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When Worship Goes Online: Rethinking RFRA’s “Substantial Burden” in the Digital Age

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By: Daniel Eum

As discussed in my previous blog, the rapid onset of the COVID-19 pandemic forced churches across the United States to transition their worship services online, often through livestreaming platforms. Even after in-person gatherings resumed, many congregations continued to livestream services. Studies show that by 2024, 91% of churches were livestreaming their services. This underscores how digital worship has become a common, if not fundamental, feature of modern religious exercise. Yet, churches that livestream services may be subject to copyright liability. 

Religious Freedom Restoration Act and the Limits of “Substantial Burden”

This tension invites closer attention to the Religious Freedom Restoration Act (“RFRA”), whose operative provision 42 U.S.C. § 2000bb-1 provides that the federal government “shall not substantially burden a person’s exercise of religion even if the burden results from a rule of general applicability,” unless the government demonstrates that the burden “(1) is in furtherance of a compelling governmental interest; and (2) is the least restrictive means of furthering that compelling governmental interest.” Although the City of Boerne v. Flores decision limited RFRA’s application to the federal government, federal copyright enforcement remains within that scope. 

Courts, however, have historically set a high bar for what constitutes a “substantial burden.” In Worldwide Church of God v. Philadelphia Church of God, Inc., the Ninth Circuit held that requiring a religious organization to obtain permission and pay licensing fees for copyrighted material used in worship did not violate RFRA, reasoning that such obligations amount to mere inconvenience rather than a meaningful constraint on religious exercise. That precedent suggests that routine copyright compliance—such as licensing requirements tied to livestreamed services—will not trigger RFRA protections. Nonetheless, this analysis may be incomplete in the post-pandemic context, where livestreaming is no longer incidental but central to how many congregations practice their faith.

Reconsidering Religious Exercise in the Age of Digital Worship

The rapid normalization of livestreamed worship raises a quieter but important question: whether existing copyright rules, when applied to digital services, impose the kind of “substantial burden” contemplated by RFRA. Part of that inquiry turns on how religious exercise itself is understood. Biblical sources indicate that religious worship depends on the participants’ intent rather than on a particular building. For example, Matthew 18:20 states, “For where two or three gather in my name, there am I with them.” Pastoral commentators read this passage to mean that a particular place, time, or form is not essential, but rather the gathering itself in Jesus’s name. Likewise, Acts 7:48 declares that “the Most High does not live in houses made by human hands,” underscoring that, in the biblical text, God is not confined to man-made structures, a point commentators emphasize in warning against limiting God’s presence to a single physical location or building. Against that backdrop, livestreamed services may be understood less as a departure from traditional worship and more as a continuation of a longstanding principle that religious exercise can adapt to circumstances without losing its essence.

This framing also informs how courts might approach the Copyright Act’s religious service exemption in 17 U.S.C. § 110(3). This provision is meant to prevent copyright law from interfering with worship practices, but its reference to services “at a place of worship” assumes in-person gatherings and does not translate well to digital participation. When congregants join a livestreamed service, they are often engaging in the same liturgy, music, and communal elements as those physically present, suggesting that the activity may be better understood as part of a single religious assembly rather than a separate public performance. Even so, existing precedent indicates that falling outside of § 110(3) would not automatically establish a substantial burden under the RFRA. In Worldwide Church of God, the court held that licensing requirements imposed only an incidental burden on religious exercise, reinforcing the view that routine copyright compliance is unlikely to trigger heightened protection.

At the same time, digital worship environments introduce features that were not present in earlier cases. Many churches livestream services on platforms such as YouTube that rely on automated enforcement systems, which can interrupt or block content in real time. In some circumstances, these mechanisms may affect a congregation’s ability to participate in a service as it occurs, raising questions about whether the burden remains merely incidental. Whether courts would treat such disruptions as “substantial” under RFRA remains uncertain. What is clear is that the combination of widespread online worship and a statutory framework designed for in-person services creates misalignment. If livestreamed services are now a core aspect of religious exercise, then requiring churches to comply with systems that can block or interrupt services in real time begins to look like the kind of substantial burden RFRA was meant to prevent.

Protecting Privacy in Libraries as AI Adoption Accelerates

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By: Anusha Nasrulai

Like picking what movie to watch, what restaurant to eat at, or where to go on vacation, what we read next is often recommended to us by personalization algorithms. Social media or reading platforms such as Goodreads already process user data to generate recommended content. Recently, the library catalog browsing app, Libby, announced its own book recommendation feature, Inspire Me.

Inspire Me by Libby recommends users’ books based on their own prompts or previously saved titles in the app. Originally announced as an optional feature, Inspire Me features prominently at the top of the home screen when users open the Libby App. The feature recommends books available through the catalogs of the libraries which users have linked accounts with. When the feature was first announced, users and libraries showed resistance, voicing concerns about forced AI adoption and diminished patron privacy. OverDrive, the parent company of Libby, states that readers’ personally identifying data and reading activity are not provided to the AI model.

Libraries work with vendor platforms, distributors, and publishers to deliver library services, particularly for e-materials. Despite popular backlash, vendors are expanding development of AI integrations. OverDrive CEO Steve Potash has announced goals to use AI to “match users to content across its platforms,” which also include streaming platform Kanopy, and k-12 education platform Sora. Other subscription vendor companies, such as OCLC, EBSCO, and Clarivate, have introduced AI features for content recommendation, enhanced search, text summaries, and AI-generated research assistants. Beyond externally marketed AI tools, vendors are incorporating AI into their internal workflows for “building, improving, and refining products.” Libraries now are finding the balance between their duty to protect patron data and privacy and providing access to digital resources.

Legal Regulations

The integration of AI by vendor platforms poses new privacy considerations for libraries. AI introduces new risk points at data collection, processing, training, and deployment.

The United States currently has no comprehensive AI or data privacy laws. Instead, states have passed dozens of laws regulating certain AI use cases. As of now, 6 states have passed cross-sectoral AI governance laws that apply to commercial entities. Vendors are likely subject to state-level AI and data privacy laws that target commercial entities. Libraries can leverage legal regulations to negotiate with vendors for stronger privacy protections. Trends in AI regulations show that states are increasingly passing and updating AI legislation amid legal challenges and an absence of federal regulation. 

AI Governance and Contracting

In light of legal uncertainties, contracts and licenses are a key opportunity for imposing guardrails on AI use. These agreements address how vendors and third parties can collect, process, and disclose user data.

More often, vendor agreements will not explicitly disclose internal use of AI tools or AI model training. Research and policy organization, Library Futures, and staff attorney, Layla Maurer, presented on this issue, flagging that broad language around operational mechanisms and data usage may permit vendors to train and deploy AI models using patron and institutional data. When reviewing vendor contracts for AI usage, libraries should focus on:

  • Vendor’s rights around data use and sharing, including with third parties. Use of patron data for “analytics” or “development and improvement of services” may include AI training.
  • References to third-party applications or tools, processors, or contractors necessary to carry out services under the agreement.
  • Whether there is a defined data retention period and what happens to patron data when the contract ends

Libraries can strengthen contract terms by including language requiring compliance with applicable federal and state laws, as well as with industry standards such as ISO and NIST. In addition, libraries may negotiate with vendors to:

  • Define user rights to data, including the right to opt out of nonessential data collection and the right to delete their data.
  • Limit secondary uses of data, including for training internal or external AI tools
  • Disclose third party partners and whether data is shared or sold to third parties
  • Conduct privacy and security audits
  • Establish a data retention period and protocol for destroying data at the end of the retention period

As said by attorney Layla Maurer, “Updating contract language to allow flexibility around software development needs while retaining safeguards for what the licensee… wants to protect is not just an expeditious way to reach an agreement with a software vendor, it’s also a strategy that helps ensure the licensee can continue to safely use the software despite future legislative changes provided the vendor updates their software in a manner consistent with the intent of the legislation.”

Future-proofing

Digital lending and services are a popular means of accessing materials from libraries, but at the same time, raise new challenges for protecting patron privacy. Therefore, as AI becomes embedded in services, libraries need to adopt AI guardrails in contracting to manage the harms and opportunities related to AI use in libraries, particularly around privacy.

From Private Jets to Prison: Art as Collateral and the Limits of Article 9

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By: Matt Unutzer

For a time, Inigo Philbrick was a rising star in the contemporary art world, dealing in blue-chip artwork and brokering deals worth millions of dollars. Behind the champagne and private jets, however, was a web of fraud that ended in a Hollywood-worthy capture on the remote South Pacific Island of Vanuatu and a missing $86,000,000. Inigo’s scheme was straightforward. He acquired valuable paintings and resold fractional shares in them to multiple owners, often selling more than 100% ownership of the same paintings. To keep cash flowing and cover payments to fractional owners, he pledged the same paintings as unencumbered collateral for loans, representing to lenders that he owned the paintings outright. When the scheme unraveled, both lenders and fractional owners were left empty-handed, raising the question of whether existing lending laws are adequate for the murky world of private art transactions.

How Was the Fraud Possible Under Existing Lending Law?

Modern secured lending is governed by Article 9 of the Uniform Commercial Code (UCC). Under UCC § 9-203(b), a security interest is enforceable only if three conditions are met: (1) value has been given, (2) the debtor has rights in the collateral or the power to transfer such rights, and (3) the debtor has authenticated a security agreement describing the collateral.

UCC § 9-202 further provides that Article 9 applies regardless of “whether title to collateral is in the secured party or the debtor.” Attachment of the lender’s security interest, therefore, turns not on formal title allocation between lender and debtor, but on whether the debtor has rights in the collateral, with no independent requirement the lender take title to the collateral.

In Inigo’s case, unwitting lenders believed they were entering into valid secured transactions: Inigo received cash, provided falsified documents purporting to establish his outright ownership of the collateral paintings, and signed security agreements purporting to grant lenders rights in those paintings in the event of default. Under UCC § 9-202, no formal title transfer was required. The problem was that in many cases, Inigo held no ownership interest in the paintings at all. When lenders attempted to enforce their security interest after default, they found themselves in fruitless legal battles with fractional owners who had acquired interests in the same paintings before the loans were made.

Why Article 9 Works in Other Markets.

Article 9’s framework is not inherently flawed. In most asset classes, a debtor’s “rights in the collateral” are independently verifiable because ownership is recorded or registered in a public accessible system. In the case of a mortgage, the quintessential secured lending transaction, title to the real property, and any competing claims or encumbrances, are recorded in public land records. A lender can search those records to confirm ownership and identify competing interests before extending credit. Similar systems exist for many other assets. Vehicles, for example, are governed by registration systems accessible to third parties. In each of these contexts, lenders can independently verify whether the debtor has sufficient rights in the asset before extending credit.

Why Article 9 Struggles in the Art Market.

The art market lacks the verification infrastructure Article 9 presupposes. Although some private registries, such as the Art Loss Register exist, there is no centralized registry of art ownership. Instead, high-value art transactions typically occur through private deals, often with purchasers’ true identities obscured behind holding corporations. Compounding the problem, art has become increasingly financialized, with investors hoping to profit by buying and selling fractional shares of blue-chip artworks, further contributing to the uncertainty surrounding debtor ownership interests in a given artwork.

The result of this system is a patchwork of private transactions. A lender cannot easily determine whether a borrower owns a work outright, holds only a partial interest, or has already conveyed their rights to others. This renders § 9-203(b)(2)’s requirement that the debtor have rights in the collateral difficult to verify with certainty and potentially leaves lenders without legal recourse in the event of default.

Where to Next for Art-Based Lending?

In the absence of a centralized ownership registry, lenders bear a substantial credit risk when accepting art as collateral. Allowing lenders to assert claims against prior owners with undisclosed interests would merely shift that risk to those owners and could, in turn, create perverse incentives that facilitate frauds like those perpetrated by Inigo. 

While high-profile frauds like Inigo’s will likely prompt more rigorous risk management and due diligence by art lenders, they do not appear to be slowing the market. Sotheby’s, a leading market participant, recently announced its latest $900 million art-backed debt security, aimed at  qualified or accredited investors such as pension funds and banks. Perhaps the future of art-based lending may therefore be shaped more by the informal risk controls already employed by major auction houses like Sotheby’s or Christie’s: requiring possession or control of the artwork, maintaining conservative loan-to-value ratios, and insisting on robust provenance documentation.

The “Veto Power” of Fragments: Why A$AP Rocky’s “Don’t Be Dumb” Almost Didn’t Exist

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By: Francis Yoon

After an eight year hiatus and a chaotic three year rollout plagued by leaks and complex clearance battles, A$AP Rocky finally released his fourth studio album, Don’t Be Dumb, on January 16, 2026. The album’s success was immediate, debuting at number one on the Billboard 200 and breaking streaming records for the year. Yet, for many in the industry, the album’s protracted journey remains a sobering case study in intellectual property gridlock. Behind the scenes, the project was reportedly paralyzed for years by the administrative burden of sample clearances, a process that grants recording owners absolute discretionary authority to block a release. Rocky’s public admission that “sample clearances” were disrupting the album underscores a growing crisis in music law: the absolute “veto power” of sound recording owners and the conspicuous absence of a compulsory licensing system to protect transformative art in the digital age.

The “Two-Tiered” Trap of Music Copyright

To understand the bottleneck, one must examine the two distinct copyrights inherent in every recorded song. The first is the musical work, which encompasses the compositional “DNA” of the song, including melody, lyrics, and arrangement. Under Section 115 of the Copyright Act, musical works are subject to “compulsory license,” a vital safety valve that allows an artist to record a cover of a song without seeking original owner’s permission, provided they pay a government-set statutory rate. This system ensures creators receive compensation while preventing them from impeding the progress of science and useful arts by gatekeeping a melody.

The second copyright is the sound recording, often referred to as the “master.” Unlike the composition, sound recordings are governed by Section 114, which offers no such compulsory mechanism. The owner of a recording has absolute discretion to say “no” for any reason, demand 100% of a new song’s equity, or simply ignore a request indefinitely. In Rocky’s case, this discrepancy meant that while he could easily cover a song, his attempt to sample existing recordings turned his creative process into a multi-year hostage situation.

The Legacy of Bridgeport and the Death of De Minimis

The current “veto power” is not just a statutory quirk; it is the product of a rigid judicial history. In the 2005 case Bridgeport Music v. Dimension Films, the Sixth Circuit famously decreed, “Get a license or do not sample.” This ruling effectively killed the de minimis defense for sound recordings, which is the longstanding legal principle that the law does not concern itself with trifles. While a filmmaker might display a copyrighted logo in the background of a shot under “fair use,” a musician today cannot use a one-second audio fragment or a distorted snare hit without risking suppression, as exemplified by the injunction ordering Biz Markie’s album I Need a Haircut to be pulled from sale.

This creates a massive “holdout” problem. Because there is no legal “safe zone” for even the smallest snippets, legacy labels and rights holders are incentivized to extract “ransom” prices as seen in the dispute between The Verve and ABKCO Records over the song “Bittersweet Symphony.” The labels and right holders know that a global superstar’s entire rollout, including merchandise deals with Puma, film collaborations with Tim Burton, and worldwide tour dates, is at the mercy of a tiny audio fragment. This is an administrative nightmare that prioritizes legacy gatekeeping over modern market efficiency.

The Absolute Property Counterargument: Absolute Control vs. Cultural Ingredients

During the development of this analysis, a fundamental challenge arose: “If I own the rights to a theme as iconic as Star Wars, shouldn’t I have the absolute right to say no to anyone else using it?” This represents the strongest argument favoring the status quo. It is rooted in the “Moral Rights” tradition, the principle that creators should maintain complete control over how their “spiritual child” is presented to the world. Under this view, if A$AP Rocky wants to use someone else’s property, he must accept the owner’s rules, no matter how protracted the negotiation becomes.

However, this “absolute property” model ignores the unique way that music, and specifically sampling, functions as a conversation across time. When we treat a three-second audio fragment with the same legal weight as a full-length film or a symphony, we create an intellectual property “thicket” that makes new creation nearly impossible. A compulsory license wouldn’t constitute appropriation but rather would replace an absolute injunctive right with a remunerative right. Just as a homeowner can’t always prevent the city from building necessary infrastructure through their land, provided they are fairly compensated, the law should recognize that once a sound becomes a part of a genre, the original owner’s “veto power” should yield to a fair, standardized compensation system.

Market Failure in the Era of Perfect Enforcement

The problem has been exacerbated by the arrival of near-perfect enforcement technology. In the 1990s, artists could “flip,” pitch-shift, or bury samples so deep that they became unrecognizable to the human ear. Mobb Deep’s “Shook Ones Pt. II” (1995) remained one of hip-hop’s greatest mysteries for 16 years because the producer, Havoc, “buried” the sample so effectively that even the most dedicated crate-diggers couldn’t identify it until 2011. However, by 2026, AI powered digital fingerprinting has become a ubiquitous “digital dragnet“, catching even the most transformed audio textures. This combination of zero tolerance law and perfect detection technology has eliminated the “human” element of risk taking that built early hip-hop.

When transaction costs for clearing a brief sound exceed the value of the sound itself, the market has failed. The manual process of tracking down every sample owner, who may be spread across different labels and estates, creates a barrier to entry that disproportionately affects independent creators. For every superstar like Rocky who can eventually afford a three-year delay, thousands of independent artists see their projects simply die in an inbox.

Conclusion: A Compulsory Sampling License to Safeguard Innovation

The solution lies in creating a “Compulsory Sampling License” similar to the existing framework for cover songs. The law should provide a tiered statutory rate for sound recording fragments based on the length of the sample and the degree of transformation. By creating standardized pricing for samples below a certain threshold, the law would eliminate years of manual negotiation and prevent the “veto power” from being used as an anti-competitive weapon.

A$AP Rocky’s Don’t Be Dumb is a triumph of persistence, but its journey shows that our IP laws are currently built for protection at the expense of progress. By maintaining absolute veto over fragments, we are not just protecting property; we are stifling the next generation of masterpieces. It is time for the law to recognize that in a world where art is increasingly a “melting pot” of styles and sounds, a few seconds of audio should not be enough to stop the music.

Across Nations, Across Identities: Why Deepfake Victims are Left Without Remedies

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By: Hanan Fathima

When a deepfake video of former President Barack Obama appeared in 2018, the public was stunned—this was not just clever editing, but a wake-up call. AI-generated content became hyper-realistic and often indistinguishable as compared to non-AI-generated content. Deepfakes are highly realistic AI-generated content that can imitate a person’s appearance and voice through technologies like generative adversarial networks (GANs). We’ve entered a digital era where every piece of media demands scrupulous scrutiny, raising questions about regulation and justice in a digital age. Different jurisdictions have adopted varying approaches to deepfake regulation, with countries like the US, UK, and EU members emphasizing on international laws on deepfakes, while countries like China and Russia preferring digital sovereignty. A key challenge is navigating the jurisdictional gaps in deepfake laws and regulations.

The Global Surge in Deepfake-Driven Crimes

Deepfake phishing and fraud cases have escalated at an alarming rate, recording a 3000% surge since 2022. In 2024, attempts to create deepfake content occurred every five minutes. This sharp escalation in global deepfake activity is alarming, particularly due to the potential for deepfakes manipulate election outcomes, fabricate non-consensual pornographic content , and facilitate “sextortion scams.” Deepfake criminals exploit gaps in cross-border legal systems. These gaps allow criminals to evade liability and continue their schemes with reduced risk. Because national laws are misaligned and international frameworks remain limited, victims of deepfake crimes face an uphill battle for justice. Combined with limited judicial precedents, tracing and prosecuting offenders has proved to be a massive challenge for many countries.

When Crime Crosses Borders and Laws Don’t

One striking example is a Hong Kong deepfake fraud case in which scammers impersonated a company’s chief financial officer using an AI-generated video in a conference call, duping an employee into transferring HK$200 million (~US$25 million). Investigators uncovered a complex web of stolen identities and bank accounts spread across multiple countries, complicating the tracing and recovery of funds. This case underscores the need for international cooperation, standardized laws and regulations, and robust legal framework for AI-related deepfake crimes[MB6]  in order to effectively combat the growing threat of deepfake fraud.

At a national level, there have been efforts to address these challenges. An example is the U.S. federal TAKE IT DOWN Act 2025, which criminalizes the distribution of non-consensual private deepfake images and mandates prompt removal upon request. States like Tennessee have enacted the ELVIS Act 2024, which protects individuals against use of their voice and likeness in deepfake content, while Texas and Minnesota have introduced laws criminalizing election-related deepfakes to preserve democratic integrity.Similarly, Singapore passed the Elections (Integrity of Online Advertising) (Amendment) Bill to safeguard against misinformation during the election period. China’s Deep Synthesis Regulation 2025 regulates deepfake technology and services, placing responsibility on both platform providers and end-users.

On an international scale, the European Union’s AI Act serves as among the first comprehensive legal frameworks to tackle AI-generated content. It calls for transparency, accountability, and emphasizes labelling AI-manipulated media rather than outright bans.

However, these laws are region-specific and thus rely on international and regional cooperation frameworks like MLATs and multilateral partnerships for prosecuting foreign perpetrators. A robust framework must incorporate cross-border mechanisms such as provisions for extraterritorial jurisdiction and standardized enforcement protocols to address jurisdictional gaps in deepfake crimes. These mechanisms could take the form of explicit cooperation protocols under conventions like the UN Cybercrime Convention, with strict timelines for MLAT procedures, and regional agreements on joint investigations and evidence-sharing.

How Slow International Processes Enable Offender Impunity

The lack of concrete laws and thus concrete relief mechanisms means victims of deepfake crimes face multiple barriers in their ability to access justice. When cases involve multiple jurisdictions, investigations and prosecutions often rely on Mutual Legal Assistance Treat (MLAT) processes. Mutual Legal Assistance is “a process by which states seek and provide assistance in gathering evidence for use in criminal cases,” as defined by the United Nations Office on Drugs and Crime (2018). MLAT is the primary mechanism used for cross-border cooperation in criminal proceedings. Unfortunately, victims may experience delays in international investigations and prosecutions due to slow and cumbersome processes associated with MLAT. Moreover, the process has its own set of limitations such as human rights concerns, conflicting national interests, and data privacy issues. According to the Interpol Africa Cyberthreat Assessment Report 2025, requests for Mutual Legal Assistance (MLA) can take months, severely delaying justice and often allowing offenders to escape international accountability.

Differing legal standards and enforcement mechanisms across countries make criminal proceedings related to deepfake crimes difficult. On a similar note, cloud platforms and social media companies hosting deepfake content may be registered in countries with weak regulations or limited international cooperation, making it harder for authorities to remove content or obtain evidence.

The Human Cost of Delayed Justice

The psychological and social impacts on victims are profound. The maxim “justice delayed is justice denied” is particularly relevant—delays in legal recourse means the victim’s suffering is prolonged. This often presents as reputational harm, long-term mental health issues, and career-related issues. Thus, victims of cross-border deepfake crimes may hesitate to report or pursue legal action. They are further deterred due to language, cultural, or economic barriers. Poor transparency in enforcement creates mistrust in international legal systems and marginalizes victims, weakening deterrence.

Evolving International Law on Cross-Border Jurisdiction

There have been years of opinions and debates over the application of international law for cybercrimes and whether it conflicts with cyber sovereignty. The Council of Europe’s 2024 AI Policy Summit highlighted the need for global cooperation in investigation and prosecutorial activities of law enforcement and reaffirmed the role of cooperation channels like MLATs. Calls for a multilateral AI research institute were made in the 2024 UN Security Council debate on AI governance. Recently, in the 2025 AI Action Summit, discussions were focused on research and the transformative capability of AI, and the regulation of such technology. Discussion on cybercrimes and its jurisdiction was limited.

In 2024, the UN Convention Against Cybercrime addressed AI-based cybercrimes, including deepfakes, emphasizing on electronic evidence sharing between countries, cooperation between states for extradition requests and Mutual Legal Assistance. The convention also allows states to establish jurisdiction over offences committed against their nationals regardless of where the offense occurred. However, challenges in implementation persist as a number of nations are yet to ratify this convention, including the United States.

Towards a Coherent Cross-Border Response

Addressing the complex jurisdictional challenges posed by cross-border deepfake crimes requires a multi-faceted approach that combines legal reforms, international collaboration, technological innovations, and victim-centered mechanisms. Firstly, Mutual Legal Assistance Treaties (MLATs) must be streamlined with standardized request formats, clearer evidentiary requirements, and dedicated cybercrime units to reduce delays. Secondly, national authorities need stronger digital forensic and AI-detection capabilities, including investing in deepfake-verification tools like blockchain-based tracing techniques. Thirdly, generative AI platforms must be held accountable, with mandates for detection systems and prompt takedown obligations. However, since these rules vary regionally, platforms do not face the same responsibilities everywhere, underscoring the need for all countries to adopt consistent standards for platforms. Fourth, nations must play an active role in multilateral initiatives and bilateral agreements targeting cross-border cybercrime, supporting the creation of global governance frameworks governing extraterritorial jurisdiction of cybercrimes like deepfakes. While countries like the United States, UK, EU members, and Japan are active participants in international AI governance initiatives, many developing countries are excluded from these discussions. Countries like Russia and China have also resisted UN cybercrime treaties, citing sovereignty values. Notably, despite being a global leader in AI innovation, the US has also not ratified the 2024 UN Convention against Cybercrime. Lastly, a victim-centered approach, through legal aid services and compensation mechanisms, is essential to ensure that victims are not left to navigate these complex jurisdictional challenges alone.

While deepfake technology has the potential to drive innovation and creativity, its rampant misuse has led to unprecedented avenues for crimes that transcend national borders and challenge existing legal systems. Bridging these jurisdictional and technological gaps is essential for building a resilient and robust international legal framework that is capable of combating deepfake-related crimes and offering proper recourse for victims.