Russia's central bank has clarified that a crypto exchange cannot receive a customer's money or digital currency and simply leave its side of the trade to be completed later in the operating day. Its guidance requires simultaneous settlement or an immediate reciprocal transfer, rather than an open-ended same-day promise.
The clarification appears in answers updated on October 26 in the Bank of Russia's cryptocurrency market FAQ. The update addresses practical questions about exchange settlement, investor tests, accounting records and digital depositories. It explains the application of existing legislation, rather than announcing that a new cryptocurrency law took effect that day.
Settlement must follow the shortest practicable interval
The exchange answer cites Article 34 of Federal Law No. 282-FZ. The bank interprets immediate performance as the shortest interval possible, under the conditions in which a transaction is executed, between operations on digital and bank accounts. It does not prescribe a universal number of seconds or minutes.
As a benchmark, the regulator says those operations must at least be comparable in timing to delivery-versus-payment settlement used in securities markets. The distinction matters because completing both sides before the close of business is not, by itself, the standard described in the answer. The timing between the two sides remains relevant.
The FAQ separately addresses transfers to a foreign custodial wallet. A digital depository can determine, in its internal documents or operating terms, which evidence is needed to establish that the destination address is administered by a foreign organisation legally entitled to perform the relevant custody or digital-currency recording and transfer functions.
That answer concerns how a depository establishes the status of the destination wallet. It does not announce unrestricted permission for every overseas transfer. The responsibility described is to establish the foreign organisation's role and legal entitlement, with the evidence requirements set out by the depository itself.
Tests follow the institution, not each business activity
Another clarification deals with an intermediary that performs more than one regulated role. A positive cryptocurrency test result can be recognised by the same testing institution regardless of the capacity in which it originally administered the test, such as broker, manager, digital depository or crypto exchange.
The regulator links that treatment to Article 32, which associates the result with the testing person rather than its particular activity. The answer therefore does not establish a general right to carry a test result between unrelated institutions. It addresses multiple roles within the same testing institution.
The bank also distinguishes acquiring cryptocurrency from moving holdings that a customer already owns into a digital depository. It explains that the test condition for acquisition by a resident individual concerns a transaction involving a change of holder. A deposit that leaves ownership unchanged is treated differently in the specified circumstances.
For the deposit described in the question, the assets must previously have been outside an address administered by a digital depository. The answer permits crediting the resident depositor's digital account subject to the provisions it identifies in Article 31. It is not a blanket exemption covering purchases or every movement of cryptocurrency.
People recognised before September 1, 2026 as qualified investors for all transactions intended for qualified investors are also recognised for digital-currency transactions, the FAQ says. This addresses the scope of an existing qualification, rather than declaring all cryptocurrency users qualified investors.
Recordkeeping and digital analysis still apply
For banks recording acquired digital currency, the regulator addresses whether blockchain information, such as an explorer extract or screenshot, can serve as an accounting document. The credit institution must determine the form of its primary accounting document, and that document must contain the mandatory details required by accounting legislation.
Digital depositories can conduct operations even while the central bank has not issued the specific digital-analysis regulation discussed in the FAQ. However, they must still carry out digital analysis under their own rules, reflecting the nature, scale and organisation of their activities and the services they provide.
Those rules, and subsequent amendments, must be sent to the Bank of Russia within five working days of adoption. The absence of the central bank regulation does not remove these duties. That separates permission to operate from an exemption from the underlying compliance work.
Earlier coverage: Russia's crypto trading framework and July 2027 restrictions. Elsewhere, Brazil has set customer-choice requirements for crypto marketing.
