<![CDATA[The article identifies cultural heritage as an important object of criminal law protection in international and comparative dimensions, with an emphasis on the legislation of Azerbaijan.The methodological basis is a theoretical and legal comparative study, which consisted of a dogmatic analysis of international legal acts (the Hague Convention of 1954, the UNESCO conventions of 1970 and 2003, the Rome Statute of the ICC) with a comparison of national criminal legislation. The analysis was carried out based on the use of the corpus delicti construction (actus reus, mens rea, subject, sanction) in selected jurisdictions of the EU, the post-Soviet space and the Middle East. As a result, the existence of three models of criminal law protection of cultural heritage was established: institutionalized (EU), mixed (post-Soviet space) and fragmentary (Middle East). The main difference between them was the degree of transition from a material model (cultural property) to a human-centered one (cultural heritage). The results indicated that the criminal legislation of Azerbaijan mainly reflected a material approach, since cultural heritage was not defined as an independent object of criminal law protection and was regulated through general property norms. At the same time, the latest legislative changes (2024–2026), in particular the introduction of liability for negligent destruction of cultural values and the expansion of the liability of legal entities, indicated a gradual transition to a hybrid model. Despite this, significant gaps were identified, in particular, the lack of specialized categories of crimes, the incomplete implementation of international standards, and the lack of a normative definition of cultural value.]]>
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