Is it permitted to use cryptocurrency for settlements with foreign counterparties?

Pursuant to Part 5 of Article 14 of Federal Law No. 259-FZ dated July 31, 2020 (as amended on August 8, 2024), the use of digital currency as a means of payment for goods, works, or services within the territory of the Russian Federation is prohibited. This prohibition applies regardless of whether the payer is a Russian or foreign entity. Accordingly, companies registered in the Russian Federation are not permitted to accept cryptocurrency as payment, even from foreign counterparties. At the same time, the law does not contain a direct prohibition on making payments to foreign entities, including in digital currency. Therefore, a Russian company may theoretically use cryptocurrency as a means of settlement outside the territory of the Russian Federation, provided it acts as the payer rather than the recipient. However, such actions remain within a regulatory gray area and may involve currency control issues, tax risks, and the risk of transactions being declared invalid.