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[Bank of Russia Prohibits Withdrawals from Regulated Crypto Accounts to Self-Custody Wallets]

The Bank of Russia, in October 12 updated guidance, clarified that individuals may not withdraw cryptocurrency from regulated digital accounts to self-custody wallets they control. The central bank stated that this restriction is based on Russia's new cryptocurrency market law (Federal Law No. 282-FZ) Article 31(9), which took effect on September 1, 2026. A digital account is a statutory account used to record crypto assets, while a digital custodian is a registered entity that records and transfers such assets and provides access to wallet addresses. The restriction applies to withdrawals under Russia's regulated custody framework. For withdrawals from ordinary investment accounts, the rules cover resident individuals and provide no exemption for qualified investors. Under Article 31, individuals who pass the required test and receive risk disclosures may transfer cryptocurrency to wallets managed by legally authorized foreign custodians, which differs from withdrawing to personal wallets outside institutional custody. The law also separately provides exceptions for foreign trade settlements and mining. The central bank also stated that transfers between individuals using addresses managed by digital custodians are not permitted, including transfers arising from transactions between individuals. These provisions form part of the general cryptocurrency market law rather than rules applicable only to participants in experimental programs. The central bank stated that direct peer-to-peer transactions between individuals are permitted only until July 1, 2027, when Article 30(1) takes effect; thereafter, residents not authorized as cryptocurrency market intermediaries must conduct transactions through or with the involvement of authorized intermediaries. Available channels include licensed brokers and cryptocurrency exchange operators listed on the Bank of Russia's register.