Bank of Russia gives peer-to-peer crypto trading until July 1, 2027

"State-linked" describes part of the licence list and not all of it. Of the 11 entities RBC counted ^[13], Cryptopolitan's report names seven: Sberbank, which is majority state-owned ^[7], and six companies that Russian media reports describe as private, three custodians and three exchanges ^[14]. Four stay unnamed ^[15]. VTB is government-controlled and T-Bank is commercial ^[9], so even the banks preparing launches are a mixed group.

Sanctions cut across that split. Sberbank, VTB and Atomyze have all been subject to Western sanctions ^[16], which makes two of the seven named licensees, about 29%, sanctioned names ^[11]. Cryptopolitan adds that Russia has been accused of using cryptocurrencies to get around restrictions imposed over its invasion of Ukraine ^[10].

In our view the licence matters more than the owner. Custody and trading are legal only through intermediaries the central bank has approved ^[6], so Sberbank and a private exchange answer to the same regulator. The report does not include trading volumes or fee terms, so the split of flow between them is untested.

The central bank's own answers are harder to line up than the headline suggests. Asked whether P2P transactions are possible, it replied "Yes, but only until July 1, 2027" ^[1], which is ten months after the law took effect on September 1 ^[12]. Asked about transfers between individuals using addresses administered by a digital depository, it said "No, transfers of digital currency between individuals are not permitted under Part 5 of Article 31 of Federal Law No. 282-FZ" ^[3]. Transfers by an individual to a non-custodial wallet are already not permitted under the law now in force, the bank said ^[4]. A holder in the transition window is reading three replies with three different scopes.

We think the flow ends up on licensed venues, and there are two ways that could play out differently. The bank noted a list of coin operations that can be done without a licensed intermediary during the transition ^[1], and some of that could outlast the date. And retail users can buy, keep and sell only Bitcoin, Ethereum and Tether's USDT at this stage ^[8], so the venues launching by year-end ^[9] are building for three assets, not a broad token list. If volume on the licensed venues is thin once the July 2027 window closes, the thesis is wrong.