What exactly did the Bank of Russia propose?
On September 18, the Bank of Russia (Russia's central bank) put forward a proposal introducing a capital cap on banks' crypto exposure. According to CryptoSlate, the cap is set at 1%, measuring so-called covered exposure to crypto assets and foreign digital instruments against the institution's own capital, not against its total assets.
A transparent note on credibility right up front: the entire regulatory core of this story (the 1% cap, the N31/N32 ratios, the exclusion of part of custody) currently comes only from a single summary by CryptoSlate. We do not have direct access to the full text of the Bank of Russia's proposal. So treat the details as reporting on a draft, not as a verified final regulation.
The proposal introduces two new ratios:
| Ratio | Who it applies to | Level of calculation |
|---|---|---|
| N31 | Individual credit institution | Individual |
| N32 | Banking group | Consolidated |
Both ratios use the same proposed cap. This means that both the bank itself and the wider group it belongs to are subject to the same percentage limit. According to CryptoSlate, it is a two-tier structure meant to prevent risk from being shifted between individual entities and the parent group.
Why might a strict cap paradoxically protect clients?
Here is the heart of the story. The cap apparently does not apply to all the crypto a bank holds. According to CryptoSlate, some positions held in client custody remain outside the new calculation.
The difference is fundamental. When a bank holds crypto as its own investment, that is a risk to its own capital, and that is exactly what the 1% cap is meant to rein in. But when a bank merely holds crypto for a client (custody), the asset belongs to the client, not the bank. Excluding such custody from the calculation would mean that client positions do not reduce the bank's headroom under the cap and at the same time are not exposed to the same regulatory pressure as the bank's own trading book.
In other words: the cap is strict on what the bank risks with its own money, but it probably lets the service where the bank merely safeguards someone else's assets breathe. That is the interpretation CryptoSlate highlighted. We stress the word interpretation: this is a reading of the draft, not a confirmed effect of a finished rule.
What is not yet clear
The proposal is still in draft form. That matters. CryptoSlate states that the rules are not final, so the precise definitions (for example, which specific custody positions fall inside and which fall outside) may still change. The exact methodology of "covered exposure" and its exemptions are not fully spelled out in the available summary, so we do not take them as settled facts.
We also do not know the effective date or the final wording. We do not know exactly which custody positions fall into the calculation and which drop out of it. The only thing that is certain so far is that, according to the source, part of custody remains outside. Everything else is open.
How does this fit into the broader banking picture?
The Russian approach is restrictive, but not isolated. Banks around the world are right now grappling with how to handle crypto custody from a regulatory standpoint.
- Bastion received, according to Cointelegraph, conditional approval from the U.S. OCC for a national trust bank charter. The entity Bastion Platforms National Trust Company aims to offer stablecoin custody, wallets, payment infrastructure, and white-label issuance from a single federally regulated entity.
- Deutsche Bank, according to Kryptomagazín, plans to launch digital asset custody for institutional and corporate clients in Europe by the end of 2026, initially for bitcoin, ether, and selected stablecoins.
- JPMorgan, according to CrypS.pl, points to a difference in investor positioning in the ETF market: according to the bank, bitcoin ETFs have so far recovered only about half of earlier capital outflows, while gold funds have already made up their losses from the start of the year.
The common denominator: custody is becoming a regulated banking service. The Russian proposal approaches it from the opposite side than a charter like Bastion's, but it addresses the same question, namely how to separate the bank's risk from client assets.
What to watch for with rules of this kind
With capital caps of this type, the key is to watch three things: (1) whether it is measured against capital or against total assets (here, according to the source, against capital), (2) how "covered exposure" is defined and what drops out of it, and (3) whether the cap applies at the level of the individual bank and the whole group (here, according to the source, both, via N31 and N32). Once the Bank of Russia publishes the final wording, these points can be checked against the draft and against how the single available source reports them today.
Charliedesk does not give investment advice. This is a description of what has been proposed and what is not yet clear.