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Analysis reveals the legal status of the Bank of Russia in relation to the digital ruble, suggesting possible conflicts in its dual role as regulator and market participant.
The purpose of the research. This article examines the public law status of the Bank of Russia in the context of developing and introducing a central bank digital currency (CBDC)—the digital ruble—in Russia. It analyzes whether the Bank’s new role as operator of the digital ruble platform aligns with its statutory objectives. The study aims to identify key features of the Bank’s legal status as a unique entity within the system of state authorities and to assess changes resulting from its expanded operational responsibilities. Results.The research reveals the hybrid nature of the Bank of Russia, combining attributes of both a state body and a special legal entity. It highlights potential conflicts of interest arising from the Bank acting simultaneously as regulator and market participant in the CBDC ecosystem. Key legal challenges in regulating the issuance and circulation of the digital ruble are identified, along with proposals for their resolution. Particular attention is given to the need to define the digital ruble as legal tender, ensure data privacy protections, and address provisions allowing the Bank of Russia to unilaterally amend digital ruble account terms.
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Artem А. Nedrov (2025) studied this question.
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