The blacklist will likely grow; factor that risk in.

FL: Will users have to report every crypto transfer abroad to the state?

A. T.: For ordinary users, no new reports are being introduced yet. Their duty is unchanged: file a 3‑NDFL declaration if they realised income from a transaction.

However, licensed Russian exchanges will have to pass KYC-data and information on your operations to the state. So details of your transfers will reach the regulator via the platforms anyway.

FL: Will the 300,000‑rouble annual cap for retail investors remain?

A. T.: The very idea of limits will certainly remain; it is embedded in the Bank of Russia’s approach. But the bill does not set a specific figure.

The cap for non‑qualified investors will be set by separate Bank of Russia regulations. Whether it stays at 300,000 or changes is a matter of technical calibration.

FL: What do tech and Web3 companies most often ask you?

A. T.: The top question is: “Are we doing everything legally?”. Founders want to know how to launch an innovation without running into fines in a given jurisdiction.

We analyse their business model, pick the right licences and build lawful payment solutions. Our job is to make the project a compliant player within tight regulatory constraints.

FL: Where is it safe to base IT firms and crypto businesses when relocating right now?

A. T.: There is no universal answer; it depends on where working with Russian roots is feasible today. For an easy start, people often pick the Seychelles, Panama or Costa Rica, whereas the popular Emirates are now heavily congested.

Among nearby neighbours, Belarus and Kyrgyzstan are doing well with clear, transparent rules. Jurisdiction is assembled like a construction set to fit goals, budget and banks’ willingness to open accounts.

FL: How should one split Russian and international business perimeters to avoid sanctions?

A. T.: There must be absolutely no legal or operational links between them. If the same owner runs both companies, that is easy to trace and creates sanctions risk.

Separate everything: from IP and the founders’ line-up to website design. Technically, this means separate platform versions, with the Russian entity serving only Russia and the international one the rest of the world.

FL: What is the costliest mistake founders make when setting up a foreign entity?

A. T.: They simply forget to notify Russia’s tax service about a controlled foreign company. It is a simple form, but ignoring it has dire consequences.

The fine is 500,000 roubles for each year of non‑notification. Forget your foreign company for three years and you have 1.5m roubles in fines for nothing.

FL: Your top advice to an entrepreneur for 2026.

A. T.: If it feels as though the law offers no obvious answers and everything is collapsing—do not be scared. Constant legal uncertainty is entirely normal for innovative business.

Do not wait for crystal‑clear laws before acting. You can operate successfully amid uncertainty—just lean on competent experts.

This conversation has been edited for length. Full podcast episode: