Comparative Legal Analysis of Models of Financial Legal Regulation of Cryptocurrencies and Tokens

The purpose of the research. Despite the short existence of the financial technology market, the world has already developed certain approaches to the legal regulation of this industry, determined by the financial policies of specific states. The study of these approaches aims to identify significant gaps in the domestic financial legislation that hinder the development of the Russian fintech industry. Results. The study of foreign experience in the financial legal regulation of tokens and cryptocurrencies on the example of countries that legalized their circulation (USA, Republic of Belarus), as well as countries adhering to a prohibitive approach (PRC), made it possible to formulate a list of gaps in Russian legislation that hinder the development of the financial technology industry in our country. Among these gaps, it is worth highlighting the lack of a fixed list of permitted operations with cryptocurrency and a legal basis for the emission of national digital currency, the inadaptability of tax legislation to taxation of income from transactions with cryptocurrencies and tokens and to economic incentives for participants in the financial technology market.

ICO, FinTech, financial technology, financial law, digital currencies, cryptocurrencies, tokens, ICO, FinTech