The disclosed scale of activity raises the compliance and enforcement stakes for any new Russian licensing regime, because a large share of current flows are described as outside the regulated perimeter. Firms serving Russian users should plan for near-term onboarding, reporting, and eligibility controls aligned to the central bank’s “differentiated access” model by investor category. In parallel, the European Commission’s proposed 20th sanctions package would expand restrictions on Russia-linked crypto trading and platforms, increasing the risk of EU-facing service cutoffs and counterparty screening changes once member states approve it.