On October 29, 2026, multiple media outlets placed two originally unrelated regulatory news stories on the same page: one from Moscow, where the National Association of Securities Market Participants of Russia (NAUFOR) completed and submitted a draft standard for testing crypto investors to the Central Bank of Russia's Basic Standards Committee. This establishes a unified threshold for brokerages and dealers to 'examine' clients before they enter the market; the other occurred in Beijing, Haidian, where the Market Supervision Administration made a penalty decision of approximately 930,000 yuan against a technology company that assisted in pyramid schemes using blockchain and related technologies. The former seeks to shift risks upfront through suitability testing and attempts to include them in a regulatory framework, while the latter uses penalties and the designation of 'first case' to send a high-pressure signal. These two distinctly different methods reported on the same day outline the current global reality of crypto regulation, building compliance pathways while simultaneously intensifying illegal crackdowns.
Russia Incorporates Crypto into Compliance Track Through Testing
If the penalty in Beijing is a case of post-fact accountability, then Moscow is attempting to write risks into the test paper upfront. Last week, NAUFOR completed a draft testing standard for crypto investors and submitted it to the Central Bank of Russia's Basic Standards Committee, meaning this new system has progressed from industry self-regulation to the standard approval process at the central bank level. NAUFOR, as a major self-regulatory organization in the local securities industry, has been responsible for the fundamental rules and suitability norms of traditional securities business; now it opts to pull crypto assets into the same compliance track with a specialized test.
At this year's Crypto Summit 2026, NAUFOR's First Vice President Ekaterina Andreeva systematically introduced the framework of this draft for the first time: brokerages and dealers will initially gain the authority to test clients, becoming the frontline gatekeepers for investor suitability assessments. More crucially, the test results will be universally applicable across all regulated platforms, with a design of "one test, mutual recognition across the market," attempting to unify the previously fragmented suitability assessment criteria, allowing regulators and platforms to judge whether investors can enter crypto trading scenarios based on the same answer sheet. Specific questions, scoring standards, and passing thresholds have yet to be made public, but this system is positioned as an attempt to provide upfront protection to investors before crypto asset trading occurs—first check your understanding, then decide whether to let you in. According to a single source A, the testing work is expected to be officially launched by brokerages and dealers by the end of November 2026 at the earliest, and the timeline still depends on the approval progress of the Central Bank's Basic Standards Committee and subsequent regulatory arrangements. However, it can be confirmed that Russia has chosen to build a path to compliance for crypto businesses through this test.
Brokerages as Gatekeepers: One Test, Universal Access
Under this design, brokerages and dealers are no longer just transaction facilitators but the security at the entrance to the crypto asset world. Investors must first pass suitability tests arranged by brokerages when opening accounts or consulting about crypto products; their knowledge base, risk understanding, and investment experience will all be systematically "scanned" to determine whether and to what extent they can participate in subsequent crypto asset trading. Moving the assessment upstream to the very front means that the judgment of "whether fit or not" no longer occurs after product recommendations but before investors step into the market.
According to a single source A, this testing work is expected to be formally launched by brokerages and dealers by the end of November 2026 at the earliest, with the timing still tied to the approval rhythm of the Central Bank's Basic Standards Committee, and the draft itself has not yet been finalized; its specific scope of application remains undisclosed. Even so, the framework of "one test, mutual recognition across the market" has already been outlined: as long as investors complete and pass the test with one regulated brokerage, their score can be valid across other compliant platforms, eliminating the need to retake the test for every single account opening or attempt. This experience reduces friction and cost, but it forms a new unified benchmark for entry—who can enter the compliant crypto asset market no longer depends on the preferences of each platform but on this entrance examination executed by brokers and endorsed by regulators.
Beijing's First Case: Blockchain Outsourcing Companies Cannot Escape Liability
If Russia is setting a unified entrance exam for future investors, what has been exposed in Beijing is a "consequence" that has already materialized: the Haidian District Market Supervision Administration announced the completion of investigations into the first case in the city utilizing blockchain and related "coin" technology to assist pyramid schemes. The case involved a technology company providing outsourcing services for a certain public blockchain; it did not directly issue tokens but undertook all technical and promotional support directed towards users, from operations and market services to publicity and daily maintenance. Regulatory investigations found that the "Atomic Plan" and "Hathaway Plan" designed under this public blockchain centered on recruiting participants with promised returns, requiring them to invest funds upfront to qualify, subsequently calculating returns based on the number of new recruits. This model clearly exceeds simple technical support boundaries and constitutes assistance for pyramid schemes. Notably, the announcement deliberately withheld the names of the technology company, the public blockchain, participant numbers, and the scale of the case, leaving the public only with the model and responsibility boundaries.
The technology company was ultimately penalized with a total of approximately 930,000 yuan, including fines and confiscation of illegal gains, although the specific amounts for each part were not disclosed. While the figures are not astonishing, they serve as a clear regulatory signal: even as merely an "outsourcing service provider," if it substantively supports a model that relies on recruiting for returns through operations, promotions, and matchmaking, it can no longer claim to be a "tool provider" or "technically neutral." The characterization of Beijing's first case pulls technology service providers from behind the scenes to the forefront, conveying a clear judgment—that technology companies involved in shaping, maintaining, or promoting illegal business models must also bear legal responsibility for their roles.
The Pseudo-Chain Circle of Recruiting for Returns: Technically Neutral Uses are not Neutral
In the operational narrative of the public blockchain involved in this case, the "Atomic Plan" and "Hathaway Plan" were packaged as high-tech, high-yield on-chain projects, but the underlying logic is simple to the point of being crude: participants must invest a sum of money to gain entry qualifications, then continuously recruit new members into the system, with returns directly linked to the scale of their downline. Regulatory authorities pointed out that this model, centered on recruiting for returns and based on the number of persons developed as the basis for returns, meets the typical characteristics of traditional pyramid schemes; the so-called "plans" are merely a renaming of old tricks.
Blockchain and token technologies do not create new business scenarios but are utilized to provide trading channels, promotional gimmicks, and integration services with exchanges, making recruiting for returns appear more "modern" and "intelligent." Public blockchain outsourcing service providers are responsible for operations, marketing, promotions, and even technical maintenance, bringing a pyramid scheme’s incentive structure onto the blockchain and turning it into a transferrable "project," which is why it is recognized as substantial assistance to an illegal model. Beijing's regulatory stance is very clear: the technology itself can be neutral, but once technology service providers participate in designing, maintaining, or promoting business models centered on recruiting individuals, they are no longer merely tool providers but must accept legal scrutiny for their applications; this delineation is a hard constraint that all industry participants cannot circumvent.
Two Regulatory Actions on the Same Day: Upfront Thresholds and Backend Crackdowns
On October 29, the news pages seemed to both Russia and Beijing extending regulatory hands in different directions simultaneously. On one side is the draft standard for testing crypto investors completed by the National Association of Securities Market Participants in Russia last week, which has been sent to the Central Bank’s Basic Standards Committee for approval, allowing regulated brokerages and dealers to conduct suitability assessments on clients before transactions, with test results recognized across various compliant platforms, expected to enter the implementation phase by the end of November; on the other is the Haidian District Market Supervision Administration's penalty decision against the first case utilizing blockchain technology and crypto asset concepts to assist pyramid schemes, identifying a public blockchain outsourcing service provider responsible for operating and promoting the "Atomic Plan" and "Hathaway Plan" as complicit in pyramid schemes, imposing a penalty of about 930,000 yuan. These two events are entirely unrelated in subject and motivation, with no public policy collaboration, yet they were reported on the same day, piecing together a distinctly different yet interrelated regulatory picture.
If Russia is trying to incorporate crypto investments into the existing compliance framework by using technically neutral suitability tests to filter out investors lacking risk tolerance, thereby allowing them to pass through a "rational threshold" before entering high-volatility assets, then Beijing is cleaning up chronic extreme chaos already in operation, revealing backend crackdowns on those masked with blockchain rhetoric and promising high returns through investment and recruitment. The former emphasizes pre-investment controls, while the latter focuses on post-investment sanctions; in a long-standing market environment filled with various "high-yield on-chain projects," these seemingly independent methods collectively achieve the same goal: constructing a complete protection net for investors that includes both entry screening and violation elimination—this net’s outline is gradually being sketched out in the regulatory practices of different jurisdictions.
Compliance Turning Points Have Emerged: The Survival Boundaries of Project Parties and Technical Services
The two regulatory clues emerging on the same day actually outline the same survival boundary. The draft standard for testing crypto investors in Russia is still at the approval stage of the Central Bank's Basic Standards Committee, and the testing work is only projected to be initiated by brokerages and dealers by the end of November; however, it has already pre-positioned "suitability assessments" at the entrance, allowing licensed institutions to conduct the first level of screening based on investors’ risk tolerance and understanding. Meanwhile, Beijing’s first case utilizing blockchain and cryptocurrency technologies to assist pyramid schemes has clearly informed the market with approximately 930,000 yuan in penalties and the designation of "assisting pyramid schemes": outsourcing technology companies providing operations, market services, promotions, and exchange integration maintenance for public blockchains can no longer present themselves as merely "pure technical services." When they fall into models based on recruiting for returns and gaining membership through financial contributions, they will be seen as part of the illegal chain. Looking back on October 29, 2026, the actions of the two countries, while unrelated in substance, convey a clear signal narrative: more jurisdictions in the future are likely to combine investor suitability testing with stringent crackdowns on illegal financing and pyramid schemes, establishing thresholds at the front end while imposing heavy penalties at the backend, reshaping the responsibility landscape for project parties, brokerages, and technology service providers within the regulatory framework. The space to continue operating outside this landscape is rapidly shrinking, making compliance no longer a optional choice but a lifeline for all participants to remain in this industry.
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