Fintech Market Overview

This article does not constitute legal advice.

Banking in Russia

Fintech Software

The Digital Marketplace model works as a platform for interaction between companies' commercial offers that are displayed to visiting consumers. Such consumers choose from these goods those that match what they are looking for. Financial products are handled similarly, performing in marketplaces designed to carry out transactions between consumers and credit institutions or intermediaries. Consumers can purchase financial products, insurance, or participate in the stock market. Business bank accounts are not permitted, though. As of July 20, 2020, with the entry into force of Federal Laws Nos. 211-FZ and 212-FZ, these financial activities on digital marketplaces in Russia are legal.1

The mandatory requirements under the new legislation that a Russian legal entity, with the legal form of a joint-stock company wishing to be an operator of a financial platform needs, are:

  • it must be included in the Central Bank's Register of Financial Platform Operators;
  • its registered capital must be at least 100 million roubles;
  • it may perform activities related to a commercial organisation, being a depositary, specialised depositary, or registrar. Apart from these functions, it must not integrate other functions inherent to a non-bank credit or financial institution.
  • to have a fully functioning Internal Control System and Risk Management System.
  • hardware and software facilities must be located in Russia;
  • meet the information protection stipulations set out by the Central Bank; and
  • members of its management groups and employees must satisfy competence requirements, as well as requirements for the market operator's shareholders must be honoured (e.g., if a shareholder's voting shares exceed 10%, it must not have the figure of a company registered in an offshore zone). 1

The Payment Services Directive II in the European Union stipulates that banks must grant access to the customers' account information. Such access is carried out via application programming interfaces (APIs) to third parties. Although Russian banks are not currently obliged to do so, the Central Bank is already working on regulations for open APIs. At current, APIs are used in the creation of associated services. The development of open APIs is covered by the draft directives for the digitalisation of the financial market for the 2022-2024 period, which were published on December 10, 2021.2

Lending in Russia

Fintech in Russia

Fintech in other countries

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Russian Fintech Lawyers

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Roman Buzko

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Viacheslav Losev

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Fintech investors from Russia



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  1. https://thelawreviews.co.uk/title/the-financial-technology-law-review/russia
  2. https://cbr.ru/StaticHtml/File/59420/standart_1.pdf
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