Аннотация
This article examines why Kazakhstan, Kyrgyzstan, and China - each inheriting the Soviet model of punishment - have diverged in their prison reforms. It asks why Kazakhstan and Kyrgyzstan have moved toward more reintegration-oriented approaches, while China remains centralized and punitive. A comparative case study evaluates four factors: foreign donor involvement, alignment with international norms, openness to NGOs, and the persistence of state ideology. Measured through treaty ratifications, donor projects, NGO access, and policy analysis, the findings show that Kazakhstan and Kyrgyzstan’s external engagement and reduced ideological control have supported gradual reform. In contrast, China’s strong ideological framework and minimal external influence sustain its punitive system. Using the concept of compliance performance the study explains these differences and contributes to understanding how structural and ideological conditions shape penal change in the Global East.