Criminal Liability for Fraud in Anglo-Saxon States (Using the Examples of UK, USA, Canada, Australia, and New Zealand)

The article presents the results of a comparative legal study of protection of public relations from various forms of fraudulent crimes under the criminal law in five states belonging to Anglo-Saxon legal tradition (UK, USA, Canada, Australia, and New Zealand).The purpose of the study is to build a systematical and comprehensive understanding of criminal liability for fraud-related crimes as acts that involve obtaining someone else’s property (the right to someone else’s property) by committing deception, dishonest or misleading actions. To achieve this objective, four tasks were set: to analyze approaches to understanding fraud in Anglo-Saxon legal tradition; to consider the list of fraudulent crimes applicable to each state based on a meaningful analysis of the sources of criminal law; to consider sanctions for committing fraud in each state on the issue of their severity and proportionality to dangerous consequences of related crimes; to resolve the issue of the (in)expediency of implementing Anglo-Saxon anti-fraud criminal law institutions into Russian criminal law.The research is carried out using both general research (analysis, deduction, induction, systematization, etc.) and special research (statistical, special legal (comparative legal, formal legal, historical legal), etc.) methods. The study allowed us to formulate certain results, the basis of which lies in the conclusion about the inappropriateness of implementing the Anglo-Saxon anti-fraud criminal law institutions into the criminal law of Russia. In addition, the study’s key findings provide informed insight into the origins of criminal fraud laws in the Anglo-Saxon states, as well as understanding of severity sanctions for fraudulent crimes in these states.