Millpay COO Igor Plotnikov spoke about the new digital currency regulations and how the USDT-to-ruble exchange process works on the Millpay service.
The law on digital currencies came into effect on September 1. How does it change services working with USDT and the ruble?
The main change is that Russia is effectively creating a separate, regulated infrastructure for the circulation of digital currencies. For services, this means a change in the very model of operations.
Organizations engaged in digital currency exchange will be required to operate under a separate status and be included in the Bank of Russia's register. Requirements will be established for their own funds, internal control system, risk management, technical infrastructure, employees, and reporting. Market participants will also be required to join a self-regulatory organization.
The law distinguishes between the actual exchange of digital currency and its accounting. The exchange organization conducts the transaction with the client, but the fulfillment of obligations in digital currency when working with Russian residents must, as a general rule, be carried out through a digital depository. The digital depository effectively becomes part of the transaction infrastructure. It records the client's digital assets, ensures their crediting and debiting, as well as access to identifier addresses and the execution of transactions with them in cases stipulated by law.
Additionally, the service is subject to requirements for client identification, AML control, and digital transaction analysis. The service must also take into account the client's status. Individuals undergo testing before conducting any digital currency transactions, and this applies to both qualified and non-qualified investors. Non-qualified investors are additionally limited to the list of available digital currencies and a limit of 300 rubles per year on acquisitions through a single intermediary.
The new system is being introduced in stages during the transition period. We have made a strategic decision to develop Millpay's infrastructure in accordance with Russian legal requirements and will consistently align our technological processes, compliance, and operating model with emerging requirements.
How significant is the annual limit for non-qualified investors?
It's important to understand that the annual limit for non-qualified investors is set separately for each licensed intermediary. This is not a cumulative annual limit per user across the entire market. The law does not prohibit a user from purchasing digital currency from another intermediary within the established limits after reaching the limit with one intermediary. However, if a user wishes to purchase digital currency from a single licensed intermediary in excess of the established limit, they must obtain qualified investor status. This status can be obtained on several grounds, such as income or property level, work or investment experience, or relevant education. Since August 31, it has also become possible to confirm the necessary qualifications by passing a special exam and receiving a certificate.
What are the most common cryptocurrency use cases for Russian users?
According to our observations, one of the most common scenarios is acquiring cryptocurrency for subsequent storage. This pattern is also confirmed by research on the Russian market: investments and storage remain the primary use cases for cryptocurrency.
Users also purchase cryptocurrency to pay for foreign goods and services.
How does payment for foreign services work using these payment instruments?
The process is incredibly simple for users. They can top up the service using one of the available methods—through the Fast Payment System (SBP) or using digital currency. The entire payment process takes no more than a minute: the user selects the service, specifies the top-up amount, and completes the transaction.
How do you structure the USDT-to-ruble exchange from a compliance perspective?
First of all, using the service is only possible after completing KYC. The client provides the necessary personal information and documents and undergoes liveness verification, which confirms that the identity of the person being identified is real. Without successfully completing KYC, transactions are impossible.
After this, the user gains access to digital currency transactions within the limits set by the service. Each transaction undergoes additional AML verification, including analysis of associated cryptocurrency addresses and transactions.
Depending on the amount, nature of the transaction, and identified risk factors, compliance may request additional documents, including confirmation of the source of funds or assets.
Thus, we evaluate not only the client themselves at the registration stage, but also the transactions they conduct through the service.
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