Особенности уголовно-правовой охраны интеллектуальной собственности в законодательстве некоторых зарубежных стран

The article examines the problems of regulating criminal liability for violation of intellectual property rights in foreign countries, examines approaches to criminal protection of intellectual property in various legal systems: Anglo-Saxon and Romano-German. The authors note that there is a global consensus that the field of intellectual property should be regulated, including criminal law, in order to protect the rights of intellectual property owners. Although there is some uniformity in national intellectual property laws, there are separate copyright laws and regulations in each jurisdiction. The work also explores various solutions and approaches to the problem of regulating criminal liability for violation of intellectual property rights, especially copyrights, in the national legislation of both developed Western countries - the USA, England, Spain, and neighboring countries - Belarus, Kazakhstan, Kyrgyzstan, Moldova, etc. A comparative legal analysis of the criminal law prohibition contained in Article 146 of the Criminal Code of the Russian Federation and similar norms in the legislative acts of some foreign countries has been carried out.