Why Russia’s harsh 1% crypto cap actually protects bank customer assets
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The Bank of Russia has proposed a 1% crypto capital cap, limiting covered crypto and foreign-digital-instrument risk to a bank’s own funds while leaving some client custody positions outside the new calculation.
Key facts
- The central bank plans official publication in the fourth quarter of 2026, with the requirements taking effect 10 days later
- The Sept. 18 proposal would create N31 for individual credit institutions and N32 for banking groups on a consolidated basis
- The Bank of Russia has proposed a 1% crypto capital cap, limiting covered crypto and foreign-digital-instrument risk to a bank’s own funds while leaving some client custody positions outside the new
- If the bank does not bear that responsibility, the client position is excluded from the two 1% ratios
Summary
01 N31 would measure individual banks, while N32 would apply the same 1% ceiling to consolidated banking groups. 02 Client custody stays outside N31/N32 only where the depository does not bear seizure or restriction-loss liability. 03 Uncovered custody receives a 50% risk weight; own and liable custody exposure receives a 1,250% risk weight. The Sept. 18 proposal would create N31 for individual credit institutions and N32 for banking groups on a consolidated basis.