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Counterfeiting of currency, securities, and other monetary instruments poses a significant threat to economic stability, public trust in financial systems, and national sovereignty. This study conducts a comparative legal analysis of criminal liability for counterfeiting in Uzbekistan and selected foreign jurisdictions, including Kyrgyzstan, Turkey, Canada, and Japan. The paper examines the scope of criminalization, legislative structures, and the severity of sanctions under national and international legal frameworks. Findings indicate that while Uzbekistan criminalizes counterfeiting under a single provision, other jurisdictions often regulate specific acts separately and impose stricter sanctions. The study highlights legislative ambiguities in Uzbekistan’s law and suggests reforms to enhance legal clarity, improve enforcement, and align national legislation with international standards.
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