Аннотация
The aim of this article is to identify current challenges and gaps in the legislation of the Republic of Kazakhstan regarding the regulation of digital assets, and to outline directions for improving the legal framework in light of international experience. The study focuses on a comparative legal analysis of regulatory models in the European Union, the United States, and Singapore, allowing for the identification of the strengths of foreign approaches and the potential for their adaptation to the Kazakhstani legal system. The research revealed that the legal status of certain types of digital assets (in particular, NFTs and utility tokens) remains undefined. Additionally, there is no proper taxation regime, nor effective oversight of custodians and legal intermediaries. Contradictions between the norms of the Astana International Financial Centre (AIFC) and national legislation have also been noted, creating challenges for businesses and investors. As a positive example, the article highlights a ruling by the Economic Court of Almaty recognizing cryptocurrency as an object of civil rights. The author concludes that the current legislation requires improvements in the following areas: formal classification of digital assets, licensing of crypto market participants, and development of a dedicated tax regime. It is proposed that the practices of the EU and Singapore be used as models for building a systematic regulatory approach. Keywords: digital assets, cryptocurrency, tokens, legal regulation, legal regime, AIFC, legislation, legal uncertainty.