Prepared in cooperation with Financial Karaulny, this note explains key legal changes starting 01.09 and the transition until 01.07.2027.

Overview of the legal shift

From 01.09 the 282-FZ framework moves from text to enforceable law, opening central bank registers and triggering licensing procedures.

The transition period runs through 01.07.2027, but the formal split between regulated market and unlicensed segment begins immediately.

Permitted operations with caveats

Holding assets and occasional trading remain allowed, though individuals must report gains and pay NDFL 13–15% on income from disposals.

• Withdrawals to bank cards: continue to carry existing risks under 115-FZ, with stricter bank powers coming from 01.07.2027.
• P2P: exposure to banking controls remains, and large repetitive transfers may fall under 171.7 of the Criminal Code with penalties up to 7 years.
• Exchangers: informal services will need a license and ₽35 M capital or otherwise become classified as unlicensed by mid‑2027.
• Referral programs: already regulated by Article 14.3 of the Code of Administrative Offences, with fines for individuals of ₽2–2.5 thousand and for unmarked internet promotion from ₽30 K.

What is prohibited

Payments for goods and services inside the country cannot be settled in cryptocurrency, including salaries in USDT or property purchases for bitcoin.

Exceptions include certain external trade settlements, miner rewards, network fees, and specified operations with securities and digital rights.

Practical precautions to avoid prosecution

Do not turn a private wallet into a regular exchange point for other people’s funds; such activity will attract law enforcement attention.

• Keep transaction proofs, exchange orders, trading history, and bank statements to demonstrate legitimate investment activity.
• Declare and pay taxes on realized gains promptly and retain supporting documents for audits.
• Avoid repeated, round‑sum P2P operations with unknown counterparties and require explanations for unusual incoming funds.
• Respond promptly and factually if a bank requests documentation, and monitor the central bank register as it becomes available.

Who should be concerned

Operators running unlicensed currency exchange businesses via personal accounts face the highest risk and must choose between licensing and ceasing activity.

Ordinary retail investors will face testing, access limitations to highly liquid instruments, and new limits, but are unlikely to be targeted if they comply with reporting rules.