Monetary-claim DFAs: whose debt you are buying and where it is recorded

A monetary-claim digital financial asset (DFA) is a digital right under which the issuer must pay you money, and the record of that right exists only inside the information system of an operator listed in the Bank of Russia register. In legal terms, you are buying a claim against a specific party, evidenced by an entry in a private operator's register, not a security. Almost every practical difference follows from this: how the asset is issued, how you can sell it before maturity, how much is disclosed, and what happens if the issuer fails to pay.

What exactly such a DFA documents

The definition is set out in Article 1 of Federal Law No. 259-FZ of 31 July 2020. Digital financial assets are digital rights that include monetary claims, the ability to exercise rights under issue-grade securities, rights to participate in the capital of a non-public joint-stock company, and the right to demand the transfer of issue-grade securities. Such rights can be issued, recorded and circulated only by making and changing entries in an information system, whether it is based on a distributed ledger or on some other technology.

The monetary-claim type is the simplest in structure and the most common on the Russian market. The substance of the obligation is set by the issuance decision (Article 3 of the law): who the issuer is, what amount it pays and by when, what the size of the payment depends on, whether there is collateral, and under what conditions early redemption is possible. Here the issuance decision plays a role similar to the offering documents for debt, but it is far less standardised: the terms of two issues by the same operator can differ fundamentally, so what you need to read is the issue document itself, not the description in the platform's storefront.

The payment does not have to be fixed. A monetary claim can be linked to anything measurable: an interest rate, a commodity price, a project's revenue, an exchange rate. This is convenient for the issuer, and for the investor it means that return and risk are defined by a formula rather than by a coupon.

Why this is not a bond

A bond is an issue-grade security: its issue goes through a registration procedure, it is held in custody by a depository, it can trade on an organised market, and it has an exchange order book and a market price. See what this looks like in the bonds section, and especially in the OFZ segment: there you have continuous quotes, comparable maturities and a yield curve.

A monetary-claim DFA has none of this. The information system operator (Article 4 of the law) keeps the records and admits issues, while the DFA exchange operator (Article 5) arranges trades. Secondary trading is possible, but it takes place within an infrastructure that is not connected to exchange price discovery, and moving assets between different information systems is restricted both technically and legally. The practical conclusion: assume you will hold the instrument to maturity, and treat the ability to exit earlier as an option, not a built-in feature.

The second difference is the scope of disclosure. A public issuer is required to publish financial statements, which are easy to cross-check in the reports section. A DFA issuer discloses what the law and the issuance decision require; for a small company with no public debt there may be little verifiable data, and there may be no credit rating at all.

Access for non-qualified investors

The law limits how much in DFAs non-qualified investors may buy: the maximum amount per calendar year is set by a Bank of Russia regulation, and certain categories of issues are available only to qualified investors. The specific limit is not tagged in the platform's database, so check it in the current version of the regulator's act and in the rules of the information system; the operator is obliged to enforce the limit when accepting an order.

Not to be confused with a margin requirement

The similar wording is misleading: a "monetary claim" and a margin requirement belong to opposite sides of a transaction. A monetary claim is your asset, the right to receive money from the issuer. A margin requirement is your obligation to the broker to post collateral for a leveraged position. The mechanism is explained in the glossary, and the other definitions are in the main glossary section.

Taxes and accounting

Income from DFAs is subject to personal income tax, and withholding is, as a rule, the responsibility of the information system operator or the exchange operator acting as tax agent. The procedure for determining the tax base for investment income is 13%. An important practical detail: the individual investment account regime and the tax breaks tied to holding securities do not, as a general rule, apply to DFAs, because a DFA is not a security. The rules in this area keep changing, and the current version on this point is not tagged in the platform's database, so check the status as of the transaction date.

What to check before buying

A sensible sequence looks like this. Step 1: find the operator in the Bank of Russia register and make sure the issue is being placed in that operator's system. Step 2: read the issuance decision: the maturity, the payment formula, the collateral and the early-redemption terms. Step 3: assess the issuer's credit quality from the available financial statements and compare the promised yield with what public debt of comparable maturity offers; if the premium is small, you are taking on additional infrastructure and illiquidity risk without being paid for it. Step 4: work out in advance how, and through whom, you could sell the asset early. Follow regulatory news on this market in the news section.