Regulatory update: digital asset and cryptocurrency tracing in Russia under Federal Law 229-FZ on enforcement proceedings

Amendments to Federal Law No. 229-FZ on enforcement proceedings, which came into force in mid-2026, have materially expanded the scope of assets that Russian court bailiffs are authorised to identify, trace, and freeze. Digital assets and cryptocurrency — previously absent from the statutory framework in any operational sense — are now expressly enumerated among the categories of property subject to enforcement action. For foreign creditors holding judgments or arbitral awards against Russian debtors, this development creates both a genuine new recovery avenue and a procedural imperative: the window to act before a debtor migrates holdings to less traceable wallets is narrow.

Before the 2026 amendments, the position of digital assets and cryptocurrency under Russian enforcement proceedings was acutely uncertain. Federal Law 229-FZ on enforcement proceedings defined recoverable property in terms that reflected an analogue economy: bank accounts, securities, movable and immovable property, receivables. Digital assets — whether defined as utilitarian tokens, digital financial assets under the 2020 framework, or cryptocurrency in the colloquial sense — occupied a legal grey zone. Bailiffs of the Federal Bailiff Service (FSSP) lacked clear authority to issue a tracing request to exchange operators, custodial wallet providers, or domestic digital financial asset platforms. Courts occasionally applied stretch interpretations, but these were inconsistent across circuits, and creditors acting on such reasoning faced meaningful enforcement risk.

The amendments change that position directly. The revised text of Federal Law 229-FZ now includes digital assets — expressed in the language of Federal Law No. 259-FZ on digital financial assets and cryptocurrency — within the asset categories subject to the FSSP's standard enforcement toolkit. The practical consequences are threefold. First, a bailiff acting on a valid writ of execution may now formally request disclosure from Russian-licensed digital financial asset operators and exchange intermediaries. Second, the FSSP is empowered to impose an attachment order over identified digital asset holdings, which triggers an obligation on the operator to restrict outbound transfers. Third, proceeds realised through court-supervised liquidation of attached digital assets may be credited to the creditor's recovery account in the same manner as proceeds from the sale of other property categories.

The before-and-after framing matters for creditors assessing the value of their position. Before mid-2026, a debtor with cryptocurrency holdings in a Russian-licensed custodial account was, from a practical standpoint, substantially beyond the reach of standard enforcement machinery. After these amendments, that same debtor is exposed to the same tracing and attachment procedures as a debtor holding funds in a conventional bank account — provided the assets sit within the regulated perimeter.

The most immediate impact falls on foreign creditors who have obtained, or are pursuing, a Russian court judgment or an arbitral award that is being enforced through Russian state courts. If the debtor is a Russian legal entity or an individual registered in Russia, and if that debtor holds digital assets through a Russian-licensed platform or a domestic custodial wallet operator, the new provisions bring those assets within reach of the enforcement writ.

The regulated perimeter is the operative constraint here. Russian law distinguishes between digital financial assets issued and traded on platforms licensed by the Central Bank of Russia, and cryptocurrency held in self-custody wallets or on foreign exchanges. The amendments to Federal Law 229-FZ operate within the licensed perimeter. A debtor who has already migrated holdings to a non-custodial wallet, or whose cryptocurrency is held on a foreign exchange without a Russian regulatory footprint, remains considerably harder to reach through this route. Creditors should not assume that the new provisions create a universal tracing mechanism for all crypto-denominated wealth.

That said, the practical significance extends beyond cases where the debtor's entire crypto position is on a Russian platform. In the firm's experience advising foreign trade creditors on asset tracing mandates in Russia, a debtor's regulated holdings are often a fraction of total digital asset wealth — but they are the traceable fraction, and the FSSP attachment of even a partial position can generate meaningful recovery or, importantly, create leverage that motivates settlement discussions. Creditors who delay initiating enforcement proceedings risk losing priority if a debtor proactively moves regulated holdings off-platform — a transfer that, once completed, removes those assets from the FSSP's direct access. Russian enforcement law does not impose a standstill on a debtor's asset management pending the bailiff's action; speed of instruction matters.

If you hold a Russian judgment or arbitral award and are assessing whether your debtor has reachable digital asset holdings — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

A creditor seeking to engage the new provisions should understand the procedural sequence that the FSSP is now authorised to follow. The starting point is a valid enforcement document — a Russian court judgment carrying the enforcement endorsement, or a recognition order issued by a Russian arbitrazh court in respect of a domestic or foreign arbitral award. The creditor (or Russian counsel acting for the creditor) presents this to the relevant territorial division of the FSSP and initiates enforcement proceedings.

Once proceedings are opened, the bailiff issues tracing requests to financial institutions and, under the amended framework, to digital financial asset operators licensed by the Central Bank of Russia. The operator's obligation to respond to such requests, and to impose a temporary restriction on outbound transfers pending further instruction, now has explicit statutory footing under Federal Law 229-FZ. The attachment order itself does not liquidate the assets; it freezes them in place while the creditor and the FSSP assess value and determine the appropriate realisation mechanism.

Realisation of attached digital assets raises questions that the amended statute addresses only in outline. The FSSP is authorised to sell attached property through designated trade organisations — the digital asset analogue is still being worked out in implementing guidance, and early FSSP practice will be closely watched. Creditors should anticipate some procedural uncertainty at this stage of the process, particularly for less liquid token categories. For creditors whose primary objective is recovery of a debt denominated in roubles or a major currency, the attachment itself may serve as sufficient leverage to bring the debtor to a negotiated position before liquidation becomes necessary.

"The 2026 amendments to Federal Law 229-FZ are a structural shift, not an incremental adjustment — they bring digital assets within the mainstream enforcement toolkit for the first time, and creditors who understand the regulated perimeter will find genuinely new recovery options available." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement & Asset Tracing, Vetrov & Partners

For creditors assessing recovery options against a Russian debtor with potential digital asset holdings — request a practice review: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

Yes — and they matter for creditors calibrating recovery expectations. The 2026 amendments to Federal Law 229-FZ establish the statutory authority for digital asset enforcement, but several implementing questions remain unresolved as of the date of this update.

First, the definition of "digital assets" cross-referenced in the amended statute is drawn from Federal Law 259-FZ, which distinguishes digital financial assets (DFAs) — essentially tokenised financial instruments issued on licensed platforms — from cryptocurrency proper. The enforcement provisions appear to apply to both categories, but the FSSP's operational guidance has not yet confirmed identical procedures for each. DFAs on licensed Russian platforms are structurally similar to securities from an enforcement standpoint; cryptocurrency is more variable in its custodial form and may require tailored procedures.

Second, the mechanism for valuing digital assets at the point of attachment is not yet standardised. The statute refers to "market value" determined through designated assessors, but for volatile or illiquid token categories, the practical application of this standard will depend on how the FSSP and supervising courts interpret it in early enforcement rounds.

Third, creditors whose debtors hold digital assets structured through foreign entities or cross-border custody arrangements — a common structuring pattern for Russian debtors with international financial interests — will not find a direct remedy in the amended Federal Law 229-FZ. The tracing of such structures requires a different set of instruments: Bilateral treaties, mutual legal assistance mechanisms, or parallel proceedings in the relevant foreign jurisdiction. The firm's comparative analysis of digital asset enforcement across key jurisdictions addresses the cross-border dimension in detail.

These open questions are not reasons to defer action. They are reasons to structure enforcement instructions carefully, with clear scope definition for the FSSP and a realistic sequencing of tracing requests.

• Navigating digital asset and cryptocurrency tracing in Russia — a practical guide
• Comparative analysis: digital asset and cryptocurrency enforcement across key jurisdictions
• Asset Tracing & Recovery in Russia — practice overview

Q: What specifically changed under the 2026 amendments to Federal Law 229-FZ?

A: The amendments expressly add digital assets — including digital financial assets licensed under Federal Law 259-FZ and cryptocurrency — to the categories of property subject to enforcement action by the Federal Bailiff Service (FSSP). Before these amendments, bailiffs lacked clear statutory authority to issue tracing requests to digital financial asset platform operators or to impose attachment orders over crypto holdings. The revised framework provides that authority directly, meaning that identified digital asset positions held on Russian-licensed platforms are now subject to the same attachment and realisation machinery as bank deposits and securities.

Q: Which foreign creditors are most affected, and in what circumstances does this new framework apply?

A: Foreign creditors with valid Russian enforcement documents — a Russian court judgment or a recognition order for a domestic or foreign arbitral award — are the primary beneficiaries. The framework applies where the debtor is subject to Russian enforcement jurisdiction (typically a Russian legal entity or individual) and holds digital assets on a platform licensed by the Central Bank of Russia. It does not automatically extend to assets in self-custody wallets or on foreign exchanges. Creditors with judgments obtained in foreign courts that have not yet been recognised in Russia will need to complete the recognition step before the FSSP's new powers are available to them.

Q: What should foreign creditors do now in light of these amendments?

A: Three steps are advisable. First, assess whether your existing enforcement documents are in a form that permits immediate FSSP action — if not, that preliminary step should be resolved before tracing requests are issued. Second, instruct Russian counsel to issue preservation-focused tracing requests promptly; the debtor has no obligation to maintain regulated holdings in place once enforcement is visible. Third, consider whether parallel asset mapping — looking beyond regulated platforms to offshore structures or self-custody arrangements — is warranted given the debtor's known financial profile. Our guide to digital asset tracing in Russia sets out the procedural sequence in detail.

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 — including institutional creditors, trade creditors, and foreign litigation funders — on the identification, freezing, and enforcement of Russian-situated assets. With over 1,000 matters handled since inception, the team combines direct procedural knowledge of the FSSP enforcement process with the cross-border coordination capability that multi-jurisdictional recovery mandates require. Partner-level involvement is maintained on every engagement.

Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

To discuss your recovery position in light of the 2026 amendments — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

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

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.