Boitsov's asset-access matrix gives an onshore desk a useful eligibility check. It gives no basis for choosing among the substitutes it names. The English abstract says the framework may be applied to portfolio construction, and the conclusion presents it as a basis for future portfolio-optimization models. Yet the goal statement and conclusion also say the matrix makes it possible to optimize portfolio structure. No substitute instrument is measured for return, spread or tracking error.
What can each investor buy?
Since 2022, Bank of Russia rules and Moscow Exchange infrastructure have narrowed the set of exposures available to retail investors. Boitsov records the remaining choices in two tables, one for non-qualified investors and one for qualified investors. Both cover the same 10 asset classes: Russian shares, Russian bonds, quasi-currency bonds (ruble-settled, foreign-currency-linked), CNY-linked bonds, foreign securities, USD/EUR spot, CNY spot, money market, derivatives and gold.
Each row gives an access grade on a four-step scale: available, available with restrictions, restricted or unavailable. It also identifies a restriction type, regulatory, market, exogenous or infrastructural, and names a substitute asset. Boitsov reads central-bank directives and exchange notices to make those assignments. There is no model.
The paper then compares the tables with Bank of Russia data on the aggregate portfolio of retail brokerage clients. Its only endpoints are Q1 2022 and Q1 2026. Over that span, non-resident shares, depositary receipts and fund units fell from 20% to 11% of the aggregate portfolio; foreign-issuer bonds fell from 13% to 2%; and resident fund units rose from 3% to 19%.
Which walls can a test remove?
The restriction types draw the line a desk needs. A row can carry more than one of the four tags: Russian shares for non-qualified investors carry both regulatory and market tags. Regulatory barriers can be cleared through status or testing. Mandatory testing of non-qualified investors has covered the main instrument groups since 01.10.2021, gating bonds rated below AA-, structured bonds, non-listed shares, repo and any derivative. Directive No. 6885-U, dated 01.10.2024 and effective 01.01.2025, places foreign-issuer securities and certain derivatives on them behind qualified status, apart from exceptions for EAEU infrastructure and international financial organizations. Subordinated and perpetual quasi-currency bonds are qualified-only as well.
The exogenous and infrastructural tags describe barriers that remain for both tiers. Exchange trading in blocked foreign securities was restricted from 30.05.2022; from 01.04.2023, brokers could no longer execute client exchange orders in them. Funds on foreign assets were temporarily suspended from 27.02.2023. After SDN sanctions, USD and EUR exchange trading stopped on 13.06.2024, and both tables grade USD/EUR spot unavailable. Foreign securities sit one grade below fully available for qualified investors: there is no formal ban, though direct purchase is blocked in practice.
Qualified status therefore eases the regulatory barrier while leaving the infrastructure barrier in place, as the paper itself says. For a desk, that distinction is the matrix's useful result.
The table labels need care. The text introduces Table 1 as the qualified-investor matrix, but its caption says non-qualified. The caption fits the entries: Table 2 is the looser matrix.
Substitutes without measurements
The substitute column carries more weight than the paper can support. For USD/EUR spot, it lists quasi-currency bonds and cash currency, with derivatives added for qualified investors. A quasi-currency bond pays dollar-linked coupons in rubles at an official rate. Boitsov notes that the Bank of Russia changed the way that rate is set after 13.06.2024. The holder takes Russian issuer credit and a central-bank fixing along with the currency link, a different position from a dollar balance. Replacement bonds bundle exposures in the same way: the paper describes blocked foreign bonds swapped into local instruments with ruble settlement.
Both tiers are offered derivatives as substitutes for foreign securities. Table 1 marks them open to a non-qualified investor who passes the test, while the paper also says 6885-U reserves certain derivatives on foreign underlyings for qualified investors. We did not find where it identifies the contracts still available to a tested non-qualified investor.
Four categorical grades and the name of a proxy cannot establish the paper's optimization claim. An optimizer needs the covariance between that proxy and the exposure it replaces. The paper supplies none.
Portfolio shares, four years apart
The moves from 20% to 11% and from 13% to 2% describe weights, not sales. A frozen holding can lose portfolio share as other holdings grow. The paper gives no totals to distinguish that case from trading, and Boitsov attributes the non-zero remainder to assets blocked since 24 February 2022.
Blocking also complicates the paper's account of reallocation. Boitsov calls the decline a consequence of direct sanction restrictions and part of a broader localization of investment capital; the abstract calls it a structural reallocation. He does not size either contribution or split valuation from flows. Other links are explicitly tentative. He introduces the connection between replacement bonds and the rise in other resident bonds as a supposition, and attributes the link between liquidity ETFs and the rise in fund units to his opinion.
Boitsov also points to money-market funds exceeding 50% of total mutual fund NAV and credits their growth to a high key rate. His introduction names monetary easing and falling deposit yields as reasons investors moved into markets. Those accounts could apply at different dates, but the paper does not reconcile them.
We could not backtest the substitutes. We have neither local price history for these instruments nor a dated record of which tier could buy each class on each day. A real test would need point-in-time eligibility by tier across the six dated rule changes from 2021 to 2025, together with local daily prices for the substitutes. I would start with tracking error between a quasi-currency bond basket and the official USD rate since 13.06.2024. A small result net of spreads would make the substitute column much more persuasive.