A Cross-Border Regulatory Coordination Framework for Digital Asset Governance: Lessons from Uzbekistan and Kazakhstan

Mukhammad Ali Turdialiev (Tashkent State University of Law, Tashkent)
Yuldashev Jakhongir Inomovich (Tashkent State University of Law, Tashkent)
Khazratkulov Odilbek Turasunovich (Tashkent State University of Law, Tashkent)
Dilboboev Nozimbek Shavkat Ugli (Tashkent State University of Law, Tashkent)
Gulomjon Khakimov (Tashkent International University, Tashkent)

JHCLS
Vol. 6 No. 2 (2026): Journal of Human Rights, Culture and Legal System

The rapid expansion of digital asset transactions has reshaped international economic activity and challenged the capacity of national legal systems to provide consistent regulatory protection. Kazakhstan and Uzbekistan have developed distinct legal approaches based on their institutional priorities and financial supervisory policies. This study examines how these regulatory differences influence legal certainty in cross border digital asset transactions. The analysis identifies three principal findings. First, different regulatory philosophies shape the recognition, classification, and supervision of digital assets, creating uncertainty about applicable legal standards. Second, differences in institutional authority and administrative practices produce overlapping responsibilities, inconsistent compliance requirements, and weak coordination among regulatory authorities. Third, limited regulatory interoperability complicates jurisdictional determination, information exchange, regulatory recognition, and cross border enforcement. The study therefore proposes a Cross Border Regulatory Coordination Framework that promotes regulatory compatibility, functional equivalence, mutual recognition, supervisory cooperation, and coordinated enforcement while preserving national regulatory autonomy and strengthening legal certainty across both jurisdictions.