The Bank of Russia has clarified that this new framework restricts more than just direct exchanges; it explicitly forbids individuals from transferring assets from regulated digital accounts to personal noncustodial wallets. While the law does not criminalize the mere possession of a hardware or software wallet, it mandates that all movement of funds must occur within the oversight of registered digital depositories. These institutions, which now include major financial players like Sberbank and VTB Bank, are tasked with maintaining rigorous records of customer holdings and transaction addresses.
For retail participants, the transition shifts the market toward a strictly supervised environment. Nonqualified investors face annual purchase limits of 300,000 rubles for eligible assets like Bitcoin, Ether, and USDT, contingent on passing mandatory knowledge tests. Although the central bank has begun issuing licenses to exchange operators, industry experts remain skeptical regarding enforcement. Critics point out that decentralized peer-to-peer networks and hardware-based self-custody solutions are inherently resistant to centralized oversight, raising questions about how authorities intend to curb activity that bypasses the formal banking infrastructure.

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