Abstract
Currently, neither doctrine, legislators nor courts have a clear understanding of cryptocurrency as an object of civil law in the context of Article 128 of the Civil Code, and even the definition of digital currency in the federal law on DFA (digital financial assets) does not help to solve this problem. As a result, the court practice on cryptocurrency is contradictory, plaintiffs are denied protection of their rights, while the pace of lawmaking has slowed down significantly. A comparative legal analysis of the best international law enforcement practice on cryptocurrency has led to the conclusion that its civilistic essence is as close as possible to property rights, and the domestic law is significantly ahead of most codified acts of the continental legal system.
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