A comparative analysis of approaches to digital currency regulation in developed and developing countries

The relevance of this study is driven by the avalanche-like growth of digital currency transactions within the global financial system, which is fundamentally altering theoretical concepts and practical approaches to regulating money markets and ensuring financial sovereignty. The rapid integration of digital assets into the economies of leading states by 2025 necessitates a comprehensive understanding of the divergent regulatory paths emerging worldwide, shaped by national priorities, economic models, and geopolitical interests. This dynamic creates significant risks, including the proliferation of fraudulent schemes and threats to financial stability, while simultaneously offering opportunities for enhancing financial inclusion and innovation. The literature review underscores that the adoption of cryptocurrencies is influenced by a complex set of factors, including economic stability, trust in traditional finance, and technological readiness. In contrast, the adoption of Central Bank Digital Currencies (CBDCs) is often driven by state-led initiatives aimed at monetary control and payment system efficiency. Scholars highlight the critical role of depersonalized trust, financial literacy, and generational effects in the acceptance of these assets. Notably, a counterintuitive relationship exists where high levels of human development do not always correlate with trust in CBDCs, as seen in cases like Nigeria, where concerns over privacy and institutional trust prevail. The academic discourse is increasingly focusing on the interplay between financial literacy, institutional trust, and the design of regulatory frameworks that can effectively balance innovation with risk mitigation. This work presents a comprehensive comparative analysis of the evolution of regulatory policies and practices concerning digital currencies-encompassing both cryptocurrencies and CBDCs-in key developed and developing countries. The study aims to identify underlying patterns and forecast their future development trajectories in the context of escalating geopolitical fragmentation and technological rivalry. The research methodology is based on a qualitative case study analysis of the United States, the European Union, the United Kingdom, Japan, Russia, China, El Salvador, and the UAE. The methodological foundation incorporates contemporary research by Russian and international scholars, legislative acts from the selected jurisdictions-such as MiCA, the GENIUS Act, and VARA-as well as data from statistical services and financial organizations including the BIS, IMF, and national central banks. The results of the analysis reveal the formation of several distinct regulatory strategies. Developed economies like the USA, the UAE, and Japan are pursuing proactive institutionalization, creating favorable legislative frameworks to attract investment and solidify their influence in the new industry. The US, following a political shift in 2024, has moved towards systematic integration of cryptocurrencies, exemplified by the GENIUS Act for stablecoins and the CLARITY Act for regulatory clarity, while explicitly rejecting a CBDC. The EU and the UK are constructing stringent regulatory systems with a strong emphasis on investor protection and transparency, as embodied by the comprehensive MiCA regulation and the UK's forthcoming FCA-led regime. In contrast, major developing economies like China and Russia are implementing restrictive models that suppress the payment function of private cryptocurrencies in favor of state-controlled digital currencies-the digital yuan and the digital ruble, respectively. These models prioritize financial control and geopolitical autonomy. The case of El Salvador demonstrates the challenges of mandatory adoption, leading to a pragmatic retreat to a voluntary model, while the UAE has successfully positioned itself as a global crypto hub through proactive and coordinated regulation. The conclusions of the study indicate that the period of doubt regarding the demand for cryptocurrencies is over; the industry has matured into a key component of financial markets. The success of any regulatory policy hinges on the state's ability to ensure a balance between legal certainty, stimulation of innovation, and the cultivation of public trust. A global trend is observed: a transition from fragmented control to comprehensive regulatory regimes. The future architecture of global finance will be significantly influenced by the competition between decentralized private stablecoins and centralized state-backed CBDCs. Key challenges ahead include navigating geopolitical competition over digital liquidity channels, addressing public concerns over privacy with CBDCs, and managing the growing influence of private corporations as quasi-sovereign issuers of stablecoins. Ultimately, countries that successfully combine transparent regulation, technological adaptation, and social trust are poised to become the leading centers of the digital asset ecosystem in the coming decades. The authors declare no conflicts of interests.

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