25 June 2025

Digital Financial Assets (DFA) in Russia: Concept, Types, and Legal Regulation

June 25, 2025

BRACE Law Firm ©

The digitalization of the financial market over the last few years has significantly changed the financial system. The active implementation of digital technologies has substantially improved process efficiency and the availability of financial services for organizations and individuals.

With the development of distributed ledger technology and the emergence of digital financial assets (the "DFA"), a need for legal regulation has arisen to legalize new technologies and prevent fraud.

In this article, we examine the concept and types of DFA, examples of global legal regulation, and the requirements of Russian legislation.

What Is a DFA in Simple Terms?

A DFA is a new category of investment instruments that emerged due to the development of information and blockchain technologies. These assets represent digital records of ownership rights to property or the obligations of parties to a transaction, stored in distributed ledgers (blockchains). They allow for significantly simplified property rights transfers, lower transaction costs, and increased operational transparency.

In accordance with Article 1 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 (the "Law No. 259-FZ", "Law on DFA", or "Law on Digital Financial Assets"), the Law recognizes DFAs as digital rights provided for by the decision on their issuance, the issuance, record-keeping, and circulation of which are possible only by making (changing) entries in an information system based on a distributed ledger, as well as in other information systems.

DFAs include:

monetary claims;
the possibility to exercise rights under equity securities;
participation rights in the capital of a non-public joint-stock company;
the right to demand the transfer of equity securities.

Thus, a DFA refers to electronic data (a digital code or designation) that satisfies the following criteria:

it is stored in an information system based on distributed ledger technology (blockchain);
it performs the functions of transferring a property right or a monetary obligation arising between the parties;
it confirms the creation and transfer of rights to own the asset.

In other words, a DFA is an electronic record confirming the existence of specific rights and obligations between the participants of the relevant legal relationship.

The following main characteristics of a DFA can be distinguished:

Decentralization, meaning the absence of a single central management center for the system. This implies that no single network participant has full control over the transaction registration process or changes to the asset issuance terms. All operations are recorded automatically and publicly, ensuring a high level of security and trust among market participants;
All operations with digital financial assets are recorded in a public ledger accessible to any system participant. This openness helps avoid fraud and abuse, providing users with confidence in the system's reliability;
High settlement speed. The use of modern technologies significantly accelerates the process of calculating payments and transfers between counterparties. For example, an operation to transfer shares can take only a few seconds, whereas a traditional procedure requires several days to wait for document confirmation.

History of DFA Development

The history of DFA development began approximately at the same time as the first cryptocurrencies appeared. The issuance of Bitcoin in 2009 was the first step toward the birth of DFAs as money surrogates in the digital space, although at the initial stage, government representatives did not pay significant attention to this technology due to its extremely low level of application and capitalization. At the same time, this event represents a shift toward the recognition of digital value analogues that can operate independently of or parallel to traditional financial systems.

Gradually, DFAs began to penetrate traditional financial markets, attracting the attention of investors and regulators. Starting from 2012, when the first DFA exchange platforms appeared, they began to be viewed as assets capable of bringing economic benefits in the future, for example, through price growth. Furthermore, their liquidity significantly increased, which also gives them properties of both money and popular securities, such as corporate bonds. An owner could be confident that they could sell their cryptocurrency funds at the equilibrium price formed in the market at a specific point in time. Today, many large financial institutions actively invest in projects related to the development of new types of digital assets.

Cryptocurrencies do not have a clear legal status and are not backed by any assets or guarantees from third parties. This situation poses threats to both investors and the state, as the unregulated nature of the market facilitates cases of fraud, market manipulation, and other financial offenses.

What Regulates DFAs?

The regulation of digital assets is currently in the formation stage. Each country is developing its own strategy for approaching such instruments, taking into account the characteristics of national legislation and existing risks.

In 2019, amendments were made to the Civil Code of the Russian Federation (the "Civil Code"), and Article 141.1 was added, which introduced a regulatory definition for "digital rights". These are specifically designated as such in the law as obligatory and other rights, the content and conditions for the exercise of which are determined in accordance with the rules of an information system meeting the criteria established by law. The exercise, disposal (including transfer, pledge, or encumbrance of a digital right by other means), or restriction of the disposal of a digital right is possible only in the information system without contacting a third party.

Thus, the primary element for beginning work with digital rights is the information system, for which, at the time the concept emerged, rules and approaches for the distribution, record-keeping, and transfer of digital rights had not been developed.

Russia became one of the first countries to develop a special DFA Law regulating activities with such instruments. According to this law, any activity related to the creation, placement, and circulation of digital assets must be carried out strictly within the established legal framework.

Furthermore, the Central Bank of Russia develops standards for the issuance and circulation of digital assets to ensure the protection of consumer interests and the stability of the country's financial system.

Also, the Bank of Russia, in accordance with Federal Law No. 86-FZ dated July 10, 2002, On the Central Bank of the Russian Federation (the Bank of Russia), is the body that regulates, controls, and supervises the activities of information system operators where digital financial assets are issued and DFA exchange operators.

Russian DFA Law

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 describes the procedure for working with DFAs, their issuance and record-keeping in an information system, as well as the list of requirements for operators authorized to issue DFAs.

From the moment the first information system operator was registered (March 14, 2022), the DFA market in Russia was only emerging, and the number and volume of issuances were insignificant (about 20). The largest number of DFA issuances did not exceed 100,000 rubles, as issuing companies and information system operators were testing the mechanism for organizing DFA issuance. As of the end of November 2022, the total volume of registered issuances was 16 units totaling 227 million rubles; by early 2023, the amount exceeded 2 billion rubles, and by the end of 2023, it was more than 50 billion rubles.

In 2024, according to Bank of Russia data, the volume of active DFAs grew fivefold—from 56 billion rubles a year earlier to 276.2 billion rubles. The number of individual owners increased nearly twofold to 108,100 people by the end of 2024. However, the Bank of Russia's data does not include already redeemed DFAs. Experts expect demand for DFAs to continue growing. According to forecasts, in 2025, the issuance volume will exceed 1 trillion rubles, and under favorable conditions, the figure could be even higher—over 1.5 trillion rubles.

According to Article 2 of the Law on Digital Financial Assets and Digital Currency, the rights certified by a DFA arise for their first holder from the moment an entry is made in the information system in which the DFA issuance is carried out, recording the credit of the DFA to the specified person.

If civil legal relations between the parties arose before the DFA Law entered into force, a court, when making a decision in the event of a dispute, will not be able to rely on the provisions of this law and will be guided by the legislation in force at the time the parties' relations arose.

The following entities have the right to perform actions to make an entry in the information system regarding the credit of digital financial assets to their first holder (i.e., to issue digital financial assets):

individuals registered as individual entrepreneurs;
legal entities (commercial and non-profit organizations).

The Decision on DFA Issuance must contain:

information about the person issuing the DFA (name, addresses, and other data);
information about the operator of the information system in which the DFA issuance is carried out;
the type and volume of rights certified by the issued DFA;
the number of DFAs issued and (or) an indication of the maximum amount of funds to be transferred in payment for the issued DFAs, and (or) the maximum number of other DFAs to be transferred as consideration for the issued DFAs, upon reaching which the asset issuance ceases;
the acquisition price of the DFA upon issuance or the procedure for determining it, as well as the payment method for the issued DFAs (payment in funds and (or) transfer of other digital financial assets as consideration);
the start date for the placement of the issued digital financial assets by concluding agreements for their acquisition;
other requirements provided for by Law No. 259-FZ.

The Decision on DFA Issuance is prepared in electronic form and must be signed with the Enhanced Qualified Electronic Signature (UK(E)P) of the person issuing the assets. The presence of a UK(E)P attached to the Decision on DFA Issuance—whether placed on the Internet or provided for review to information system users directly by the operator—allows a potential investor to verify that the document has legal force and, accordingly, reduce their risks, particularly the risks of data falsification.

The person issuing the DFA must place the decision on asset issuance on their website and on the website of the information system operator where the DFA issuance is carried out. This decision must remain in the public domain until the full performance of obligations by the person who issued the assets to all DFA holders issued on the basis of the corresponding decision.

The rights certified by the DFA arise for their first holder from the moment an entry is made in the information system recording the credit of the DFA to the specified person. Therefore, a right existing before the entry is made in the information system regarding the credit of the DFA to the first holder cannot be a DFA.

DFAs are recorded in the information system where they are issued as entries using methods established by the rules of that system.

Entries regarding assets are made or changed upon the instruction of:

the person issuing the assets;
the asset holder.

The transfer of DFA ownership, restrictions, or encumbrances on the right to dispose of assets arise from the moment an entry to that effect is made in the information system.

A DFA holder is recognized as a person who:

is included in the user registry of the information system where the DFAs are recorded;
has access to the system by possessing a unique code required for such access, which allows them to receive information about the assets they possess and to dispose of these assets by using the information system.

Please note that it is prohibited to accept DFAs as a means of payment or other consideration for transferred goods, performed works, or rendered services, or in any other way that suggests payment for goods (works, services) with DFAs, except for use as consideration under foreign trade contracts (contracts) concluded between residents and non-residents that provide for the transfer of goods, performance of works, rendering of services, or the transfer of information and intellectual activity results, including exclusive rights to them.

The Law on Digital Financial Assets establishes a number of requirements for the information system operator (i.e., the person operating the information system, including the processing of information contained in its databases).

Thus, the operator of the system where the DFA issuance is carried out must be included in the corresponding registry of such operators maintained by the Bank of Russia. As of June 22, 2025, 15 organizations are included in the registry of information system operators where digital financial assets are issued.

The Bank of Russia supervises the activities of the information system operator where DFAs are issued. The Bank of Russia has the right to establish additional requirements for the information system operator, including requirements for the internal control system, operational reliability, and reporting.

The primary document determining the procedure for the information system's operation, the rights and obligations of its operator and users, and the procedure for engaging DFA exchange operators, nominal holders, transaction validators, is the Information System Rules, which (including any changes) are approved by the Bank of Russia.

The information system operator's liability is provided for by Article 9 of the DFA Law. The information system operator must compensate for losses arising from the loss of information contained in the information system regarding the holder of the relevant assets or their volume, information technology and technical equipment failures, or the provision of inaccurate information to users regarding the information system or its operator. The operator is also liable for violating the requirements for the uninterrupted and continuous functioning of the information system.

Another subject of the DFA market is the DFA exchange operator, who ensures the conclusion of transactions with such assets (purchase and sale, exchange, etc.). By law, the status of a DFA exchange operator is granted to a legal entity included in the corresponding registry of the Bank of Russia.

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

Note the possibility of including DFAs in the debtor's bankruptcy estate during bankruptcy. In accordance with Article 128 of the Civil Code, digital rights are classified as property. Since all property is included in the debtor's bankruptcy estate, DFAs must also be included in the debtor's bankruptcy estate.

The main problem is identifying property within bankruptcy procedures in the event of the debtor's bad faith behavior. An insolvency officer, in the absence of information about the debtor's assets, has the right to demand documents directly from the debtor. If the debtor evades the obligation to transfer documents, the insolvency officer has the right to petition the court to compel the debtor to produce the documents.

Law enforcement practice is already forming toward demanding from the debtor information about the existence of digital financial assets, specifying the issuer, the personal account address, the login, and the password.

Examples of DFA Regulation in Other States

Even without special regulation, DFAs fall under the scope of existing laws (contract, commercial, criminal, property, and civil rights laws), as compliance with their norms is necessary for all participants in legal relations in this sphere. Some states practice active observation and regulation of DFAs (e.g., Japan, Germany, Australia, Canada, India), where laws and regulations are introduced for oversight and monitoring, and new technologies are regulated. Others adhere to a wait-and-see position (e.g., France), where warnings about risks are issued and development support is lacking, but there is no direct ban. A third group of states prohibits DFA operations (e.g., Thailand), where they refuse to recognize their legal status but simultaneously formulate regulatory rules.

Legal regulation in the PRC is the most stringent regarding DFAs. The following prohibitions apply in the PRC:

a ban on financial organizations conducting transactions with cryptocurrency;
a ban on the issuance of tokens (ICOs) by their issuers; in this case, persons who have already conducted an ICO are obliged to return the funds to investors. However, owning cryptocurrency and tokens is not prohibited in itself;
the inclusion of national and foreign websites and platforms related to cryptocurrency trading and placement in the registry of prohibited sites and their blocking.

At the same time, China uses the advantages of blockchain technology and smart contracts based on it and provides for the possibility of inheriting cryptocurrency. Judicial practice confirms the legality of owning cryptocurrency (bitcoins). Courts view cryptocurrency and tokens as property.

Also, the digital yuan, which represents currency in digital form, has been issued in the PRC. The digital yuan significantly increased the adoption of digital payments in China. As of January 2022, more than 261 million digital yuan wallets were created, highlighting the rapid integration of this digital currency. Despite this, the usage level remains modest compared to the 903.6 million people using mobile payments in China. To stimulate wider adoption, the central bank entered into partnerships with major trading platforms such as Alipay and WeChat Pay, aiming to make digital yuan transactions as fast as current payment methods.

Currently, citizens of other countries cannot directly buy the digital yuan unless they are in one of China's pilot zones, such as Beijing, Shanghai, or Shenzhen. Access to the digital yuan application is limited, and downloading it from international app stores will not work if your phone's location is not in one of these zones.

In the Republic of Belarus, a special legal regime has been created within the Hi-Tech Park. For instance, Decree of the President of the Republic of Belarus No. 8, On the Development of the Digital Economy, created conditions for the implementation of transaction block registry technology (blockchain) and other technologies based on the principles of distribution, decentralization, and security of operations performed using them. Prior to the adoption of this decree, the circulation of digital signs (tokens) was not regulated by legislation and, accordingly, they were not objects of legal relations. Legal entities received the right to own tokens and perform the following operations:

through a resident of the Hi-Tech Park, create and place their own tokens in the Republic of Belarus and abroad;
store tokens in virtual wallets;
through crypto-platform operators, cryptocurrency exchange operators, or other Hi-Tech Park residents, acquire or alienate tokens and conduct other transactions (operations) with them.

Individuals received the right to own tokens and perform operations such as mining, storing tokens in virtual wallets, exchanging tokens for other tokens, and acquiring or alienating them for Belarusian rubles, foreign currency, or electronic money, as well as gifting and bequeathing tokens.

The activity of individuals in mining, acquiring, and alienating tokens, carried out independently without engaging other individuals under labor and (or) civil law contracts, is not a business activity. Tokens are not subject to declaration.

In the USA, concepts such as "blockchain", "cryptocurrency", "token", and "smart contract" are enshrined in legislation at the individual state level. Thus, in the state of Arizona, a smart contract means an event-driven program that runs on a distributed, decentralized, shared, and replicated ledger and that can take custody of and instructions for the transfer of assets on that ledger. In the state of Vermont, blockchain technology means a mathematically secured, chronological, and decentralized consensus ledger or database maintained via Internet interaction, a peer-to-peer network, or otherwise.

The purpose of legal regulation is to establish the possibility of using blockchain technology as a means of recording and storing information for the purpose of presenting procedural evidence, as well as to recognize the legal force behind the turnover of digital rights and digital currency through a smart contract. Instead of DFA, a concept such as "token" is considered, and instead of digital currency, legislative acts operate with the concept of cryptocurrency. There is also the concept of cryptoassets, denoting the economic value of tokens and cryptocurrency.

It should be noted that in the USA, if cryptocurrencies meet the criteria of a security, the relevant acts regulating activities in the securities market apply, as the goal of US legislators when adopting securities laws was to regulate investments, in whatever form they are carried out and whatever they are called.

The Securities and Exchange Commission (the "Securities and Exchange Commission"), when determining whether a specific DFA is a security, uses the so-called "Howey test", created on the basis of a 1946 US Supreme Court decision related to transactions with Florida citrus groves. By this test, four key criteria are evaluated:

investment of funds;
expectation of profit;
use of a common enterprise;
profit is due to the efforts of third parties.

One high-profile example is the case of the failed primary securities placement of the Telegram messenger, where Pavel Durov was able to raise a record 1.7 billion US dollars from the sale of Gram tokens to qualified investors. In 2019, the Securities and Exchange Commission filed a lawsuit against Telegram, claiming that Gram tokens are securities and that Telegram violated legislation by conducting an unregistered sale of assets. In the complaint, the SEC also referred to the Howey test and claimed that Gram tokens met all four criteria of the test.

Which Types of DFA Exist?

As mentioned above, the DFA Law distinguishes the following types of DFA, which contain:

monetary claims – allow investors to receive payments on terms fixed in the Decision on DFA Issuance. These assets, in turn, may be analogous to traditional financial instruments such as bonds, stocks, or futures, but are issued and circulated in digital form;
the possibility to exercise rights under equity securities – provide the right to demand from the person obligated under such DFAs the exercise, through the information system operator, of the rights under equity securities provided for by the decision on the issuance of equity securities;
participation rights in the capital of a non-public joint-stock company – allow the DFA holder to participate in the management and profits of such a company. They are an analogue of a share in the authorized capital but exist in digital form;
the right to demand the transfer of equity securities – provide their holder with the right to demand the transfer of securities provided for by the Decision on DFA Issuance during the period or upon the occurrence of an event provided for by such decision.

Also, the following main types of digital assets exist: digital currency, utilitarian digital rights, and hybrid digital rights.

It is important to note that Law No. 259-FZ highlights the term "digital currency" and establishes strict frameworks for its use, but not digital currencies like Bitcoin or Ethereum.

Digital currency is recognized as a set of electronic data (a digital code or designation) contained in an information system that are offered and (or) can be accepted as a means of payment that is not the monetary unit of Russia, the monetary unit of a foreign state, and (or) an international monetary or settlement unit, and (or) as an investment, and in relation to which there is no person obligated to each holder of such electronic data, with the exception of the operator and (or) nodes of the information system obligated only to ensure that the procedure for issuing this electronic data and performing actions in relation to it for making (changing) entries in such an information system complies with its rules.

Article 14 of Law No. 259-FZ determines that organizing the issuance of digital currency is the activity of providing services aimed at ensuring the issuance of digital currency using domain names and network addresses located in the Russian national domain zone, and (or) information systems whose technical equipment is located on the territory of the Russian Federation, and (or) software and hardware systems located on the territory of Russia.

The issuance of digital currency refers to actions using objects of the Russian information infrastructure and (or) user equipment located on the territory of Russia aimed at providing opportunities for third parties to use digital currency.

The activity of providing services aimed at ensuring the conclusion of civil law transactions and (or) operations entailing the transfer of digital currency from one holder to another using objects of the Russian information infrastructure is the organization of digital currency circulation.

In Russia, it is prohibited to distribute information about the offer and (or) acceptance of digital currency as consideration for transferred goods, performed works, rendered services, or any other method that suggests payment for goods (works, services) with digital currency.

Article 8 of Federal Law No. 259-FZ dated August 2, 2019, On Attracting Investment Using Investment Platforms and on Amending Certain Legislative Acts of the Russian Federation, defines utilitarian digital rights (the "UDR") as the following digital rights that can be acquired, alienated, and exercised only on an investment platform:

the right to demand the transfer of a thing (things);
the right to demand the transfer of exclusive rights to intellectual activity results and (or) the rights to use intellectual activity results;
the right to demand the performance of works and (or) the rendering of services.

UDRs cannot include the right to demand property if the rights to it are subject to state registration, and (or) the right to demand property if transactions with it are subject to state registration or notarization.

It is prohibited to accept UDRs as a means of payment or other consideration for transferred goods, performed works, rendered services, or any other method that suggests payment for goods (works, services) with UDRs. At the same time, UDRs can be used as consideration under foreign trade contracts (contracts) concluded between residents and non-residents that provide for the transfer of goods, performance of works, rendering of services, or the transfer of information and intellectual activity results, including exclusive rights to them.

Hybrid digital rights (the "GCP") combine the properties of DFA and UDR (for example, they simultaneously certify a monetary claim and the right to demand the transfer of a thing). When using GCP, an investor can choose which redemption method they will use (receive a physical tangible asset or service, or present monetary claims and receive funds). Currently, GCPs cause concern from the standpoint of targeted use and application, partly because the legislator did not initially form a clear distinction regarding which digital rights should be defined as DFAs (by form) and which should not.

GCPs are not enshrined at the legislative level, but in accordance with paragraph 13 of Article 8 of the aforementioned federal law, digital rights including simultaneously utilitarian digital rights and digital financial assets can be acquired and alienated on an investment platform. In this case, the issuance, record-keeping, and circulation of such digital rights are carried out in accordance with the requirements of Law No. 259-FZ.

Advertising DFA

Law No. 259-FZ, via Article 20, supplemented Federal Law No. 38-FZ dated March 13, 2006, On Advertising (the "Law on Advertising"), with Article 29.1, which regulates DFA advertising.

Advertising for issued DFAs must contain:

the name of the person issuing the digital financial assets;
the Internet website address where the Decision on DFA Issuance is placed;
information on the maximum amount for which DFAs can be acquired by persons who are not qualified investors in accordance with Federal Law No. 39-FZ dated April 22, 1996, On the Securities Market, or the maximum total value of other DFAs that can be transferred as consideration to acquire DFAs by such persons;
an indication that the offered DFAs are high-risk, their acquisition may lead to the loss of transferred funds in full, and before concluding transactions with the offered digital financial assets, one should become familiar with the risks associated with their acquisition.

DFA advertising must not contain:

a promise to pay income on the DFA, except for income the obligation to pay which is provided for by the Decision on DFA Issuance;
forecasts for the growth of the market value of the issued DFAs.

Advertising for issued DFAs is not permitted before the Decision on DFA Issuance is published.

These restrictions are justified, as DFA advertising can be used by scammers to attract investment into projects that may not even exist. This type of protection for the average investor will help save their financial assets.

Thus, in case No. 039/05/5-284/2024, considered upon the application of the Bank of Russia regarding the distribution of advertising for financial services in a Telegram channel with an offer to invest in cryptocurrency with ultra-high returns, the Kaliningrad FAS Russia, in its decision dated June 28, 2024, stated that the news published on November 24, 2023, at 17:23 in the Telegram channel lacked the information provided for by Article 29.1 of the Law on Advertising, including "information on the possible risk of losing funds, given that investing in cryptocurrency is quite risky. The absence of information provided for by Article 29.1 of the Law on Advertising also makes it impossible to establish the existence of a decision on the issuance of such cryptocurrency, which grants the right to advertise a digital financial asset".

As we have seen in this article, DFA volumes are growing at a rapid pace. Concluding financial transactions within civil law relations is the most promising sphere for the application of DFAs. The enshrinement in legislation of the basic concepts and characteristics of the civil law regime for DFAs has influenced legal certainty in their application. Using DFAs as a source of attracting funds can have a positive impact on both the cost and the timing of project financing. At the same time, it is important to understand the risks of DFAs.

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References

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2. Ibid.

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5. Resolution of the Tenth Arbitration Appeal Court dated December 14, 2020, in Case No. A41-4212/20.

6. Digital Financial Assets and Their Operators. Official Website of the Bank of Russia.

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10. Ibid.

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12. Ibid.

13. National Legal Internet Portal of the Republic of Belarus.

14. Arizona Revised Statutes, Bill HB 2417, Section 44-7061. 2017. Arizona State Legislature website.

15. Vermont Statutes, Title 12, Chapter 81, Subchapter 1. 2016. Justia U.S. Law website.

16. Zaynutdinova E. V. Models of Legal Regulation for the Circulation of Digital Rights and Digital Currency. Law. Journal of the Higher School of Economics, 2023, Vol. 16, No. 4.

17. Reves v. Ernst & Young, 494 U.S. 56 (1990). U.S. Supreme Court. Justia U.S. Law website.

18. What is the Howey Test. Why the SEC Evaluates Cryptocurrencies According to 1940s Norms. June 8, 2023, RBC Internet Portal; Securities and Exchange Commission v. Telegram Group Inc. et al, No. 1: 2019cv09439 (S.D.N.Y. 2020). US Law. Justia.

19. Stankevich, V. S., Vlasov, A. V. Overview of Digital Assets. Trends in the Development of Digital Financial Assets in the RF and Development Forecast. Russian Journal of Economics and Law, 2024, Vol. 18, No. 2.

20. Decision of the Kaliningrad FAS Russia dated June 28, 2024, No. 039/05/5-284/2024.