The Digital Ruble in Foreign Economic Settlements: New Opportunities and Currency Control Requirements

The use of the digital ruble in international settlements could become an additional tool for Russian companies working with foreign counterparties. The proposed amendments allow for certain currency transactions to be conducted through digital ruble accounts and establish a special procedure for monitoring such transactions.

For businesses, the significance of this initiative extends beyond the creation of an additional payment method. Companies will need to consider who is authorized to use the digital ruble in foreign exchange transactions, which bank will oversee the proceeds, and the potential consequences if this bank is not designated.

What opportunities will appear for participants in foreign economic activity?

The proposed approach expands the methods for settling foreign trade transactions. Specifically, digital rubles are proposed for use in receiving payments from foreign counterparties for goods, work, and services.

Furthermore, the amendments affect certain situations related to the fulfillment of obligations under foreign trade agreements. In the cases envisaged by the draft, digital ruble accounts can be used to obtain:

• payments under contracts with non-residents;
• insurance payments related to the failure of a foreign counterparty to fulfill its obligations under a foreign trade transaction;
• funds within the framework of individual transactions for the assignment of a monetary claim to a financial agent;
• funds for the fulfillment or termination of obligations under contracts subject to the relevant currency regulation rules.

Thus, the digital ruble is viewed not simply as a new format for domestic payments, but as an additional channel for certain transactions with foreign counterparties.

However, the mere ability to open a digital ruble account will not automatically grant the right to use it for any foreign exchange transactions. It is expected that the regulator will define the categories of platform users and the list of acceptable cases for using digital rubles as a means of payment.

Who will determine the procedure for using the digital ruble?

The authority to establish the conditions for using the digital ruble in foreign exchange transactions is planned to be vested in the Bank of Russia. The regulator’s decisions will determine who exactly will be able to conduct such transactions and under what circumstances they will be permitted.

It is expected that the relevant decisions will be published within ten calendar days of their adoption.

For businesses, this means that when planning settlements, it will no longer be sufficient to rely solely on the general applicability of the digital ruble. Additional verification will be required to ensure that the established conditions apply to the specific transaction participant and the relevant type of operation.

In practice, this will require taking into account several factors:

• status of the transaction participant – resident or non-resident;
• the nature of the obligation and the basis for payment;
• admissibility of using the digital ruble for a specific category of transactions;
• the procedure for confirmation and control of receipts;
• requirements for interaction with an authorized bank.

Until final rules are issued, companies working with foreign counterparties should consider the digital ruble as a potential additional instrument, rather than a universal replacement for existing payment channels.

How will currency control be organized?

A key element of the initiative is the distribution of currency control agent functions among authorized banks participating in the digital ruble platform.

The procedure will depend on the direction of the transaction: whether digital rubles are debited from the user’s account or credited to it.

When funds are debited, the functions of the currency control agent are expected to be assigned to the bank to which the user submits the digital ruble transfer instruction. This bank will be responsible for executing the relevant transaction and performing control procedures.

for depositing funds will be different. The bank granting the user access to the platform must control the deposit. If multiple banks provide access, the user will be able to select one to control the deposit.

This distinction has practical implications: the bank through which the payment is sent and the bank responsible for monitoring its receipt may perform different functions. Therefore, it is important for companies to determine in advance how operations will be organized on both sides of the payment process.

Why choosing a bank is becoming critically important

If only one authorized bank provides access to the platform, receipt control will be linked to that bank. If multiple authorized banks are available, the user will be able to determine which one will perform the relevant functions.

To make a choice, you will need to notify the regulator of your decision through your chosen bank. According to the proposed procedure, the bank will begin acting as a currency control agent after receiving the necessary information from the platform operator.

This leads to an important practical conclusion: a company’s internal decision on choosing a bank is not sufficient. The choice must be communicated to the platform operator and confirmed in the prescribed manner.

If the bank responsible for monitoring receipts is not determined, digital rubles should not be credited as part of a foreign exchange transaction.

This requirement creates additional operational risk. Even if a foreign counterparty is willing to transfer funds, the lack of a properly designated bank may prevent the payment from being completed.

Therefore, companies should:

• find out which authorized banks provide them with access to the platform;
• determine the bank that will control the transfers;
• check whether the choice has been made in accordance with the established procedure;
• agree with the bank on the procedure for exchanging information and documents;
• Provide a procedure for action in the event of a change of bank or the occurrence of technical difficulties.

What challenges will banks and companies face?

The proposed model assumes that the platform operator will transmit information about digital ruble accounts and transactions to authorized banks, which is necessary for performing currency control functions.

Banks, in turn, will be required to apply the requirements of currency legislation to transactions with digital rubles according to principles comparable to the control of transactions on regular bank accounts.

For companies, this means that the transition to a new payment format does not eliminate the obligation to comply with currency regulation requirements. What changes primarily concern the transaction infrastructure and the mechanism for banks’ participation in oversight.

In particular, businesses will need to ensure consistency between contractual documentation, payment orders, and information provided to the bank. It’s also important to consider the timeframes for document preparation and compliance procedures, especially if the payment is related to the fulfillment of obligations under a foreign trade contract.

Additional attention will need to be paid to internal processes: the distribution of responsibilities between the finance department, accounting, and the foreign economic activity department, as well as the procedure for checking the status of payments.

What to consider when preparing for change

Until the bill has completed all necessary procedures, companies should not assume the new rules are in effect. However, preparing for the potential expansion of settlement instruments can mitigate risks after the changes come into effect.

At the preliminary stage, it is advisable to carry out several checks.

1. Assess the applicability of the new instrument. Determine which foreign trade transactions the company could potentially conduct using the digital ruble.
2. Review the banking infrastructure. Find out which banks provide access to the platform and who can act as currency control agents.
3. Review contracts. Determine whether it will be necessary to agree on a new payment procedure with foreign counterparties or clarify the terms of payment obligations.
4. Set up document flow. Determine what documents and information will be required to conduct transactions and interact with the bank.
5. Provide a backup plan. Maintain the option to use other acceptable payment methods in case a digital ruble transaction becomes impossible.

These actions are especially important for companies with regular income from non-residents, a large number of foreign trade contracts, or multiple banking service channels.

When might the new rules come into effect?

The draft provides for a delayed entry into force of the amendments—180 calendar days after the official publication of the law.

This period is intended to be used to prepare market participants and infrastructure for the new order. However, the final deadlines will depend on whether the law is adopted and the version in which it will be reviewed.

Until the changes come into force, companies should continue to adhere to current currency control regulations and evaluate the use of the digital ruble for foreign trade transactions in light of the final terms and conditions.

The proposed changes could expand the range of instruments available for settlements between Russian companies and foreign partners. However, the practical availability of the digital ruble will depend on the conditions established by the regulator and compliance with special currency control procedures.

For businesses, the key questions will be the permissibility of a specific transaction, the choice of a bank for receipts, and the readiness of internal processes for the new payment format. However, the lack of a designated bank may result in the inability to credit digital rubles, making preliminary arrangements with the bank an essential part of preparation.

Consequently, the potential benefits of the digital ruble in foreign economic activity will depend not only on the technological infrastructure, but also on the extent to which a company coordinates payment processes, documents, and banking support with the anticipated requirements.