Proper Media Buying in 2025: New Legislation

At 3S.INFO about Proper Media Buying in 2025, we break down the changes, associated risks and recommended steps to comply with the new regulations.

Publication date: 30 Jul 2025

On July 5 and September 1, 2025, new laws will take effect in Russia, directly affecting traffic arbitrage, account sales, SIM-card transfer, and the use of bank cards for fraudulent purposes (“dropper activity”). At 3S.INFO, we break down the changes, associated risks and recommended steps to comply with the new regulations.

This content serves informational purposes only. We do not endorse violations of local laws or service policies. Please familiarize yourself with local regulations and comply accordingly! 

What Laws in 2025 Will Affect the Promotion of Gambling and Betting? 

What Penalties Apply for “Dropper activity”—Transferring Bank Cards and Accounts?  

Law No. 176-FZ of June 24, 2025: Criminal Liability for “Dropper Activity”. Now, transferring your bank card to others (including for compensation) incurs penalties: fines up to 300,000 RUB, compulsory labor or up to 2 years of restricted freedom.
If the card transfer was motivated by greed (e.g., for cashing out money or conducting fraudulent transactions), punishment escalates to up to 6 years imprisonment and a fine of up to 500,000 RUB.

Liability extends to organizers (“droppers”) who manage such schemes. They face up to 6 years imprisonment and a fine of up to ₽1 million.

  • The law went into effect on July 5, 2025. Shortly thereafter, Moscow saw its first criminal case related to “dropper activity”. A 52-year-old woman was arrested after she found “online work,” registered her own business, and opened a bank account. Her credentials were handed over to scammers, who transferred and withdrew roughly 1 million RUB using her account.  

Who Is Subject to the “Dropper” Law?

  1. Russian citizens are always liable, regardless of their location. If a Russian citizen participates in a drop scheme abroad, they can still be prosecuted if their identity and involvement are established.
  2. Foreigners are subject to prosecution if they commit illegal acts within Russia’s territory (e.g., reside in Russia and sell accounts) or utilize Russian infrastructure (cards from Russian banks, SIM cards from Russian operators, websites in the .ru domain, advertising targeting Russian users, etc.).

The law does not apply if:

  • Neither you nor your team are residents of Russia. You do not use Russian bank cards, SIM cards or accounts. You do not deal with Russian offers or users.  
  • All operations take place outside Russian jurisdiction and have no connection to it.

Even if you’re outside Russia, you could face charges if:

  • You purchase accounts from Russian citizens.
  • You use someone else’s Russian bank cards or SIM cards. 
  • You make payments in rubles through Russian banks.

You may be implicated if any involved party is apprehended and provides testimony.

Who?  Subject to the Law? Clarifications
Russian Citizen  Yes Always, Regardless of Location
Foreign Citizen in Russia Yes Actions in Russia or Through Russia
Foreign Citizen Outside Russia, Unconnected to Russia No No Use of Russian Infrastructure

New Rule in “Personal Data”: Prohibition on Account Transfer

Account transfer is also prohibited. Effective September 1, 2025, a new amendment to Federal Law No. 152 “On Personal Data” will prohibit the sale of gaming accounts, character transfers, boosting and any transfer of account registration data (including advertising accounts).

Fines: individuals 30,000–50,000 RUB; sole proprietors up to 100,000 RUB; companies up to 200,000 RUB; severe cases up to 700,000 RUB, forced labor, or imprisonment up to 3 years.

What Is Allowed?  

  • Sale of Accounts: If they don’t breach platform terms and aren’t used for financial or fraudulent purposes. 
  • Temporary Access Transfer: Through power-of-attorney or explicit user consent (e.g., corporate advertising accounts).
  • Accounts created and registered under a real legal entity or individual entrepreneur: As long as usage is transparent.Warning! Even if you didn’t personally benefit, participation in such schemes becomes criminally punishable.

What About SIM Cards?

Although SIM cards are not directly addressed in the laws, here’s what matters:

  • Mass purchasing, registering under fake identities, and selling to third parties constitutes indirect facilitation of “drop” schemes.
  • If SIM cards are used to verify accounts subsequently employed for money laundering, farming, or circumventing blocks, this can lead to potential criminal liability.

Impact of the Ban on “Dropper Activity” and Account Transfers on Media Buying 

Legislators clearly stated the intent: to combat “drop” schemes and the shadow economy surrounding account trading. While media buying remains in a grey area, even a single involvement in such schemes can now lead to criminal prosecution.

  • Minimal Risk: If you’re not a Russian citizen and work with foreign traffic sources, cards and SIM cards.
  • Higher Risk: If you engage with drops, Russian banks, or Russian numbers — you fall into a risk zone, even when working abroad.
What Is Now Risky  What Must Be Avoided 
  • Purchase of accounts verified under a “dropper” 
  • Using someone else’s SIM cards or bank cards  
  • Farming volume using third-party passports, cards, and numbers
  • Selling or renting advertising accounts without confirmed verification
  • Purchasing SIM cards from gray market sellers on telegram  
  • Linking accounts to numbers without proper control  
  • Ignoring whose names finances and logins are registered under

How to Adapt to New Laws in 2025 as a Media Buyer 

1.Legalize Your Operations:

  • Register bank cards and SIM cards under your name or a legal entity (sole proprietorship, LLC).  
  • Use corporate numbers from major carriers (MTS, Megafon, Tele2 — unlimited activation possible).  
  • Attach accounts only to verifiable data.  
  • Work through contracts: rentals, subcontracting, verified access.

2. Choose Safe Services: 

  • Employ eSIM and official VoIP services (Tinkoff, Zadarma, Sipuni).  
  • Automate through legal APIs, avoiding shady farm panels.

3. Prepare for Audits: 

  • Save receipts and contracts for SIM cards, accounts, and bank cards.  
  • Have documentation proving you’re a digital specialist, not a money launderer.

Checklist: How to Correctly Promote Gambling and Betting in Compliance with New Laws in 2025

1 of 7
  • 1. Bank Cards
    • All cards used in media buying should be registered under your name or legal entity.  
    • Do not lend or rent cards to third parties for money.  
    • Do not use cards belonging to “droppers,” even with a “proxy agreement.”  
    • Have agreements with those who pay for advertising from your accounts.
    Read more
  • 2. SIM Cards
    • Buy SIM cards directly from official carriers (MTS, Tele2, Megafon, Beeline, etc.).  
    • Use SIM cards registered under a legal entity (sole proprietorship or LLC).  
    • Keep receipts and contracts for SIM card purchases.  
    • Do not purchase disposable numbers from anonymous sellers on Telegram or bots.
    Read more
  • 3. Accounts and Logins
    • Do not purchase accounts registered under other people’s names.  
    • Never share login/passwords with third parties, even at the start.  
    • Use whitelisted farming methods, verified under your own or employee’s passport.  
    • Obtain user consent or contract if the account belongs to someone else.
    Read more
  • 4. Working with a Team
    • Everyone knows whose name should be behind each asset.  
    • Each member using SIMs, accounts, or cards should have an internal agreement or rental contract.  
    • Be able to explain the arrangement quickly: who, why, and how each tool is utilized.
    Read more
  • 5. Legal Arrangement
    • Establish a sole proprietorship or LLC to legally register accounts, SIM cards and payments.  
    • Track logins, payments and accounts.  
    • Able to confirm income sources and legal compliance of traffic.
    Read more
  • 6. What Not to Do
    • Do not purchase cards, SIMs, or accounts “on behalf of a dropper.”
    • Do not rent accounts without contracts. 
    • Do not run ads from third-party accounts using TeamViewer or AnyDesk.
    • Do not use unofficial VoIP services without documentation.
    Read more
  • 7. Safety Measures
    • Screenshots, contracts and receipts stored in case of questions from banks, tax authorities, or law enforcement.
    • All accounts and cabinets labeled and organized properly.
    • Have an exit strategy from grey schemes in case authorities arrive.
    Read more

Two significant amendments will come into force in 2025: on July 5 and September 1. These regulations affect media buying, SIM card exchange, account sales and transactions via “drop cards”. We’ve explained the changes, highlighted new threats and outlined steps for adaptation. Act cautiously and in compliance with the law! 

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