Comparative Legal Analysis of Central Bank Digital Currency Regime

Global digitalization around the world and the active use, including for criminal purposes, of unregulated cryptocurrencies, led to the creation of the central bank digital currency (CBDC). Since 2017, the Bank of Russia has been engaged in research in this area, by August 2023, legislative norms regulating the digital ruble were adopted and a pilot regime was launched, at the end of which, presumably from January 2025, a new form of the ruble will be introduced into mass use. At the same time, with the advent of the central bank's digital currency, questions arose about determining the legal nature and distinguishing the digital ruble from non-cash and electronic money, stablecoins and digital currency. In order to address these issues, a comprehensive comparative legal analysis of each of the above entities was conducted within the framework of Russian legislation, as well as an analysis of approaches to regulating the digital currency of the central bank in Nigeria, China and Hong Kong. In carrying out this research, such general scientific methods as analysis, deduction, and special methods of legal research were used: formal legal and comparative legal. As a result of the research, the author demonstrated, among other things: the prerequisites for the emergence of a new form of money; definitions of the central bank's digital currency presented by international organizations and various countries; the legal nature of the digital ruble and the regulation of the digital ruble platform; a comparative legal table of differences and similarities between the digital ruble and non-cash and electronic money; a comparative analysis of approaches to the development of the central bank's digital currency in Russia, Nigeria, China and Hong Kong.