Today, a crypto economy is actively developing throughout the globe based on the use of cryptographic technologiesfor the creation of new digital products, including the issuance of digital financial instruments. The topic of regulationof digital financial assets (DFA) is relevant in the world: since 2019, some countries, including Russia, began tointroduce legal norms regarding the issuance of DFA, as well as the sale and turnover of such assets on the market.This article compares approaches to the regulation of DFA in Russia and globally, including the issue of determiningfinancial instruments that will be related to these assets, aspects of the procedure for issuing, storing, and tradingthem, including the basic rights and obligations of issuers and investors in such assets, and the features of the operationof trading floors and platforms for issuing DFA.In general, two approaches to the regulation of DFA can be distinguished. The first approach is the applicationof existing rules to tokenized assets (for example, laws on securities and financial instruments); this approach is usedin the United States. The second is regulation through the introduction of a new framework for the application ofdistributed ledger technology in financial services, for example, in Russia, Germany, Luxembourg, the EuropeanUnion (EU), and Switzerland. This article examines the second approach, which is currently implemented in Russia,to identify differences with foreign regulation, for example, the use of custodian institutions for accounting and storingdigital assets, converting DFA into traditional financial assets, and creating rules for trading digital financial assets.

The article was prepared as part of the research work of the state task of the RANEPA