The Bank of Russia's September 18 proposal would limit covered crypto and foreign-digital-instrument risk to 1% of a bank's own funds, while conditionally excluding client custody positions from this calculation. The draft rules create N31 and N32 ratios for individual institutions and banking groups, respectively, comparing covered exposure to capital. Client custody positions are excluded if the bank does not bear liability for loss in case of seizure or transaction restrictions, though these positions still receive a 50% risk weight for capital adequacy. Direct holdings and liable client positions receive a 1,250% risk weight. The central bank plans official publication in Q4 2026, with requirements taking effect 10 days later and reporting expected from January 2027.