Risks and Prospects of Cross-Border Circulation of Digital Assets for National and International Security: International Legal and Kyrgyz Context

The subject of the study consists of the international legal and national mechanisms regulating the cross-border circulation of digital assets in the context of ensuring national and international financial security. The aim of the work is to identify the key threats generated by the extraterritorial nature of digital assets and to substantiate a risk-oriented model of state regulation applicable to the Kyrgyz Republic. The research employs comparative legal, formal legal, and system-structural methods, as well as elements of a risk-oriented approach. The paper examines the risks of transaction anonymity, regulatory arbitrage, and threats to financial stability, tax administration, and the effectiveness of anti-money laundering mechanisms. It provides a comparative analysis of four foreign regulatory models (the European Union, the United States, the Russian Federation, and the People’s Republic of China), which makes it possible to identify common trends in the institutionalization of the market and the strengthening of financial monitoring requirements. Based on the Law of the Kyrgyz Republic “On Virtual Assets,” decrees of the Cabinet of Ministers, and the 2026 Presidential Decree, the paper explores the specific features of national regulation and law enforcement practice from 2022 to 2026. The findings are of practical importance for improving the legislation of the Kyrgyz Republic, developing blockchain analytics tools, introducing the digital som, and harmonizing regulation within the Eurasian Economic Union. It is concluded that an effective model of state regulation should be based on a risk-oriented approach, international cooperation, and a balance between state financial security and the development of digital financial technologies.