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Asset Tracing &amp Recovery

Alert: important development in digital asset and cryptocurrency tracing in Russia against privately held Russian companies

Alert: important development in digital asset and cryptocurrency tracing in Russia against privately held Russian companies Effective: July 2027

Russian arbitrazh courts have materially expanded their approach to digital asset and cryptocurrency tracing in enforcement proceedings against privately held Russian companies. Under Russia's legal framework for digital financial assets, courts are now ordering operators of digital asset platforms and custodians to disclose wallet data and freeze cryptocurrency holdings at the creditor's application — a development with direct consequences for foreign creditors seeking recovery from Russian counterparties.

Until recently, tracing digital assets held by privately held Russian companies was practically and legally uncertain. Russian law privately held Russian companies were rarely subject to effective cryptocurrency disclosure obligations in civil enforcement proceedings. That position has shifted. Courts have increasingly treated digital financial assets as attachable property under general enforcement rules, extending existing freezing mechanisms to on-chain holdings. The practical effect is that a foreign creditor pursuing a Russian debtor can now apply to an arbitrazh court for interim measures that reach a counterparty's cryptocurrency wallet — provided the creditor can identify the relevant platform or demonstrate that the debtor holds digital assets.

Three points require immediate attention from foreign creditors with live or anticipated recovery claims against privately held Russian companies. First, the window for early application matters: interim measures in cryptocurrency tracing proceedings are typically granted on an ex parte basis, before the debtor can dissipate holdings. Delay reduces the effective pool of recoverable assets. Second, the disclosure and freeze mechanism operates under Russian law, not through MLAT or foreign court order — meaning a locally admitted counsel relationship is essential from the outset. Third, for creditors with EAEU or CIS exposure, parallel enforcement routes may be available; the interplay between Russian domestic enforcement and cross-border recognition frameworks warrants early review.

Foreign creditors should review open recovery claims against Russian counterparties to assess whether digital asset holdings may form part of the recoverable estate. Counsel instruction at the interim measures stage — before formal enforcement proceedings are issued — will preserve the widest range of options.

Further analysis is available in our publications on digital asset tracing in Russian proceedings and the Supreme Court's clarification on digital asset recovery. The firm's Asset Tracing & Recovery practice advises foreign creditors at all stages of Russian enforcement.

To discuss a live recovery matter — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.

— Elizaveta Razina Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners vetrovpartners.com/razina/

About Vetrov & Partners

Vetrov & Partners is a boutique Russian law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm's Asset Tracing & Recovery practice advises foreign creditors on locating and enforcing against Russian-held assets, including digital financial assets and cryptocurrency holdings. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom