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KYC/AML for the crypto industry: users, wallets and transactions under the digital currency law

Since 1 September 2026 the digital currency law has been in force: exchanges, brokers, exchange offices and digital depositories enter the Bank of Russia registers and are responsible for checking customers under 115-FZ. We check the user by document and face, the person against the Rosfinmonitoring lists and sanctions, the wallet by risk score and transactions by monitoring rules. The decision on a deal stays with you.

Checking a crypto service customer: document, lists and sanctions, wallet risk score
195+ countries and territories in document recognition
5 ₽ OFAC, EU, UK and UN sanctions lists
36 ₽ international screening: sanctions and PEP
from 29 ₽ document + liveness per KYC session
Data is stored in Russia Russian software registry no. 19972 152‑FZ

Choose a crypto industry segment

The card shows whom this business checks and which checks to connect. The crypto wallet checking page already exists, the segment pages will appear in this section — until they are released, the card leads to the relevant section of this page.

Exchanges, exchange offices and wallets

The customer, their wallet and transactions before the first deal.

  • Address risk score · Sanctions · Wallet owner

    AML check of crypto wallets

    The customer's address — before the deal: risk score, sanctioned addresses, links to mixers and the darknet, share of funds by category. The owner — against the Rosfinmonitoring lists and sanctions in the same process. Digital analysis under Article 35 of 282-FZ — from 1 September 2026.

  • KYC · Liveness · Sanctions · KYT

    Crypto exchanges and brokers

    User verification with a liveness check, Rosfinmonitoring lists, sanctions lists and PEP before the first deposit. The non-qualified investor limit is in your system, the checks are with us.

  • KYC · AML address check · KYT

    Wallets, custodial services and crypto acquiring

    A custodial wallet owner — by document and face, incoming addresses — by risk score, foreign-trade payments — by counterparty and sanctions. No anonymous accounts: a digital depository does not open accounts for anonymous or pseudonymous holders (para. 5.2‑2, Art. 7, 115‑FZ as amended by 283‑FZ).

  • Passport recognition · Lists · Wallet address

    Exchange offices and crypto ATMs

    A customer of an exchange point or crypto ATM — by passport and liveness in one session, lists and sanctions — before the payout, the address — before sending. Preparing for the Bank of Russia register before 1 July 2027.

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Law No. 282-FZ on digital currencies: what changes for exchanges, exchange offices and digital financial asset operators

Crypto compliance is now built on the law: Federal Law No. 282-FZ 'On Digital Currencies and Digital Rights' has been in force since 1 September 2026 and recognises digital currency as property. Only participants from the Bank of Russia registers will be able to organise its circulation, and a breach of the 115-FZ rules is grounds for removing the organisation from the register.
NeuroVision covers checking the customer, their wallet and transactions. Capital requirements, reporting and the decision on a deal stay with you.

  • Exchanges, brokers and managers

    282‑FZ, Part 3, Art. 1, Arts. 14–16; para. 3, Part 1, Art. 31 — Bank of Russia instruction

    User KYC

    Who is entitled

    • A trading organiser, broker and trust manager from the Bank of Russia registers
    • The requirements for them are set by the Bank of Russia

    Investor

    • A non-qualified investor — after a test; the annual amount is set by the Bank of Russia — under the draft instruction, 300 000 ₽ through one intermediary
    • A qualified investor — also after a test, with no annual limit

    What to check

    • The investor's identity and document
    • The Rosfinmonitoring watchlists and sanctions
    • Your system maintains the status for the test and the limit
  • Exchange offices and digital depositories

    282-FZ, Art. 17, 18, 21, 30–31; Part 2 of Art. 56

    Rosfinmonitoring watchlists

    Exchange office

    • Systematic exchange — two or more deals a month for an amount over 3.5 million ₽
    • Only an organisation from the Bank of Russia register and a member of a self-regulatory organisation
    • Own funds — not less than 15 million ₽ (Part 3, Art. 44, 282‑FZ)

    Before 1 July 2027

    • Exchange offices work without being entered in the register
    • After this date banks refuse transfers to those who organise circulation without the right

    Digital analysis

    • An exchange, broker, manager and exchange office check addresses and transaction risk before the deal — from 1 September 2026 (Art. 35)
    • Details — on the crypto wallet checking page

    Transfers

    • A transfer to an address not administered by a digital depository — only in cases set by law and to the address of a foreign organisation that has such a right
  • Digital financial assets, mining and settlements

    259-FZ; 282-FZ, Parts 6–7 of Art. 1, Part 13 of Art. 6, Art. 55; 221-FZ; 223-FZ

    Digital financial assets and mining

    Digital financial assets

    • Issuance — after identification of the acquirers under 115-FZ
    • Existing operators move to the new law during a transition period

    Mining

    • The registers of miners and infrastructure operators are kept by the Federal Tax Service
    • A miner reports to the tax authority the currency received and the addresses

    Payment

    • Paying with digital currency for goods and services in Russia is not allowed
    • It is allowed — in foreign-trade contracts with non-residents

1 September 2026, 300 000 ₽, 1 July 2027: dates and thresholds of the new law for crypto services

Four figures on which the compliance plan for the coming year depends. Everything the law leaves to the Bank of Russia — capital requirements, tests, the list of available currencies — is clarified by its acts.

  • 1 September 2026 — the law takes effect

    Digital currency — is property, rights to it are protected in court.

    Market participants prepare documents for the Bank of Russia registers.

    • Part 1 of Art. 56 of 282-FZ
  • The non-qualified investor limit — under the draft instruction, 300 000 ₽ a year

    Before deals — a test and a signed risk statement.

    The limit — the annual amount for all transactions through one intermediary is set by the Bank of Russia; under the draft instruction — 300 000 ₽.

    • para. 3, Part 1, Art. 31, 282‑FZ
  • 3.5 million ₽ a month — the threshold of systematic exchange

    Two or more deals a month for an amount over 3.5 million ₽ — is already exchange office activity.

    Exchange office — only from the register, membership in a self-regulatory organisation — within 90 days.

    • Art. 18 of 282-FZ
  • 1 July 2027 — only participants from the registers

    Organising circulation of currency is allowed only to persons named in the law.

    Banks refuse transfers to those who work without the right and report them to the Bank of Russia.

    • Part 2 of Art. 56, Art. 21 of 282-FZ

From registration to withdrawal of funds: what to check about a crypto service customer

  • A Russian passport or a foreign document from 195+ countries and territories is recognised from a photo, the fields arrive in the form NeuroVision
  • The document is checked for forgery: a photo of a screen, a printout, editing in an editor NeuroVision
  • Liveness and face comparison — in front of the camera is the same live person, not a mask or a deepfake NeuroVision
  • One document — one account: a repeat registration on the same data is visible immediately Your compliance

  • The address for deposit or withdrawal gets a risk score: sanctioned addresses, mixers, darknet, fraudulent wallets NeuroVision
  • That an external wallet belongs to the customer — confirmation of the owner under your procedure Your compliance
  • A transfer to an address outside the digital depository — only in cases set by law The Bank of Russia and Rosfinmonitoring

  • Real-time transaction monitoring: splitting, transit, atypical amounts and links between accounts NeuroVision
  • A repeat check against the lists when they are updated and before a large withdrawal NeuroVision
  • The decision to suspend a transaction and the report to Rosfinmonitoring Your compliance
  • Requirements for the internal control rules and reporting of a register participant The Bank of Russia and Rosfinmonitoring
  • Payer and recipient data is sent together with the transfer (Travel Rule) — Art. 7.2‑1, 115‑FZ, threshold 60 000 ₽ The Bank of Russia and Rosfinmonitoring
  • NeuroVision — covered by the NeuroVision check: document, face, lists, sanctions, wallet address, transaction monitoring
  • Your compliance — the decision, internal control rules and reports to the regulator: yours
  • The Bank of Russia and Rosfinmonitoring — the regulator's requirements and actions: NeuroVision does not take part in them

Where NeuroVision ends: checks of the customer and wallet are ours, the decision and reporting are yours

  • NeuroVision does

    The customer. Document, liveness and face comparison — in one KYC session.

    Watchlists and sanctions. Rosfinmonitoring, OFAC, EU, UK, UN, PEP — as you choose.

    Wallet and transactions. Address risk score and real-time transaction monitoring rules.

  • Done by your compliance

    Decision. Accept the customer, refuse a transaction, request the source of funds.

    Internal control rules. Risk profile, thresholds, repeat check intervals.

    Reports to Rosfinmonitoring — through your personal account.

  • Not part of NeuroVision

    The Bank of Russia register. Capital, self-regulatory organisation, reporting and documents for entry in the register.

    The investor test and limit. Testing and tracking of the annual limit are done by the intermediary.

    Custody of assets. Wallets, keys and records of rights — with you and the digital depository.

We do not hold your assets and do not send reports to the regulator. We make sure that a person with someone else's passport, a person from a list or a wallet with a dirty history does not get through to the deal.

What is visible about a crypto service customer before the first deposit

Verification of a crypto exchange or exchange office user takes place in one session: a photo of the document, liveness, database checks and the wallet address. Before the first deposit you already know who is in front of you and where the money will come from.

  • Document

  • Face

    • Liveness — a live person in front of the camera, not a photo, video or mask
    • Detection of a deepfake and face substitution — before entering the account
    • Comparison of the selfie with the photo in the document
    • The widget — in a browser and in an app via WebView
  • Watchlists and sanctions

    • The list of terrorists and extremists Rosfinmonitoring
    • OFAC, EU, UK and UN — by spelling in Latin and Cyrillic letters
    • Politically exposed persons and the register of foreign agents
    • A repeat check when the lists are updated
  • Wallet

  • Profile and transactions

    • INN from the passport, bankruptcy, wanted lists, enforcement proceedings
    • A non-resident — international screening
    • Transaction monitoring: splitting, transit, linked accounts
    • The decision and thresholds — in your risk policy
  • A hardware wallet and a smartphone with an exchange app on a compliance officer's desk

Digital financial asset operators and mining: identifying investors and checking participants

Digital financial assets and mining have their own law and their own buyer of checks. A digital financial asset operator checks investors before issuance, a mining company — customers and buyers of the currency.

  • 01

    A digital financial asset investor — before issuance

    The operator issues digital rights only after identifying the acquirers under 115-FZ. The document, liveness, lists and sanctions are passed before the first order, not after the funds are credited.

  • 02

    Issuer and payouts

    The issuing company — by INN, director and beneficiaries. Payouts on digital rights to addresses outside the depository also require identification of the recipient.

  • 03

    A miner in the Federal Tax Service register

    Mining activity is conducted under the mining law, the registers of miners and infrastructure operators are kept by the tax authority. The customer for equipment hosting and the buyer of mined currency — by INN and sanctions before the contract.

  • 04

    Transition to the new law

    Existing digital financial asset operators bring their activity into line with the digital currency law during a transition period. Customer checks do not depend on the change of regime — the scenario carries over as it is.

Exchange offices and crypto ATMs: the customer, wallet and source of funds before the deal

An exchange office works with cash, cards and other people's wallets, and the customer often comes once. Until 1 July 2027 an exchange office may work without a register, but the checks that the Bank of Russia will require are easier to set up in advance.

  • Passport and liveness in one session

    The cashier or crypto ATM photographs the passport, the customer passes liveness on the phone. The data goes into the form with no retyping, forgery and a photo of a screen — before the payout.

  • Lists before the payout

    The list of terrorists and extremists, sanctions and wanted lists — while the customer waits. A match goes to manual review and the deal is stopped.

  • The address before sending

    The wallet to which the customer asks to send the currency gets a risk score. An address from a sanctions list or linked to a mixer is a reason to refuse.

  • Source of funds

    For a large amount or high risk the customer explains the origin of the money. The form and documents are recognised by the same service, the decision is made by your compliance.

How a crypto service customer check works

Three steps from registration to the decision. The customer goes through the widget in the app or on the website, the rest goes through the API.

Step 1

Document and liveness in the app

The customer photographs the passport and passes liveness in the widget — in the app or on the website. The document type and country are determined automatically.

The customer photographs the passport and passes liveness in the app
Step 2

Lists, sanctions and wallet address

The document data goes to checks against the Rosfinmonitoring lists, sanctions and PEP, the wallet address — to the risk score.

Checks against lists, sanctions and the wallet address risk score
Step 3

The decision in your system

The results arrive in JSON, disputed customers — to manual review. Transactions then go under monitoring.

A customer card with check results and a decision

What a solution for the crypto industry is built from

Six products of one platform. Connect the ones you need — you pay for completed checks.

  • KYC and document recognition

    Documents of 195+ countries and territories, document anti-fraud, a form with no manual entry.

    Learn more
  • Liveness and deepfake protection

    Liveness, deepfake detection by face and comparison of the face with the document.

    Learn more
  • Rosfinmonitoring watchlists

    The list of terrorists and extremists and the register of foreign agents — 5 ₽ per check.

    Learn more
  • Sanctions and PEP

    OFAC, EU, UK, UN — 5 ₽; international screening — 36 ₽.

    Learn more
  • AML check of crypto wallets

    Address risk score: sanctions, mixers, darknet, fraud — before deposit and withdrawal.

    Learn more
  • KYT — transaction monitoring

    Real-time transactions, splitting and linked accounts, cases for investigations.

    Learn more

How much KYC and AML checks cost for a crypto service

The price is per one KYC session of one customer and per each database check. No subscription fee, the more checks a year — the lower the price.

  • Watchlists and sanctions

    5 ₽ per check

    Configure a set

    The list of terrorists and extremists, the register of foreign agents, OFAC, EU, UK and UN sanctions. The basic package of database checks — 50 ₽, international screening — 36 ₽.

  • Most popular choice

    Document + liveness

    from 29 ₽ per session

    Enable

    Recognition and anti-fraud of the document, liveness, face comparison, deepfake detection.

  • Wallet and transactions

    on request

    Calculate

    AML address check and transaction monitoring for your volume and networks.

The 'Extended' package — document, liveness and database checks in one session — on request. For 100 000+ checks a year — an individual price.

How to connect the checks to an exchange or exchange office: widget, API or cloud

An exchange needs a widget in the app and an API into the back office, an exchange office — a widget link and a web account.

Widget and link

Document, liveness and face comparison — in a browser or in an app via WebView. No development — a widget link. The logo, colours, texts and languages are configurable.

Terms

  • A 1-month trial period
  • A dedicated manager
  • Tickets-based technical support
  • Payment for the checks performed

Why crypto services and digital financial asset operators choose NeuroVision

A crypto service needs a provider that covers the person, wallet and transactions and keeps data in Russia.

The person, wallet and transactions — in one platform

KYC with liveness, Rosfinmonitoring lists, sanctions, address checking and transaction monitoring work on the same customer data. There is no need to combine three systems into one form.

One customer form instead of three systems.

Liveness and deepfake protection

A photo, video and face substitution do not pass.

OCR MRZ 195+ JSON

Data in Russia

The NeuroVision cloud, 152-FZ.

Payment per check

From 5 ₽, with no subscription fee.

Skolkovo — participant

A Russian developer

Russian software register No. 19972.

Licences and certificates

Innovation Promotion Foundation

The project «Development of a multimodal system using artificial intelligence "Neuromed" for managing the diagnostic processes of a clinic on the basis of the "Neurovision" computer vision platform» is supported by the Innovation Promotion Foundation within the federal project «Domestic Solutions»

Crypto compliance terms

Briefly on the concepts of the digital currency law and AML checks.

Digital currency
A set of electronic data in an information system that is accepted as a means of payment or investment. Under Law No. 282-FZ — property; paying with it for goods in Russia is not allowed.
Crypto
Digital financial assets
Digital rights — monetary claims, rights under securities and others — that are issued in the operator's information system.
Digital financial assets
Identifier address
A unique sequence of characters for recording transactions in an information system — the wallet address.
Wallet address
Digital depository
An organisation from the Bank of Russia register that records rights to digital currency and administers customers' addresses.
Custodian
Digital currency exchange office
An organisation from the Bank of Russia register that systematically buys and sells digital currency for its own account outside an exchange.
Exchanger
Non-qualified investor
An investor who has access only to liquid currencies, after a test and within the annual limit through one intermediary: the amount is set by the Bank of Russia, under the draft instruction — 300 000 ₽.
Address risk score
An assessment of how far a wallet is linked to sanctions, mixers, the darknet or fraud.
Risk score
Mixer
A service that mixes the funds of different users to hide their origin.
Mixer
KYT
Transaction monitoring of the customer in real time: amounts, links, atypical behaviour.
Know Your Transaction
Travel Rule
The FATF rule: providers pass the sender and recipient data of a virtual asset transfer to each other. In Russia — Art. 7.2‑1, 115‑FZ: payer and recipient data is sent together with the transfer, threshold 60 000 ₽.
FATF R.16

Questions about KYC and AML in the crypto industry

The law No. 282-FZ 'On Digital Currencies and Digital Rights' has come into force. Digital currency is recognised as property, and exchanges, brokers, exchange offices and digital depositories enter the Bank of Russia registers. From 1 July 2027 only participants from the registers will be able to organise currency circulation. A breach of the 115-FZ rules is grounds for removal from the register.

Yes. Register participants apply the 115-FZ rules: they identify customers, check them against the Rosfinmonitoring lists and monitor transactions. How exactly — will be determined by the internal control rules and Bank of Russia acts.

An organisation that systematically buys and sells digital currency for its own account outside an exchange: two or more deals a month for an amount over 3.5 million ₽. It may work only after entry in the Bank of Russia register; before 1 July 2027 — without the register.

The annual amount is set by the Bank of Russia — under the draft instruction, 300 000 ₽ through one intermediary (para. 3, Part 1, Art. 31, 282‑FZ), and only after a test. The intermediary tracks the limit, and checking the investor\'s identity can be entrusted to NeuroVision.

Yes. The address gets a risk score: links to sanctioned addresses, mixers, darknet marketplaces and fraudulent wallets. The check runs before crediting and before withdrawal, and the decision is made by your compliance.

By the document from the KYC session: OFAC, EU, UK and UN — 5 ₽, the Rosfinmonitoring list of terrorists and extremists — 5 ₽, international screening with PEP — 36 ₽. A repeat check — when the lists are updated.

Yes. Liveness checks that a live person is in front of the camera, not a photo or video, and deepfake detection works by face. The face is compared with the photo in the document.

No. We check the customer, wallet and transactions and pass the results to your system. The decision on a deal and reports to the regulator are the responsibility of your compliance.

Yes. The operator issues digital rights after identifying the acquirers under 115-FZ: the document, liveness, lists and sanctions are passed before the first order, and the issuer is checked by INN.

Document with liveness — from 29 ₽ per session, a check against lists and sanctions — 5 ₽, wallet check and transaction monitoring — on request. Test access — on application.

We will select checks for your exchange, exchange office or digital financial asset platform

Tell us whom you check and how many customers and wallets a month. We will build a KYC and AML scenario and give test access.

Can't put your request into words? Book a call and our team will contact you at a convenient time

Book a call

The company is included in the register of IT companies and the register of personal data operators of the Russian Ministry of Digital Development.

Address: Moscow, Presnenskaya Embankment 12 — Moscow City business centre, Federation Tower. Nearest metro stations: Delovoy Tsentr and Mezhdunarodnaya.