New Russian Law Takes Effect, The Suspense of A7A5 Has Just Begun
Digital Financial Assets Law (259-FZ), which allows licensed "information system operators" to issue regulated digital financial assets (DFA) that must be hosted on private chains and issued by licensed institutions like Sberbank and Alfa-Bank—sounding completely different from a public chain stablecoin like A7A5.
However, according to an analysis article from Harvard University's Davis Center, in October 2025, the Central Bank of Russia issued a "non-opposition letter," which some research institutions interpreted as a tacit approval from Russian regulators for the cross-border use of A7A5. It should be noted that this is still an analytical wording from research institutions regarding the Central Bank of Russia's actions, not an official characterization publicly used by the Central Bank itself.
The official identity of A7A5 is actually "foreign-issued digital rights" (FDR), which does not fully comply with the original intent of 259-FZ, but the regulatory authorities chose to tacitly allow it. This has been the path A7A5 has taken over the past two years: without a dedicated law tailored for it, it relied on an ambiguous document from the central bank to open the door for cross-border settlements retroactively.
Broad Road vs. Narrow Bridge
The new law from the Duma essentially paves this side road into a formal highway—allowing the use of digital currencies for foreign trade contract settlements directly written into law, no longer requiring an ambiguous letter from the central bank.
However, the new law establishes a domestic registration directory: exchanges, clearing institutions, and brokers must all enter the Central Bank of Russia's registry, and banks and financial institutions will face stricter compliance requirements. A7A5, on the contrary—the issuer is in Kyrgyzstan, and the trading venues are foreign exchanges and public chain DeFi protocols, which objectively reduce the impact of freezing by a single jurisdiction.
This presents a paradox left for A7A5 by the new law: to enjoy the benefits of compliance, it must align with the domestic registry; yet once it leaves clear institutional and financial traces, its proud moat of being "easily re-minted and hard to freeze" will also be weakened.
The new law seeks a visible and manageable state pipeline; the value of A7A5 is precisely built on the invisibility and unmanageability of the matter. Whether the two can be compatible is itself a suspense.
After the Ceasefire, Who Will Exit First?
What truly makes A7A5 anxious is not the sanctions themselves, but the possibility that the sanctions may end.
As rumors of a ceasefire between Russia and Ukraine intensify, A7A5 executive Oleg Ogienko publicly stated: even if the sanctions are lifted, this coin still has reasons to survive—faster and more convenient cross-border settlements. This statement sounds confident, but from another perspective, it is also anxious: once the soil of sanctions that supports its existence disappears, what will it use to compete with liquidity-crushing dollar stablecoins?
The new law from the Duma is not preparing another stablecoin, but a national-level digital asset cross-border settlement system. In the past, Russia relied more on market-driven solutions like A7A5; in the future, whether it be new compliant stablecoins, regulated digital financial assets, or the digital ruble, all may play different roles within this institutional framework, without having to bet cross-border settlement capabilities on a token already deeply entangled in sanctions.
Interestingly, the Central Bank of Russia also plans to continue promoting the broader application of the digital ruble. The institutional framework and central bank digital currency are advancing almost simultaneously, indicating that Russia is attempting to gradually shift from a reliance on a spontaneously formed "shadow settlement network" to a state-led, regulatory-controlled digital settlement system.
A shadow token that survives through repeated maneuvering, a newly legitimized law that requires traceability, and a digital ruble issued directly by the central bank—three lines are running simultaneously. What sanctions truly force out is never a single brilliant design, but a whole set of mutually supportive survival systems.
Who will be eliminated first? Who will survive until after the ceasefire?
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