Federal Law No. 115-FZ: AML/CFT Regime for Digital Currency Activity

Article 2 expressly brings digital-currency miners and mining-pool organizers within the statute’s wider preventive framework. Article 7.1 applies a defined set of obligations by cross-reference to duties elsewhere in 115-FZ. The provisions reviewed here therefore do not, by themselves, make every holder, transferor, or self-directed miner of digital currency an Article 7.1 reporting entity.

The law uses the Russian statutory concept of “digital currency.” That category should not be assumed to be interchangeable with digital financial assets issued through regulated information systems or with the digital ruble, which are addressed through separate provisions and related legislation.

For mining activity that falls within Article 7.1, the incorporated requirements include:

• identifying clients, representatives, beneficiaries, and beneficial owners, and keeping relevant information current;
• assessing suspicious-transaction risk, assigning risk levels, and applying measures designed to reduce identified risk;
• maintaining internal controls, recording and retaining information, assessing risks from new services or technical tools, and applying required freezing or blocking measures;
• refusing client onboarding in circumstances specified by the statute and requesting identity, registration, ownership, or other necessary documents; and
• notifying Rosfinmonitoring when there are grounds to suspect that covered transactions or client conduct may involve money laundering or terrorist financing.

Pool organizers have a tailored reporting trigger: they must notify Rosfinmonitoring when there are grounds to believe distributed mined currency may be used by pool participants for money laundering or terrorist financing. Covered persons may not disclose that they transmitted information to the authority.

Government Resolution No. 131, effective February 22, 2025, sets the reporting and information-request procedure. It generally requires suspicious-operation information within three working days and uses Rosfinmonitoring’s electronic personal account as the principal channel. The rules also govern responses to regulator requests and reports concerning freezing measures.

Government Resolution No. 1180, effective August 16, 2025, established updated requirements for internal-control rules developed by Article 7.1 subjects, expressly including covered miners and pool organizers. Rosfinmonitoring’s May 2026 memorandum states that use of its personal account is mandatory for Article 7.1 subjects and summarizes the associated reporting, internal-control, training, and responsible-officer framework.

Article 8 requires Rosfinmonitoring to maintain a list of address identifiers where there are grounds to believe recorded digital-currency operations may be connected with money laundering, terrorist financing, extremist activity, or another criminal offense. The extremist-activity language became effective on June 1, 2025. Article 9.1 places Article 7.1 subjects within Russia’s risk-oriented AML/CFT supervisory framework, including remote monitoring based on information received by the authority.

As of June 23, 2026, 115-FZ and the digital-currency provisions described above are in force. The regime should be read alongside Federal Law No. 259-FZ, the 2024 mining amendments, and implementing government and Rosfinmonitoring measures. Because 115-FZ is repeatedly amended and its crypto provisions are actor- and transaction-specific, this profile describes the statutory architecture rather than case-specific compliance obligations.