A Comparative Analysis of Regulatory Approaches to Digital Assets in Kazakhstan and China in the Context of Regional Trade

The article presents a comparative legal and institutional analysis of the regulatory models governing the circulation of digital assets and sovereign central bank digital currencies (CBDC) in the Republic of Kazakhstan and the People’s Republic of China. Against the backdrop of growing bilateral trade turnover and the transformation of cross-border payment systems, the study examines the problem of regulatory dissonance between Kazakhstan’s segmented-liberal approach and China’s sovereign-prohibitive model. On the basis of an eight-criterion matrix and scenario modelling of four settlement channels, it is shown that private unbacked crypto-assets and regulated stablecoins cannot serve as instruments for export-import operations, owing to the PRC’s regulatory prohibition, irrespective of their legal status in Kazakhstan. It is argued that the only legally viable vector of financial integration is the interoperability of national CBDCs — the digital tenge and the e-CNY — through bilateral channels and the mBridge platform.