Crypto Law Profile

Federal Law No. 115-FZ: AML/CFT Regime for Digital Currency Activity

Russia’s general AML/CFT statute treats digital currency as property and applies identification, risk-control, reporting, freezing, recordkeeping, and anti-tipping-off duties to specified miners and mining-pool organizers.

Russia Effective Act Feb 1, 2002

At a glance

Status In force within Russia’s broader AML/CFT framework.
Primary authority Rosfinmonitoring receives reports and maintains the flagged address-identifier list.
Covered activity Specified client-facing mining and mined-currency distribution, including pool activity.
Crypto phase-in Property treatment began in 2021; mining AML duties began in August 2024.

Overview

Russia’s Federal Law No. 115-FZ is the country’s general anti-money laundering and counter-terrorist financing statute. It was enacted on August 7, 2001, entered into force on February 1, 2002, and remains in force as of June 23, 2026. The law is not a crypto-specific code. Its digital-currency regime is formed by amendments that treat digital currency as property, extend selected AML/CFT duties to covered mining actors, and authorize monitoring of digital-currency address identifiers.

Federal Law No. 259-FZ added the rule that digital currency is property for purposes of 115-FZ from January 1, 2021. Federal Laws Nos. 221-FZ and 222-FZ then added the address-monitoring and mining provisions from August 19, 2024. The scope is qualified: Article 7.1 covers miners, including mining-pool participants, when they prepare or conduct specified transactions for or on a client’s instructions, including digital-currency mining or distribution of mined currency. A mining-pool organizer is covered when distributing mined currency among pool participants.

Scope of the digital-currency AML/CFT regime

Article 2 expressly brings digital-currency miners and mining-pool organizers within the statute’s wider preventive framework. Article 7.1 applies a defined set of obligations by cross-reference to duties elsewhere in 115-FZ. The provisions reviewed here therefore do not, by themselves, make every holder, transferor, or self-directed miner of digital currency an Article 7.1 reporting entity.

The law uses the Russian statutory concept of “digital currency.” That category should not be assumed to be interchangeable with digital financial assets issued through regulated information systems or with the digital ruble, which are addressed through separate provisions and related legislation.

Key duties for covered mining activity

For mining activity that falls within Article 7.1, the incorporated requirements include:

  • identifying clients, representatives, beneficiaries, and beneficial owners, and keeping relevant information current;
  • assessing suspicious-transaction risk, assigning risk levels, and applying measures designed to reduce identified risk;
  • maintaining internal controls, recording and retaining information, assessing risks from new services or technical tools, and applying required freezing or blocking measures;
  • refusing client onboarding in circumstances specified by the statute and requesting identity, registration, ownership, or other necessary documents; and
  • notifying Rosfinmonitoring when there are grounds to suspect that covered transactions or client conduct may involve money laundering or terrorist financing.

Pool organizers have a tailored reporting trigger: they must notify Rosfinmonitoring when there are grounds to believe distributed mined currency may be used by pool participants for money laundering or terrorist financing. Covered persons may not disclose that they transmitted information to the authority.

Reporting procedures and internal controls

Government Resolution No. 131, effective February 22, 2025, sets the reporting and information-request procedure. It generally requires suspicious-operation information within three working days and uses Rosfinmonitoring’s electronic personal account as the principal channel. The rules also govern responses to regulator requests and reports concerning freezing measures.

Government Resolution No. 1180, effective August 16, 2025, established updated requirements for internal-control rules developed by Article 7.1 subjects, expressly including covered miners and pool organizers. Rosfinmonitoring’s May 2026 memorandum states that use of its personal account is mandatory for Article 7.1 subjects and summarizes the associated reporting, internal-control, training, and responsible-officer framework.

Address-identifier monitoring and supervision

Article 8 requires Rosfinmonitoring to maintain a list of address identifiers where there are grounds to believe recorded digital-currency operations may be connected with money laundering, terrorist financing, extremist activity, or another criminal offense. The extremist-activity language became effective on June 1, 2025. Article 9.1 places Article 7.1 subjects within Russia’s risk-oriented AML/CFT supervisory framework, including remote monitoring based on information received by the authority.

Status and legal context

As of June 23, 2026, 115-FZ and the digital-currency provisions described above are in force. The regime should be read alongside Federal Law No. 259-FZ, the 2024 mining amendments, and implementing government and Rosfinmonitoring measures. Because 115-FZ is repeatedly amended and its crypto provisions are actor- and transaction-specific, this profile describes the statutory architecture rather than case-specific compliance obligations.

Key provisions

Digital currency treated as property

For purposes of 115-FZ, digital currency is recognized as property, bringing it within the statute’s property-based AML/CFT concepts.

AML/CFT Jan 1, 2021 Source

Conditional coverage of miners

Article 7.1 applies to miners, including pool participants, when they prepare or conduct specified mining or distribution activity for or on a client’s instructions.

Mining Aug 19, 2024 Source

Mining-pool organizer coverage

A mining-pool organizer falls within Article 7.1 when distributing mined digital currency among participants in the pool.

Mining Aug 19, 2024 Source

Identification and risk controls

Covered actors must apply incorporated duties on client and beneficial-owner identification, information updates, suspicious-transaction risk assessment, mitigation, records, and internal controls.

Risk controls Aug 19, 2024 Source

Suspicious reporting and anti-tipping-off

Covered miners and pool organizers must report specified suspicions to Rosfinmonitoring and may not disclose that information was transmitted.

Reporting Aug 19, 2024 Source

Address-identifier monitoring list

Rosfinmonitoring maintains a list of address identifiers linked on stated grounds to suspected laundering, terrorist financing, or other criminal conduct; extremist activity was added from June 1, 2025.

Asset monitoring Aug 19, 2024 Source

Electronic reporting procedures

Resolution No. 131 governs reports and regulator requests, generally using Rosfinmonitoring’s personal account and a three-working-day suspicious-report deadline.

Reporting Feb 22, 2025 Source

Updated internal-control standards

Resolution No. 1180 sets current requirements for internal-control rules developed by Article 7.1 subjects, expressly including covered miners and pool organizers.

Internal controls Aug 16, 2025 Source

Timeline

  1. Federal Law No. 115-FZ enacted

    Russia enacted Federal Law No. 115-FZ, the foundation of the current national AML/CFT framework.

    Enacted Source
  2. Federal Law No. 115-FZ entered into force

    The general AML/CFT statute became legally operative.

    In force Source
  3. Digital currency property rule took effect

    The law began recognizing digital currency as property for purposes of 115-FZ.

    In force Source
  4. Mining and address-monitoring amendments took effect

    Mining actors entered Article 7.1’s qualified scope, and Rosfinmonitoring’s address-identifier list was authorized.

    In force Source
  5. Reporting procedure took effect

    Resolution No. 131 established electronic reporting and regulator-request procedures for Article 7.1 subjects.

    In force Source
  6. Extremist-activity amendments took effect

    The broader regime and address-list wording were expanded to include extremist activity.

    In force Source
  7. Updated internal-control requirements took effect

    Resolution No. 1180 established updated internal-control requirements for Article 7.1 subjects.

    In force Source
  8. Rosfinmonitoring published updated Article 7.1 memo

    The regulator summarized current personal-account, reporting, internal-control, training, and officer obligations.

    Enacted Source

Who it affects

Actors

Government of the Russian Federation, Rosfinmonitoring

Asset classes

Digital currency

Official sources

Editorial note

This profile isolates the digital-currency and mining-related provisions of a much broader Russian AML/CFT statute. English renderings of Russian legal terms are editorial translations; the Russian-language text controls.