Bank of Russia Digital Financial Asset Exchange Operator Register Regime

This regime is not a general cryptocurrency-exchange licence. Under Federal Law No. 259-FZ, DFAs are digital rights that may embody monetary claims, rights connected with issuance securities, participation rights in a non-public joint-stock company, or rights to demand delivery of issuance securities. The statute defines digital currency separately. A registered DFA exchange operator facilitates covered transactions by matching opposing orders or by entering a transaction for its own account in the interests of third parties.

The statutory perimeter includes purchases, sales, exchanges between types of DFAs, and certain transactions involving hybrid digital rights. It also contains important boundaries. Transactions using DFAs as consideration under foreign-trade contracts are excluded from the general exchange-operator channel in Article 10. Separately, an operator of a DFA issuance information system may arrange transactions in DFAs issued in its own system without separate exchange-register entry when its approved system rules incorporate the required exchange-rule provisions.

Credit institutions, trade organizers, and other qualifying legal entities may seek entry. Other commercial legal entities are subject to statutory thresholds that include at least RUB 50 million in charter capital and at least RUB 50 million in net assets. The law also addresses Russian legal status, ownership restrictions, governance, internal control, risk management, management qualifications, and business reputation.

An applicant must approve proposed DFA exchange rules and submit them to the Bank of Russia with its register application and supporting documents. The rules must address transaction procedures, eligible asset types, interaction with DFA information-system operators, information protection, operational reliability, specified automated-performance scenarios, and nominal-account arrangements where the operator provides settlement services.

The Bank of Russia states that review may take up to 45 working days for a credit institution or trade organizer and up to 90 working days for another legal entity. It may request corrected or missing materials. After approving the exchange rules, the regulator enters the operator in the register within three working days and publishes the updated register and approved rules. Amendments to approved exchange rules must also be submitted for approval and cannot take effect before approval.

Registered operators are subject to Bank of Russia supervision. Federal Law No. 259-FZ requires an operator to retain information on DFA transactions and participants for at least five years and authorizes the regulator to impose additional operational-reliability, market-organization, and reporting requirements. The framework also intersects with Russia’s anti-money-laundering and counter-terrorist-financing rules.

The Bank of Russia may exclude an operator following specified repeated violations, and exclusion is mandatory in certain licence-loss or register-removal circumstances for firms combining regulated activities. Covered transactions may no longer be conducted through an excluded operator. An operator may also request voluntary removal, subject to the statutory process.

The register is operational rather than merely enabling. On August 3, 2023, the Bank of Russia announced that Moscow Exchange had become the first organization entered in the DFA exchange-operator register. As of June 23, 2026, the regulator continued to publish the register through its financial-market admission pages. The regime therefore functions as a public gatekeeping and supervisory mechanism for a defined segment of Russia’s tokenized financial-rights market, while its statutory exceptions mean that separate exchange-register entry is not the only lawful route for every transaction involving a Russian-law DFA.