Major Russian banks have begun asking corporate clients to explain transactions with USDT and other cryptocurrencies — including companies outside the experimental legal regime (EPR). About the increased checks, RBC was told by two sources in the banking market, a source in the crypto exchange segment, and Sovcombank.
In addition to standard checks under 115-ФЗ, banks have begun requiring clients to explain the economic purpose of buying USDT and to confirm that the counterparty is included in the Bank of Russia’s register of digital currency exchange operators and complies with AML/FT requirements. Such a register does not yet exist.
De-risking, not a directive
Crypto expert Viktor Pershikov told ForkLog that banks are not acting on a direct instruction from the regulator but out of self-insurance.
“Before the digital currency law was signed, there was a regulatory ‘sandbox’ called the EPR, where banks and participants in foreign economic activity learned to work together at the crypto/fiat interface. Now cryptocurrency is becoming a regulated financial instrument, which increases the number of requests and the concerns of bank compliance about its nature, origin, and the source of funds,” he explained.
Some Telegram channels suggested banks may have acted on a Bank of Russia letter. Pershikov disagrees. In his view, the initiative is more likely coming from Rosfinmonitoring — the agency responsible for enforcement — rather than the Central Bank, which issues regulations. Pershikov sees no legal risks for banks demanding what does not yet exist: all their actions fall under 115-ФЗ.
“They have every right to ask even about the source of the cryptocurrency, or who Satoshi Nakamoto really is,” the expert added.
Registry expected this fall and will be confidential
The Bank of Russia plans to create the register of digital currency exchange operators this fall. According to Pershikov, its key feature will be maximum secrecy: it is obvious that EPR participants use cryptocurrency to bypass restrictions imposed by unfriendly countries.
At the same time, the Central Bank will set detailed requirements for the register, limits, and the rules for exchange services by separate by-laws. This explains why banks are now operating amid uncertainty — the regulatory framework has been adopted, but its content has yet to be filled in.
What companies can provide right now
In addition to basic AML/FT documentation and a risk assessment, corporate clients of banks participating in the EPR will have to disclose the nature and chain of how the cryptocurrency appeared: where it is purchased and the source of funds. They will also need to ensure transparency in relationships with their own clients who use digital assets to solve their tasks.
“Obviously, EPR companies’ compliance staff will have more paperwork,” Pershikov said.
Working with USDT outside the EPR: not just a gray area
Companies providing crypto services within foreign economic activity without being included in the register and without an exchange license under the new laws risk facing criminal consequences — not just a ban. In parallel, bill No. 1193493-8 introduces criminal and administrative liability for the illegal circulation of cryptocurrencies — with confiscation of illegally exchanged assets.
An exception is provided for those who use cryptocurrency in accordance with the terms of foreign trade contracts or to fulfill obligations under them. A separate threshold is set for small players: if monthly turnover is below 3.5 million rubles, inclusion in the register is not required. But they still have to buy cryptocurrency somewhere — which automatically raises questions about the source of funds.
The law as an answer
A separate issue arises for companies that use USDT not by choice but because the SWIFT channel is closed due to sanctions. They now have to explain to the bank the economic purpose of the transaction, and an honest answer documents the sanctions context — even within a legal scheme. In Pershikov’s view, the adopted law resolves this collision: starting September 1, cryptocurrency settlements for foreign economic activity become a full-fledged legal instrument rather than an exception from the “sandbox.” Banks will be required to service such transactions if the documents are in order.
“Banks will have to, if all the client’s documents are in order, service such transactions, since the federal law has been signed and will soon take effect,” the expert noted.
The law “On digital currency and digital rights” takes effect on September 1. The transition period will run until July 1, 2027.
