Differences in the criminal law regulations of liability for fraud in the legislation of some foreign countries

Abstract. During the last decade, there has been an interest in comparative legal studies concerning the science of criminal law. A significant change in the conditions of social life and the desire to adhere to the principles accepted by the peoples of developed countries require the study of foreign experience and sometimes taking information from international law.

Comparative research makes it possible to reveal and take into account other people's mistakes and achievements when solving questions about criminality and the punishment of specific acts, helps to understand the role and significance of criminal law as a tool of social regulation.

Recently, comparative legal studies of norms concerning property criminal offenses have appeared in science, but they pay unjustifiably little attention to the investigation of fraud. In this article, without pretending to be an exhaustive analysis, we will focus attention on the most significant differences in the criminal law regulation of liability for fraud in the legislation of some foreign countries.

No society can exist without property, which, being the economic basis, largely determines political, moral, legal, and other relations. According to the modern idea of the system of social values, the right to property is regarded as the greatest of the social benefits of an individual. Therefore, encroachments on these benefits are encroachments on personality.

Fraud occupies a special place among criminal offenses against property. Even though in quantitative terms, fraudulent crimes are inferior to theft and robbery, in terms of the growth rate of the number of registered cases of fraud, this type of criminal offense is significantly ahead of other crimes against property.

A feature of foreign legislation is the presence, along with the general regulation concerning liability for fraud, of an extensive system of special regulations concerning liability for fraud in financial markets, in insurance, lending, and circulation of actual objects, goods, and services.