The article is devoted to the development of a concept for the legal regulation of the organization of digital currency circulation in the Russian Federation. The author analyzes doctrinal approaches to determining the status of infrastructure intermediaries, identifies the shortcomings of the model proposed by the Bank of Russia, and substantiates the advantages of an alternative system based on establishing regulation of specialized entities — exchange operators and digital currency storage operators. The article reveals the requirements for licensing, capital of these entities, describes security mechanisms, and investor protection measures, as well as measures to comply with anti-money laundering standards. It is concluded that the proposed model will allow bringing the market out of the shadow sector and forming an effective mechanism for controlling the circulation of digital assets.