Full-cycle legal support for ecosystem companies, super apps, marketplaces, platform-based businesses, and digital platforms.

Amid the active development of digital ecosystems in Russia, stricter antitrust regulation, heightened requirements for personal data, cross-border settlements, and sanctions pressure, the sustainability of an ecosystem business depends not only on the technology platform but also on the legal integration of all services – from payment solutions and marketplaces to fintech embedding, logistics, and big data processing.

Our team supports ecosystems, super apps, multi-service holdings, marketplaces, and B2B2C platforms at every stage: from structuring the ecosystem model to ongoing compliance and regulatory disputes.

We provide professional legal assistance where standard legal solutions fail, and where errors in cross-service integration, data use, cross-border payments, or interaction with the FAS and the Central Bank of the Russian Federation lead to service shutdowns, multimillion-ruble fines, suspension of operations, and loss of user trust.

In current conditions, Russian digital ecosystems find themselves between a rock and a hard place: on the one hand, active growth and user demand; on the other, harsh antitrust, tax, and sector-specific regulation. What is needed is not formal opinions, but workable legal structures that allow the ecosystem to grow, attract users, process data, process payments, and not fear inspections.

When we are needed

• Legal uncertainty of the ecosystem model – how to connect different legal entities and services without violating antitrust and tax laws.
• Risks in handling personal data (Federal Law No. 152-FZ) – cross-border transfer, data localisation, consents, big data processing.
• Antitrust risks – abuse of dominant position, unfair competition, self-preferencing (promoting one’s own services).
• Payment infrastructure requirements – onboarding banks, compliance with Federal Law No. 115-FZ (AML/CFT), protection against account freezes.
• Sanctions risks – disconnection from international payment gateways, blocking of cloud services.
• Risks from using foreign software and clouds – import substitution, sanctions clauses, migration to Russian IT infrastructure.
• Regulatory requirements for marketplaces – aggregator offer terms, returns, cash register equipment, product labelling.
• Inconsistency of service policies – conflicts between user agreements, liability for harm caused through the ecosystem.

Our clients

• Digital ecosystems (B2C and B2B) – holdings with multiple services (fintech, e‑com, logistics, media, telecom).
• Super apps – a single app combining more than 10 services.
• Marketplaces – goods, services, B2B marketplaces.
• Platforms with embedded financial services (embedded finance, banking as a service).
• Service aggregators (taxi, delivery, cleaning, doctor appointments).
• Hardware-software complexes with ecosystem logic.
• Groups of companies sharing a common IT core, CRM and payment gateway.

Stages of support (full cycle)

1. Structuring the ecosystem

• Legal audit of your ecosystem
• Choosing the legal architecture (central holding / service legal entities / agency structures / division of liability)
• Drafting cross-service agreements (data transfer, settlements, revenue allocation)
• Registration with the Federal Tax Service / Central Bank registries (if the ecosystem includes fintech services: payments, digital financial assets, crowdfunding)

2. Regulatory compliance (FAS, Central Bank, Roskomnadzor, Ministry of Digital Development)

• Analysis of dominant position risks (for large ecosystems)
• Clearance of transactions with the FAS (when acquiring new services, control)
• Compliance with the Consumer Protection Law (marketplace offer terms)
• 152-FZ (personal data): localisation, notification to Roskomnadzor, processing consents, including for big data
• 149-FZ (online resources, hosting provider): if the ecosystem provides a platform for content sharing

3. Payment infrastructure and 115-FZ

• Choosing the payment service model (through a partner bank, own payment aggregator, non-bank credit institution)
• Implementing AML/CFT (internal control rules, KYC, suspicious transaction monitoring)
• Legal protection against transaction freezes and account blocks
• Registration as a payment system operator or non-payment information system (grey zones)

4. Data and IT infrastructure

• Sanctions compliance for foreign software and clouds used
• Developing an import substitution plan (migration to Russian clouds and software)
• Security policies and data transfer between services
• Compliance with 126-FZ (SORM) for telecom operators within the ecosystem

5. Commercial and user agreements

• Unifying offer terms and privacy policies across all ecosystem services
• Agreements on joint liability toward users (so that harm is not attributed to a single service)
• Contracts with counterparties (partners, suppliers, logistics providers, acquirers)

6. Ongoing maintenance (current compliance)

• Monitoring legislative changes concerning ecosystems, marketplaces, digital platforms (State Duma bills, clarifications from the FAS and Central Bank)
• Supporting inspections by the FAS, Roskomnadzor, Rospotrebnadzor, and the Prosecutor’s Office
• Antitrust compliance (internal rules prohibiting self‑preferencing, data exchange)
• Judicial protection in disputes with users, partners, regulators
• Updating policies and offer terms to meet new requirements (e.g., labelling, working with self‑employed individuals)

Our advantages

• Law + ecosystem logic + GR – we understand not only the rules of the FAS, 115‑FZ, 152‑FZ, but also the business architecture of ecosystems: cross‑selling, unified user profile, platform economics.
• GR support – representing the ecosystem’s interests during the drafting of regulations (including pilot regimes).
• Continuity‑focused – we preserve your ability to operate, attract users and partners even as regulations tighten.
• Confidentiality (attorney‑client privilege) and speed – ecosystem projects are often large‑scale and sensitive; we act quickly and discreetly.

Where we are especially effective

• Ecosystems with fintech services (payments, BNPL, digital assets, deposits, insurance)
• Goods and services marketplaces (e‑com, delivery, bookings)
• Super apps (single sign‑on, unified wallet, end‑to‑end analytics)
• Groups of companies with diverse OKVED codes (telecom + IT + finance + logistics + media)
• Digital platforms for B2B and public‑private partnerships
• Companies under close scrutiny of the FAS (large IT corporations)

What the client receives

• Legally impeccable ecosystem model – balanced allocation of risks and liabilities
• Reduced regulatory risks – protection against FAS fines (up to 15% of revenue for abuse of dominant position), service blocks
• Personal data protection – localisation, notifications, consents, readiness for Roskomnadzor inspections
• Payment infrastructure without freezes – both 115‑FZ compliance and alternative channels
• Anti‑sanctions resilience – replacement of foreign software, sanctions clauses, backup clouds
• Readiness for inspections by any regulator (FAS, Central Bank, Roskomnadzor, Prosecutor’s Office)
• Ability to scale the ecosystem (acquiring new services, entering new segments)