What legislative requirements apply to documents in the course of an ICO?
Territorial jurisdiction:
Russia
Short answer:
The question of documentary requirements for ICOs under Russian jurisdiction is irrelevant, as classic ICOs are prohibited. Applicable requirements pertain solely to the issuance of Digital Financial Assets (DFA).

Denis Polyakov
Head of Digital Economy practice at GMT Legal
Since a classic ICO, involving the placement of tokens with payment in cryptocurrency, cannot be conducted by a Russian company within the framework of current legislation, discussing legal requirements for documentation in the context of an ICO is incorrect. This format violates the prohibition on the use of digital currency as a means of payment (Part 5, Article 14 of Federal Law No. 259-FZ). If a company plans a lawful issuance of digital assets, it refers to the issuance of Digital Financial Assets (DFA). In this case, the key document is the Decision on the Issuance of DFA, the requirements for which are established in Article 3 of Federal Law No. 259-FZ. The decision must include, in particular, information about the issuer, nominal value, volume of issuance, terms of placement, circulation and redemption of the DFA, rights of the holders, and so forth. Therefore, when correctly formulating the issue, one should refer to the regulatory requirements for the issuance of DFA, rather than ICOs.