The Bank of Russia has proposed a 1% crypto capital cap, limiting covered crypto and foreign-digital-instrument risk to a bank’s own funds while leaving some client custody positions outside the new calculation.

The Sept. 18 proposal would create N31 for individual credit institutions and N32 for banking groups on a consolidated basis. Each ratio compares covered exposure with the relevant institution’s capital, not its total assets. The rules remain in draft form.

The two-level structure subjects both a bank and its wider group to the same proposed percentage ceiling. N31 uses the individual institution’s own funds, while N32 uses consolidated group capital, keeping the measurement tied to the entity that carries the covered risk.