In the past two years of advising foreign creditors pursuing digital asset and cryptocurrency tracing in Russia, one observation has become consistent: the assumption that blockchain transparency automatically translates into recoverable evidence before a Russian court significantly underestimates the procedural and regulatory obstacles that apply when the counterparty is a state-related entity. As of mid-2027, those obstacles have become materially higher. Recent regulatory changes to the framework governing digital financial assets in Russia — combined with judicial practice that has evolved to treat state-linked counterparties with procedural deference — require foreign creditors to revisit their tracing strategy from the ground up before initiating or continuing enforcement steps.
Until the end of 2026, digital asset and cryptocurrency tracing in Russia operated under a framework that, while restrictive, left creditors with identifiable procedural pathways. Russian law distinguishes between digital financial assets (DFAs) — tokenised rights issued on domestic platforms regulated by the Central Bank of Russia — and "other digital rights", a residual category that has historically captured foreign-issued cryptocurrency holdings. Foreign creditors could, in principle, seek judicial assistance in identifying wallet addresses, compel disclosure through pre-trial evidence orders in Russian arbitrazh proceedings, and request cooperation from domestic digital platform operators. These channels were narrow, but they existed.
The regulatory landscape changed materially in the first half of 2027. Amendments to the legislation governing digital financial assets, read alongside updated guidance from the Central Bank of Russia and Federal Financial Monitoring Service (Rosfinmonitoring), have introduced a set of provisions that expressly restrict disclosure of DFA-related information held by operators of information systems where the holder is a legal entity with state participation above a defined threshold. The stated rationale is protection of information relating to entities with strategic importance to the Russian economy. For foreign creditors engaged in digital asset cryptocurrency tracing, the practical effect is that the most transparent investigative channel — compelled operator disclosure — is now effectively foreclosed against this class of counterparty.
The 2027 amendments operate across three dimensions. First, operators of Russian DFA information systems are now prohibited from disclosing wallet addresses, transaction histories, and associated account data in response to civil enforcement proceedings where the account holder is a state-related entity as defined under the amendments — broadly, entities in which the state holds a direct or indirect participation interest above 25 per cent, or which have been designated as strategic under federal legislation. This prohibition applies regardless of whether the enforcement proceedings are conducted before Russian courts or a foreign arbitral tribunal seeking Russian judicial assistance.
Second, the amendments introduce a parallel restriction on blockchain analytics service providers that are registered or operate within Russian jurisdiction. Entities in this category are now required to obtain a specific authorisation before providing tracing outputs in connection with state-related counterparties to foreign persons. In practice, this authorisation has not yet been made available under any published procedure, meaning the restriction operates as a de facto prohibition in the near term.
Third, Russian courts have interpreted the new provisions broadly in early decisions following their entry into force. The prevailing approach in the arbitrazh courts — particularly in matters coming before the Moscow commercial courts, which handle the majority of state-linked entity disputes — has been to treat the statutory protection as extending to pre-trial disclosure orders as well as trial-stage evidence compulsion. Foreign creditors who obtained pre-trial blockchain tracing orders under the prior framework should not assume that those orders remain enforceable without re-examination.
"The 2027 amendments effectively create a parallel evidentiary regime for state-linked digital asset holders — one that foreign creditors pursuing recovery must address as a threshold question before any tracing step is taken." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners
The amendments are directly relevant to four categories of foreign creditor.
Trade creditors holding unpaid claims against Russian state-owned or state-controlled enterprises — including those in the energy, transport, and defence-adjacent sectors — will find that any digital asset or cryptocurrency holdings belonging to their counterparty are now substantially insulated from direct tracing through domestic procedural channels. Where the underlying claim is already in arbitral proceedings, creditors should assess whether the evidentiary restrictions affect their ability to establish the existence of traceable assets before the tribunal reaches an award.
Foreign institutional creditors and distressed investors who acquired claims against state-linked Russian entities through secondary markets face the additional complication that the amendments apply regardless of when the underlying obligation was incurred. The date of the debt does not determine whether the asset holder qualifies as a state-related entity for purposes of the new disclosure restrictions.
Foreign creditors who have already obtained arbitral awards against state-related Russian entities and are now at the enforcement stage face the most immediate pressure. The amendments do not alter the underlying enforceability of a foreign arbitral award under the New York Convention as implemented in Russia, but they substantially limit the investigative toolkit available to identify assets against which enforcement can be levied. Creditors who delay initiating tracing steps risk losing access to on-chain evidence that may be irretrievably obscured through wallet migration or asset transfer — a window that narrows once state-linked counterparties become aware of proceedings.
Finally, foreign companies in joint ventures with Russian state-linked entities should note that the amendments may also affect their ability to trace contributions, distributions, or intercompany transfers made through DFA platforms by their co-venturers, including in the context of corporate disputes or exit negotiations.
For creditors already in live proceedings, reassessing the asset-tracing component of their strategy is a matter of some urgency.
For foreign creditors engaged in recovery proceedings against state-linked Russian counterparties, make an enquiry to discuss the impact of the 2027 amendments on your matter: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76
The practical response to the 2027 amendments is not to abandon digital asset and cryptocurrency tracing as a recovery avenue, but to recalibrate the approach. Three lines of action remain available and, in the current environment, are more likely to produce results than domestic disclosure channels.
The first is jurisdictional arbitrage. Where a state-related entity holds digital assets through wallets or platforms in jurisdictions outside Russia — including through offshore structures in EAEU member states and CIS jurisdictions where regulatory cooperation with Russia is less fully developed than often assumed — tracing through those jurisdictions' own disclosure mechanisms may still be viable. This requires early coordination between Russian counsel and local counsel in the relevant jurisdiction, and a clear factual picture of where assets are actually held before proceedings are initiated. The firm's Asset Tracing & Recovery practice has handled cross-jurisdictional tracing matters of this type and can assist in mapping the asset landscape before formal steps are taken.
The second is pre-proceedings intelligence. Where domestic disclosure channels are foreclosed, open-source blockchain intelligence and non-compelled forensic analysis — conducted without reliance on Russian operator cooperation — becomes the primary evidential foundation. This requires engaging specialist blockchain analytics providers operating outside Russian jurisdiction, ideally at the earliest possible stage. Evidence gathered at this stage can later be placed before a foreign arbitral tribunal or enforcement court, even where Russian courts decline to compel its production domestically.
The third is review of existing procedural steps. Foreign creditors who have previously relied on Russian pre-trial disclosure orders, letters rogatory, or judicial assistance requests targeting DFA operators should obtain a current assessment of whether those orders remain operative under the 2027 framework. Courts have in several instances vacated prior disclosure orders on application by state-linked respondents. Waiting for the counterparty to bring that application is a materially worse position than conducting the review proactively.
Creditors pursuing cross-border enforcement involving Russian state-linked entities can also find context in the firm's analysis of comparative approaches to digital asset tracing in Russia and the procedural guide to navigating digital asset and cryptocurrency tracing in Russian proceedings. For matters involving insolvency of state-linked entities, the intersection with the Restructuring & Insolvency framework warrants separate analysis. See also the firm's Matters page for representative cross-border asset recovery instructions.
If you are a foreign creditor reassessing your digital asset tracing strategy against a Russian state-linked counterparty, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76
Q: What specifically changed in Russian law on digital asset tracing in 2027?
A: Amendments to the Russian digital financial assets framework that entered into force in 2027 introduced express restrictions on the disclosure of wallet addresses, transaction histories, and DFA account data where the asset holder is a state-related entity — broadly, any legal entity with state participation above 25 per cent or designated as strategically significant. Operators of domestic DFA information systems are prohibited from responding to civil enforcement disclosure requests concerning these counterparties. Blockchain analytics providers operating within Russian jurisdiction are similarly restricted pending an authorisation procedure that has not yet been made available. Russian courts have construed these provisions broadly in early post-amendment decisions, extending the protection to pre-trial as well as trial-stage disclosure orders.
Q: Which foreign creditors are most affected by the 2027 digital asset tracing restrictions?
A: The amendments most directly affect four groups: trade creditors with unpaid claims against state-owned or state-controlled Russian enterprises; institutional creditors and distressed investors who hold acquired claims against state-linked entities; foreign creditors who already hold arbitral awards and are now at the enforcement stage; and foreign companies in joint ventures with Russian state-linked co-venturers where tracing of asset flows is relevant to exit or corporate dispute proceedings. The restrictions apply regardless of when the underlying obligation arose — the date of the debt does not determine whether the counterparty qualifies as a state-related entity for purposes of the new disclosure framework.
Q: What should a foreign creditor do now in light of the 2027 amendments?
A: Three courses of action merit immediate attention. First, assess whether the counterparty holds digital assets through wallets or platforms outside Russia — jurisdictional arbitrage through offshore structures in EAEU or CIS member states may preserve tracing options that are foreclosed domestically. Second, commission non-compelled blockchain forensic analysis through providers outside Russian jurisdiction, which produces evidence that can be placed before foreign tribunals even where domestic disclosure is unavailable. Third, review any existing Russian pre-trial disclosure orders or judicial assistance requests targeting DFA operators — courts have vacated such orders on state-linked respondent applications, and proactive review is preferable to waiting for that step. Engaging Russian-qualified counsel with experience in cross-border asset tracing at the earliest stage preserves the most options.
Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 — Russia's principal legal directory — for eight consecutive years, and listed as a trusted adviser by the German Consulate General in Novosibirsk.
The firm's Asset Tracing & Recovery practice advises foreign creditors, institutional investors, and litigation funders on the identification and recovery of assets held by Russian counterparties, including across cross-border structures involving EAEU and CIS jurisdictions. With over 1,000 matters handled since inception, the practice combines deep knowledge of Russian investigative procedure with direct partner involvement on every engagement. Based in Novosibirsk, the team operates on UTC+7, providing effective morning-session overlap for Asia-Pacific creditors and end-of-business overlap for European instructing counsel.
Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom
This publication is provided for informational purposes only and does not constitute legal advice under Russian or any other applicable law. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Vetrov & Partners is a Russian-qualified law firm. For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction. For advice regarding your particular situation, please contact info@vetrovpartners.com.
— Elizaveta Razina Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners vetrovpartners.com/razina/