Abstract
The purpose of this study was to conduct a comparative legal analysis of the legislative models governing the gambling industry in the Republic of Kazakhstan and Singapore and to identify the key differences in regulatory approaches, principles, and control mechanisms. The methodology includes comparative legal, systemic, and formal legal analysis of the core legislative acts of the countries under study. The research examines the objectives of legal regulation, the powers of authorized regulatory bodies, and state control mechanisms in the gambling sector. The legislation of the Republic of Kazakhstan is based on a model of territorial restrictions and detailed regulation of permitted gambling activities, while prohibiting online casinos and the operation of foreign operators without a license. In contrast, the Singaporean regulatory model is focused on establishing a single regulatory authority with broad supervisory powers and a clear mandate to minimize the social harm associated with gambling. Particular attention is paid to licensing procedures, gambling addiction prevention measures, and restrictions on access to gambling activities for certain categories of individuals. The study reveals significant differences in regulatory principles: Kazakhstan primarily relies on the principle of territorial limitation of gambling activities, whereas Singapore follows the principle of responsible gambling under the strict supervision of a unified regulator. The Singaporean model is characterized by a more comprehensive approach to balancing the state's economic interests with the protection of public interests. The scientific novelty of the study lies in identifying the fundamental differences between the gambling regulatory models implemented in Kazakhstan and Singapore.