The use of virtual currencies, including cryptocurrencies, is an integral part of the digital economy. However Russian attempts to adopt a law that would determine the legal status of cryptocurrency were not successful. It underlines the need to create approach based on a comparative legal study allowing to understand necessity of cryptocurrency legalisation or prohibition. The Macau Special Administrative Region of China is one of the leading financial centers in Asia. Its financial authorities developed an approach based on limiting the use of cryptocurrency due to high risks of criminal money laundering. This experience can be useful for Russian legislator in constructing a model of cryptocurrency legal regulation.