Falsifying the register of companies under the criminal law of Russia, UK, and USA: A comparative study

The article examines the current criminal law prohibitions on falsification of registers of legal entities adopted in the Russian Federation, the United Kingdom, and the United States (at the federal and state levels). The topic of the article seems to be relevant, since such a study allows carrying out a wider - through contrast and comparison of existing regulations - study of the advantages and disadvantages of domestic experience in legal regulation and, if necessary, putting forward proposals for borrowing foreign countries' experience. The degree of scientific elaboration of the topic is low; Russian lawyers have not previously conducted similar studies. At the same time, crimes in the sphere of economic activity under Anglo-American law were studied earlier by N.E. Krylova, N.N. Polyansky, E.V. Chuprova, and other domestic researchers. Thus, the novelty of the article consists in the fact that it is the first Russian-language comparative legal study of the criminal falsification of the register of legal entities under the law of the Russian Federation, the United Kingdom, and the United States. The author of the article compares the norms of criminal law of the Russian Federation, the United Kingdom, and the United States, particularly focusing on the criminal law regulation of the falsification of the register of companies under the law of different states. The basis of the methodology is a combination of general scientific and specific legal research methods. The general scientific methods are: analysis, analogy, induction, interpretation, and others. The main specific legal methods are: the comparative legal method and the formal legal method. At the beginning of the article, the author gives introductory provisions on the role of criminal law in the protection of public relations in the field of economic activity and indicates the problem of the lack of scientific development of the topic. In the main part, the author analyses the criminal law prohibitions in force in the Russian Federation, the United Kingdom, and at the federal level and at the level of individual states in the USA. In the final part of the article, the author presents the main conclusions of the study. The article has theoretical and practical significance. Thus, the conclusions of the article enrich the scope of theoretical knowledge about the criminal law of the United Kingdom and the United States on the analysed criminal law prohibitions. With regard to the practical plane, the conclusions of the article can become the basis for future changes in Russian legislation.

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