Digital Financial Asset (DFA) Operators in Russia: Legal Status and Regulatory Requirements

 

July 13, 2025

BRACE Law Firm ©

The development of digital technologies has led to the emergence of new non-credit financial organizations that use digital financial technologies to create additional opportunities for consumers.

In this article, we analyze their legal status and the requirements imposed on such organizations.

Types of DFA Operators

The DFA Law identifies several types of operators, each performing its own role in the digital financial assets ecosystem:

• Information System Operators in which digital financial assets are issued (the "IS Operator", or the "DFA Information System Operators"), which ensure the operation of platforms where digital financial assets are issued and stored, as well as participant access to these platforms.
• Digital Financial Asset Exchange Operators (the "DFA Exchange Operators"), which facilitate DFA transactions and settlements across different information systems.
• Mining Infrastructure Operators, defined as persons providing mining infrastructure services for digital currency mining and mining pools.

Registry of DFA Information System Operators

In accordance with Federal Law No. 86-FZ dated July 10, 2002, On the Central Bank of the Russian Federation (Bank of Russia), the Bank of Russia is the body that regulates, controls, and supervises the activities of IS Operators and DFA Exchange Operators. Meanwhile, the Federal Tax Service of Russia (FNS Russia) regulates the activities of mining infrastructure operators and maintains a special registry of mining infrastructure operators.

Under Federal Law No. 149-FZ dated July 27, 2006, On Information, Information Technologies, and Information Protection, an Information System (the "IS") is a set of information contained in databases and the information technologies and technical means that ensure its processing.

In turn, an information system operator is a citizen or legal entity that operates an information system, including the processing of information contained in its databases.

However, the DFA Law stipulates that an IS Operator may only be a Russian legal entity, including a credit organization, an entity entitled to carry out depository activities, or an entity entitled to carry out activities as a trade organizer, that is included in the registry of IS Operators. DFA Information System Operators are entitled to carry out their activities from the moment they are included in the registry.

Generally, the legal status of an IS Operator and the requirements imposed on it, as well as on a DFA Exchange Operator, are determined not only by the DFA Law but also by regulations adopted by the Bank of Russia as the primary regulator.

The Bank of Russia maintains the registry of IS Operators in electronic form in accordance with the procedure it has established. [1] As of July 9, 2025, the registry published on the Bank of Russia website contains information on 15 DFA Information System Operators. [2]

The following information is included in the registry of IS Operators:

• The full and abbreviated (if any) name in Russian;
• The primary state registration number (OGRN);
• The taxpayer identification number (INN);
• The address within the location specified in the Unified State Register of Legal Entities;
• The official website address;
• The telephone number and email address.

What are the Requirements for DFA Information System Operators?

An IS Operator must establish an internal control service and a risk management service or appoint a controller and an officer responsible for organizing the risk management system.

Additionally, an IS Operator that records rights to shares in a non-public joint-stock company must hold a professional securities market participant license to carry out registry-keeping activities.

The registry of IS Operators includes information regarding the sole executive body, members of the collegiate executive body (if any), members of the collegiate management body (supervisory or other board) (if any), the chief accountant, the head of the internal control service (controller), and the head of the risk management service or the person responsible for organizing the IS Operator’s risk management system. This information is included upon appointment (election) to the positions and throughout the entire period of exercising functions in these positions, including the temporary performance of duties.

It should be noted that a legal entity cannot act as the sole executive body, and the functions of the sole executive body cannot be transferred to a commercial organization (management company) or an individual entrepreneur (manager).

The specified individuals must meet the following qualification and business reputation requirements:

• For the individual exercising the functions of the sole executive body and members of the collegiate executive body: a higher education degree and at least two years of experience managing a credit organization or a non-credit financial organization, an organization operating in the field of information and communication technologies, or experience in senior positions in Russian government bodies, government bodies of member states of the Eurasian Economic Union, government bodies of Russian constituent entities, or the Bank of Russia;
• For members of the collegiate management body (supervisory or other board): a higher education degree;
• For the chief accountant: a higher education degree and at least one year of experience related to bookkeeping, the preparation of accounting (financial) statements, or auditing activities in a financial organization;
• For the head of the internal control service (controller), the head of the risk management service, or the officer responsible for organizing the risk management system: a higher education degree and at least one year of experience managing a financial organization or a structural unit of a financial organization related to methodology and risk management assessment, internal control, or internal audit; or at least one year of experience in senior positions in Russian government bodies, government bodies of member states of the Eurasian Economic Union, government bodies of Russian constituent entities, or the Bank of Russia; or at least three years of experience in a structural unit of a financial organization related to methodology and risk management assessment, internal control, or internal audit;
• No unspent or outstanding criminal record for committing an intentional crime;
• The expiration of the period during which the individual is considered subject to administrative punishment in the form of disqualification;
• No exercise of functions (regardless of the duration) as the sole executive body, member of the collegiate executive body, member of the collegiate management body (supervisory or other board), or chief accountant of a financial organization during the 12 months preceding the date of the revocation (cancellation) of the financial organization’s license for violating legislation. This restriction does not apply if the individual submitted evidence to the Bank of Russia of non-involvement in the decision-making or the actions (omissions) that led to the revocation (cancellation) of the financial organization’s license;
• No instances of being held administratively liable two or more times within the last three years for unlawful actions during the bankruptcy of a legal entity, or for intentional and (or) fictitious bankruptcy of a legal entity (except where such administrative offense resulted in an administrative punishment in the form of a warning);
• No instances of being held criminally liable for unlawful actions during the bankruptcy of a legal entity, or for intentional and (or) fictitious bankruptcy of a legal entity, if the five-year period from the date the relevant judicial act entered into force has not expired;
• The absence of information in the list of organizations and individuals for whom there is information regarding their involvement in extremist activities or terrorism, or in lists of organizations and individuals associated with terrorist organizations and terrorists or with the proliferation of weapons of mass destruction compiled as part of the implementation of powers provided for by Chapter VII of the UN Charter by the UN Security Council or bodies specially created by decisions of the UN Security Council;
• The absence of information regarding a decision by the interdepartmental coordinating body exercising functions to combat the financing of terrorism and extremist activity to freeze (block) the individual’s funds or other property.

If facts of non-compliance with qualification and (or) business reputation requirements are identified, the Bank of Russia is entitled to demand that the IS Operator replace such individuals by sending an order within five business days from the date the facts of non-compliance were identified. [3]

DFA Information System Operators are obliged to ensure:

• The possibility of restoring a digital financial asset holder's access to the IS records upon their request if such access was lost;
• The uninterrupted and continuous functioning of the IS, including the availability and proper functioning of duplicating (backup) technological and operational means that ensure the uninterrupted and continuous functioning of the IS;
• The integrity and reliability of the DFA information contained in the IS records;
• The correct implementation of the established algorithms for creating, storing, and updating information contained in the distributed ledger, and algorithms ensuring the identity of said information in all databases constituting the distributed ledger, as well as the impossibility of other persons making changes to them;
• The impossibility for a user to make and (or) change a record of digital financial assets in order to prevent the user from violating the prohibition on accepting digital financial assets as a means of payment or other counter-performance, as well as the violation of the prohibition on performing certain types of foreign exchange transactions with DFAs;
• The impossibility of acquisition of digital financial assets — the issuance decision for which indicates that they may be acquired only by individual entrepreneurs and legal entities specified in such decision and (or) meeting the criteria established in such decision — by other persons, except for the acquisition of specified digital financial assets through universal succession.

An IS Operator is obliged to ensure the entry (change) of DFA records based on a legally effective judicial act, an enforcement document (including an order from a bailiff), acts of other bodies and officials, or an issued certificate of the right to inheritance providing for the transfer of digital financial assets of a certain type through universal succession, no later than the business day following the day the relevant request was received. An IS Operator is obliged to inform the DFA exchange operator of the entry (change) of records no later than the business day following the day the records were entered (changed).

An IS Operator is obliged to provide DFA information and DFA issuance decisions contained in the IS records:

• At the request of a court;
• At the request of the federal executive body taking measures to combat the legalization (laundering) of proceeds from crime, the financing of terrorism, extremist activity, and the financing of the proliferation of weapons of mass destruction; the Bank of Russia; enforcement bodies; tax authorities; other bodies and officials; and based on a judicial decision in cases where such information is necessary for them to exercise their functions;
• With the consent of the head of the investigative body — at the request of preliminary investigation bodies for cases pending before them;
• Based on a judicial decision — to officials of bodies authorized to carry out operational-search activities, when they perform functions to identify, prevent, and suppress crimes, based on their requests where there is information regarding signs of crimes being prepared, committed, or having been committed, as well as regarding persons preparing, committing, or having committed them, if there is insufficient data to resolve the issue of initiating a criminal case;
• Based on requests sent by authorized persons in accordance with anti-corruption legislation;
• At the request of a bankruptcy trustee during bankruptcy proceedings against a DFA holder;
• At the request of the registrar (depository) where a DFA personal account (depository account) is opened.

DFA Information System Operators are obliged to ensure the storage of information regarding DFA transactions issued in their IS, as well as regarding the participants in such transactions, for at least five years from the date the relevant transactions were performed.

An IS Operator is obliged to ensure the actual possibility of exercising rights under equity securities, the right to demand the transfer of equity securities, and rights under shares in a non-public joint-stock company, including rights to participate in the general meeting of shareholders, rights to receive payments, and other rights, in accordance with the procedure and conditions provided for by the relevant DFA issuance decision.

An IS Operator is entitled to recognize persons as qualified investors upon their application. In this case, the consequence of acquiring digital financial assets that persons who are not qualified investors are prohibited from acquiring (including in the case of the improper recognition of said person as a qualified investor) is the imposition on the IS Operator of the obligation to acquire these DFAs at the request of the person who acquired them at its own expense and to reimburse all expenses incurred by the person in doing so.

When acquiring DFAs in excess of the established limit of 600,000 rubles, this applies only to digital financial assets acquired in excess of said limit. If a person is recognized as a qualified investor based on false information they provided, this consequence does not apply.

The considered consequences do not apply in the case of the acquisition of digital financial assets by foreign individuals and legal entities. A claim for the application of consequences may be filed by the person who acquired the DFAs. It should be noted that these consequences also apply to the DFA Exchange operator.

DFA Information System Rules and the Procedure for Their Approval

An IS Operator is obliged to approve information system rules, which must contain:

• Rules for making changes to the algorithm (algorithms) of the information system software;
• Requirements for information system users;
• Rules for the issuance of digital financial assets;
• Rules for engaging digital financial asset exchange operators, including requirements for said operators;
• Requirements for information protection and operational reliability;
• Methods for recording DFAs in the IS, as well as entering (changing) DFA records in the IS;
• Rules for providing access to the IS for DFA holders (including rules for using the hardware and software means that provide such access, if they are used in the IS);
• The procedure for maintaining the registry of IS users, including rules for engaging IS nodes (for distributed ledger-based IS) and (or) operators of other IS to maintain the user registry (subject to their engagement);
• Rules for maintaining the registry of securities owners in the IS, including the timeframes for performing operations in the registry of securities owners, if the IS Operator records rights to shares in a non-public joint-stock company issued in the form of DFAs;
• An indication that the DFA Information System Operator performs settlements for transactions made using an electronic platform by transferring funds belonging to beneficiaries between them within one nominal account without changing the balance of funds on the nominal account (if such services are provided);
• Rules for using a nominal account in the case of settlements for transactions made using electronic platforms;
• An indication of the possibility of recording and circulating DFAs in an IS organized in accordance with foreign law, and the specifics of performing operations with the relevant DFAs in the IS in which they were issued (provided that the IS Operator adopts the relevant decision).

After approving the DFA information system rules, the operator is obliged to submit said rules for approval to the Bank of Russia along with the following documents:

• An application for inclusion in the registry of IS Operators;
• Copies of documents regarding the election (appointment) of the sole executive body, members of the collegiate executive body (if any), members of the collegiate management body (supervisory or other board) (if any), the chief accountant, the head of the internal control service (controller), and the head of the risk management service or the person responsible for organizing the risk management system;
• Documents containing information regarding persons entitled to directly or indirectly, independently or jointly with other persons, dispose of 10% or more of the votes constituting the statutory capital;
• Documents confirming the compliance of said persons with qualification and business reputation requirements;
• Documents confirming the establishment of the internal control service and the risk management service or the appointment of a controller and an officer responsible for organizing the risk management system.

Within a period not exceeding 60 business days from the date the IS rules and documents are received, the Bank of Russia adopts a decision to approve said rules or a decision to refuse their approval.

The Bank of Russia adopts a decision to refuse to approve the rules in the following cases:

• Non-compliance of the IS rules with the requirements of federal laws and regulations of the Bank of Russia adopted in accordance with them;
• Non-compliance of the IS Operator’s employees with qualification and business reputation requirements;
• The absence of an internal control service and a risk management service or a controller and an officer responsible for organizing the risk management system, as well as a professional securities market participant license to carry out registry-keeping activities if the DFA Information System Operators record rights to shares in a non-public joint-stock company;
• The presence of incomplete and (or) unreliable information in the documents submitted to the Bank of Russia.

The Bank of Russia notifies in writing of the adopted decision to refuse to approve the IS rules, indicating the grounds for the refusal, no later than five business days from the date the decision to refuse approval was adopted.

In the case of making changes to the DFA information system rules, the operator is obliged to submit said changes to the rules for approval to the Bank of Russia in the form of a new edition of the rules. Within a period not exceeding 30 business days from the date the changes are received, the Bank of Russia adopts a decision to approve said changes or to refuse their approval. Changes made to the rules of an information system in which digital financial assets are issued enter into force no earlier than the date of their approval by the Bank of Russia.

In Which Cases are DFA Information System Operators Removed from the Registry?

In the event of repeated violations within one year by an IS Operator of the requirements of the DFA Law, Federal Law No. 115-FZ dated August 7, 2001, On Combating the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism, or requirements of Bank of Russia regulations, the Bank of Russia is entitled to remove such operator from the registry of IS Operators.

From the date the operator is removed from the registry, the entry (change) of digital financial asset records in the relevant IS is prohibited. A removed DFA Information System Operator is obliged, no later than 30 business days from the date of its removal from the registry, to ensure the transfer of the consolidated information stored in the IS regarding persons who issued DFAs, as well as their holders, to an operator of another information system in accordance with the procedure established by a Bank of Russia regulation.[4] Said consolidated information must be generated as of the date the information system operator was removed from the registry of information system operators.

An IS Operator is entitled to apply to the Bank of Russia with a petition for its removal from the registry, provided that the persons who issued DFAs have fully performed their obligations to all DFA holders. The Bank of Russia removes an IS Operator from the registry no later than 14 business days from the date it submits the petition and documents confirming the fact of the full performance of its obligations.

In the event that the Bank of Russia identifies a violation by an IS Operator of the requirements of the DFA Law, Bank of Russia regulations, IS rules, or the rights and legitimate interests of IS users, or if there is a threat to the rights and legitimate interests of IS users, the Bank of Russia, in accordance with the procedure it has established, is entitled to:

• Oblige the IS Operator to partially or completely terminate the circulation of DFAs by prohibiting the entry and (or) change of DFA records in the IS;
• Oblige the IS Operator to completely or partially restrict the performance of activities to ensure the conclusion of digital financial asset transactions;
• Demand that the IS Operator replace the individual exercising the functions of the sole executive body.

What is the Liability of a DFA IS Operator?

A DFA Information System Operator is obliged, in accordance with civil legislation, to compensate users of this information system for losses arising as a result of:

• The loss of information stored in the IS regarding the volume of DFAs belonging to their holders and (or) regarding the DFA holders themselves;
• A failure in the operation of the information technologies and technical means of the IS;
• Providing IS users with unreliable, incomplete, and (or) misleading information regarding the IS, its rules of operation, and the IS Operator;
• Violation of the IS operating rules, including violation of the requirements for its uninterrupted and continuous functioning;
• Non-compliance of the IS with the requirements of the DFA Law.

In the event of a failure in the operation of the IS information technologies and technical means, the operator is also obliged to perform the user's actions that were prevented by such failure.

Registry of DFA Information System Users

An IS Operator maintains the registry of IS users. The operator is entitled to engage individuals performing the functions of information system nodes, as well as operators of other information systems, to maintain such a registry.

IS nodes are defined as users of a distributed ledger-based information system who ensure the identity of the information contained in said information system using procedures to confirm the validity of the records entered (changed) therein.

The following information is entered into the registry for each user:

• Information regarding the information system user;
• Information necessary for the authentication of the user in the information system;
• A record of the capacity in which the user is authenticated in the information system (as a person issuing DFAs, a DFA holder, a DFA exchange operator, a nominal holder of digital financial assets, or a foreign nominal holder of DFAs).

The specified information is entered into the registry based on documents necessary to confirm this information: [5]

• An identification document of the user (for individuals);
• An identification document of the user's representative;
• A document confirming the user's registration with the tax authority, or in its absence, a document confirming the impossibility of obtaining said document;
• An extract from the Unified State Register of Legal Entities (for a user who is an individual entrepreneur);
• A document confirming the user's acquisition of legal entity status (for a user that is a foreign legal entity).

Documents must be submitted to the operator in hard copy or in electronic form in the manner provided for in the rules of the relevant information system. In the absence of an indication of the submission method, documents shall be submitted in a manner that allows the fact and date of receipt of the documents by the operator to be confirmed.

At the user's discretion, documents may be submitted to the operator in the form of copies certified by the user's representative and containing the words "certified copy", the date of certification, the signature, and the printed name of the person who certified the copy. If documents are submitted to the operator as electronic copies, the documents must be signed with the authorized person’s electronic signature.

Documents prepared in a foreign language must be submitted to the operator with a Russian translation attached.

A DFA Information System Operator is obliged to store the specified documents and information throughout the entire period the user remains in the registry of information system users, as well as for five years after their removal from the registry of information system users.

When storing documents (copies of documents) and information entered into the registry, the operator must:

• Ensure their protection against destruction, spoilage (including mechanical damage), theft or loss, unauthorized access, as well as the effects of malicious computer programs and unauthorized changes to their content (when stored on electronic media), including those caused by the unlawful actions of third parties and the operator itself (its employees);
• Take measures aimed at the timely detection of instances of destruction, spoilage (including mechanical damage), theft or loss of documents (copies of documents) and information entered into the registry, unauthorized access to them, as well as the effects of malicious computer programs and unauthorized changes to their content (when stored on electronic media), including those caused by the unlawful actions of third parties and the operator itself (its employees).

DFA Exchange Operator

Another subject of DFA circulation is the DFA exchange operator, which facilitates the conclusion of transactions with such assets (purchase and sale, exchange, etc.). By law, the status of a DFA exchange operator is assigned to a legal entity included in the relevant registry of the Bank of Russia. As of July 4, 2025, the registry contains information on 2 exchange operators.[6]

The primary document defining the procedure for interaction between a DFA exchange operator and its clients and the information system operator is the DFA Exchange Rules, which are approved by the Bank of Russia.

DFA purchase and sale transactions and other transactions related to them (including the exchange of one type for another) are performed through a DFA exchange operator, which ensures the conclusion of DFA transactions by collecting and matching opposing orders for such transactions or by participating in the transaction as a party in the interests of third parties at its own expense.

DFA exchange operators may be credit organizations, trade organizers, or other legal entities that meet the requirements of the DFA Law and Bank of Russia regulations and are included by the Bank of Russia in the registry of DFA exchange operators based on their petition. From the moment of inclusion in this registry, an exchange operator is entitled to carry out its activities. A DFA exchange operator may combine its activities with those of an IS Operator.

The Bank of Russia includes legal entities that are not credit organizations or trade organizers in the registry of DFA exchange operators if they meet the established requirements (Article 10 of the DFA Law).

Regarding commercial organizations, these requirements are:

• It must be a Russian legal entity;
• The size of the statutory capital on the date the petition is submitted is at least 50 million rubles;
• The size of net assets for a business company, calculated in accordance with the requirements of the Bank of Russia, [7] is at least 50 million rubles. For the purpose of including a business company in the registry of exchange operators, the size of the company's net assets must be calculated as the difference between the value of assets and the amount of the company's liabilities as of a date no earlier than five business days before the date the petition for inclusion in the registry of exchange operators is submitted to the Bank of Russia;
• The participants (including members and shareholders) of such a legal entity cannot be legal entities registered in states or territories providing a preferential tax regime and (or) not providing for the disclosure and provision of information when performing financial transactions (offshore zones). Until January 1, 2026, a list of 39 offshore zones [8] approved by the Bank of Russia [9] is in effect;
• A collegiate management body (supervisory or other board) has been established in the legal entity, and an internal control service and a risk management service have been established, or a controller and an officer responsible for organizing the risk management system have been appointed;
• The sole executive body, members of the collegiate executive body, members of the collegiate management body (supervisory or other board), the chief accountant, the head of the internal control service (controller), and the head of the risk management service (officer responsible for organizing the risk management system) of such a legal entity must meet the previously discussed qualification and business reputation requirements.

Similar requirements are established for non-profit organizations, except for requirements regarding statutory capital and the size of net assets; however, the DFA Law provides that the total annual amount of property contributions by the founders (participants, members) to the property of the legal entity must be at least 50 million rubles.

A DFA exchange operator is obliged to ensure the storage of information regarding DFA transactions performed through it, as well as regarding the participants in such transactions, for at least five years from the date the relevant transactions were performed.

A DFA exchange operator is obliged to refuse to ensure the conclusion of DFA transactions performed in violation of the prohibition on accepting DFAs as a means of payment or other counter-performance for transferred goods, performed work, or rendered services, or any other method that allows for the assumption of DFA payment.

The Bank of Russia is entitled to establish additional requirements for the activities of DFA exchange operators and additional requirements for the information system used to perform DFA transactions through a digital financial asset exchange operator. [10] For instance, the permissible downtime and (or) degradation of technological processes that ensure the possibility of performing digital financial asset transactions and interaction with the information system operator must not exceed 12 hours.

A digital financial asset exchange operator is entitled to recognize persons as qualified investors upon their application, with consequences similar to those for an IS Operator.

In the event that the Bank of Russia identifies a violation by a DFA exchange operator of the requirements of the DFA Law, Bank of Russia regulations, DFA exchange operator rules, or the rights and legitimate interests of IS users, or if there is a threat to the rights and legitimate interests of IS users, the Bank of Russia is entitled to:

• Completely or partially restrict the performance of activities by the digital financial asset exchange operator to ensure the conclusion of digital financial asset transactions;
• Demand that the digital financial asset exchange operator replace the individual exercising the functions of the sole executive body.

Mining Infrastructure Operators

Individual entrepreneurs and Russian legal entities are entitled to carry out digital currency mining (including participating in a mining pool) from the moment they are included in the registry of persons carrying out digital currency mining. Digital currency mining and a mining pool — that is, the combination of the capacities of several technical and hardware-software means belonging to different owners and used for the purposes of digital currency mining — are carried out using mining infrastructure, defined as objects used to house technical and hardware-software means.

Individual entrepreneurs and Russian legal entities are entitled to carry out the activities of a mining infrastructure operator. They become such from the moment they are entered into the relevant registry.

Mining infrastructure operators are obliged to ensure the uninterrupted and reliable functioning of the mining infrastructure, the protection of the information they process, and the stability of the power supply systems when carrying out their activities.

Mining infrastructure operators must establish an internal control service and a risk management service or appoint a controller and an officer responsible for organizing the risk management system. Generally, the qualification and business reputation requirements for employees of a mining infrastructure operator, if it is a legal entity, are similar to the requirements for IS and DFA exchange operators. If the mining infrastructure operator is an individual entrepreneur, then in carrying out activities, they must meet the qualification requirement regarding a higher education degree, while the business reputation requirements are identical to those already discussed. [11]

The registry must contain the following information regarding the mining infrastructure operator:

• For legal entities: OGRN, INN, full and abbreviated (if any) names, domain name, and website page pointer; for individual entrepreneurs: OGRNIP, INN, last name, first name, and patronymic (if any), domain name, and website page pointer;
• The address (addresses) of the location of the mining infrastructure objects, specifying the persons carrying out digital currency mining, as well as information regarding such persons;
• The name of the territorial grid organization to whose networks the mining infrastructure operator is connected;
• The electricity supply points used in relation to the technical and hardware-software means used for digital currency mining;
• The maximum capacity of the technical and hardware-software means used for mining;
• Information regarding the mining infrastructure operator’s ownership or other legal basis for an electricity production facility;
• The maximum capacity provided by the mining infrastructure operator to each person carrying out digital currency mining for the consumption of electricity by the technical and hardware-software means used for digital currency mining.

Information regarding a mining infrastructure operator entered into the registry is not subject to publication in the mass media or placement on the internet. The information contained in the registry is provided to government bodies, other state bodies, courts, the Bank of Russia, territorial grid organizations, and the system operator of the Russian electricity systems using the unified system of interdepartmental electronic interaction. [12]

The registry of persons carrying out digital currency mining and mining infrastructure operators will be considered by us in more detail in one of the following articles.

In this article, we have provided a brief overview of the subjects that the DFA Law has endowed with the status of DFA operators, and we have considered in more detail the legal status of DFA operators and the requirements for them. The primary function of an IS Operator is management, within which the issuance, recording, and circulation of DFAs are carried out. A DFA exchange operator organizes DFA purchase and sale transactions and other transactions related to DFAs. They may carry out their activities from the moment they are entered into the relevant registry. Currently, 15 organizations are registered as IS Operators, and 2 organizations are registered as DFA Exchange Operators.

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References

[1] Bank of Russia Regulation No. 746-P dated December 16, 2020, On the Maintenance by the Bank of Russia of the Registry of Information System Operators in which Digital Financial Assets are Issued, the Registry of Digital Financial Asset Exchange Operators, on the Procedure and Timeframes for the Submission by Information System Operators in which Digital Financial Assets are Issued and Digital Financial Asset Exchange Operators to the Bank of Russia of Information on Persons Disposing of Shares (Interests) of Said Operators, as well as on the Procedure for the Submission and Approval by the Bank of Russia of Changes to the Rules of an Information System in which Digital Financial Assets are Issued and Changes to Digital Financial Asset Exchange Rules.

[2] Bank of Russia website: https://cbr.ru/admissionfinmarket/navigator/ois/.

[3] Bank of Russia Regulation No. 745-P dated December 9, 2020, On the Procedure for the Issuance of Orders by the Bank of Russia in Connection with Non-compliance with Qualification Requirements (Requirements for Qualification) and (or) Business Reputation Requirements, Violation of the Procedure for Acquiring Shares (Interests), Establishing Control over Shareholders (Participants) of Financial Organizations, Identification of an Unsatisfactory Financial Position, on the List of Persons to Whom Copies of Orders are Sent, the Procedure for Bringing to the Attention of Shareholders (Participants) of Financial Organizations Information on the Receipt of Copies of the Order and the Act Rescinding the Order, the Procedure for Determining the Number of Voting Shares (Interests) of Credit Organizations in Connection with the Issuance of Orders, the Procedure for Sending Notification of the Execution of the Order, the Act Rescinding the Order, as well as on the Procedure for Placing Information on the Issued Order (the Rescission of the Order) on the Official Website of the Bank of Russia on the Information and Internet.

[4] Bank of Russia Ordinance No. 5664-U dated December 16, 2020, On the Procedure for the Removal by the Bank of Russia of an Information System Operator in which Digital Financial Assets are Issued from the Registry of Information System Operators in which Digital Financial Assets are Issued.

[5] Bank of Russia Ordinance No. 5625-U dated November 19, 2020, On the Documents Provided for by Part 4 of Article 8 of Federal Law No. 259-FZ dated July 31, 2020, On Digital Financial Assets, Digital Currency and On Amending Certain Legislative Acts of the Russian Federation, and Requirements for Their Storage.

[6] Bank of Russia website: https://cbr.ru/admissionfinmarket/navigator/ootsfa/.

[7] Bank of Russia Ordinance No. 5647-U dated December 3, 2020, On the Requirements for the Calculation of the Size of Net Assets of a Business Company for the Purpose of Its Inclusion by the Bank of Russia in the Registry of Digital Financial Asset Exchange Operators.

[8] Anguilla, Principality of Andorra, Antigua and Barbuda, Aruba, Commonwealth of the Bahamas, Kingdom of Bahrain, Belize, Bermuda, Brunei Darussalam, Republic of Vanuatu, British Virgin Islands, Gibraltar, Grenada, Commonwealth of Dominica, Macao Special Administrative Region (Aomen) of the People's Republic of China, Anjouan Island of the Union of the Comoros, Republic of Liberia, Principality of Liechtenstein, Republic of Mauritius, Labuan Island of Malaysia, Republic of Maldives, Republic of the Marshall Islands, Principality of Monaco, Montserrat, Republic of Nauru, Curacao and Sint Maarten (the Dutch part), Niue, Cayman Islands, Cook Islands, Turks and Caicos Islands, Republic of Palau, Republic of Panama, Independent State of Samoa, Republic of San Marino, Saint Vincent and the Grenadines, Saint Kitts and Nevis, Saint Lucia, Certain administrative units of the United Kingdom of Great Britain and Northern Ireland (Isle of Man, Channel Islands (islands of Guernsey, Jersey, Sark, Alderney)), Republic of Seychelles.

[9] Decision of the Board of Directors of the Bank of Russia dated December 24, 2024, On the Requirements for the Activities of Credit Organizations, Non-credit Financial Organizations (Persons Entitled to Directly or Indirectly Dispose of Shares (Interests) Constituting the Statutory Capital of Credit Organizations, Non-credit Financial Organizations).

[10] Bank of Russia Regulation No. 779-P dated November 15, 2021, On the Establishment of Operational Reliability Requirements Mandatory for Non-credit Financial Organizations when Carrying Out Types of Activities Provided for by the First Part of Article 76.1 of Federal Law No. 86-FZ dated July 10, 2002, On the Central Bank of the Russian Federation (Bank of Russia), for the Purpose of Ensuring the Continuity of Financial Services Provision (Except for Banking Services).

[11] Decree of the Government of the Russian Federation No. 1463 dated October 31, 2024, On the Approval of Requirements for the Activities of a Mining Infrastructure Operator.

[12] Decree of the Government of the Russian Federation No. 1464 dated October 31, 2024, On the Approval of the Rules for Maintaining the Registry of Persons Carrying Out Digital Currency Mining and the Rules for Maintaining the Registry of Mining Infrastructure Operators.