CRIMINAL LAW REGULATION OF CRIMES RELATED TO CRYPTO-ASSETS: FOREIGN EXPERIENCE AND PROSPECTS OF NATIONAL LEGISLATION

Abstract

The article examines foreign legal models for combating criminal acts related to crypto-assets from a comparative legal perspective. Based on the experience of the European Union, the USA, Singapore, South Korea, Russia, Kazakhstan, Belarus and Kyrgyzstan, the ratio of criminal-legal and administrative-legal tools in the regulation of the crypto-market, unlicensed activities, fraud, market manipulation, the use of insider information, the use of virtual assets for criminal purposes and procedural measures are analyzed. The study substantiates the need to harmonize foreign models with the principles of national criminal law instead of their mechanical transfer to the legal system of Uzbekistan. As a result, proposals have been developed to improve legislation on crypto-market manipulation, acts committed using artificial intelligence, and the procedural protection of virtual assets.