The Divergence of Legislative Models in Addressing Artificial Intelligence Crimes: A Comparative Study of the European Union, China, and the United States

Abstract

The rapid advancement of artificial intelligence technologies has created unprecedented legal challenges in combating crimes arising from their unlawful use. This study analyzes comparative legislative frameworks for addressing ai-related crimes through three international models: the European union, which adopts a preventive risk-based approach; China, which implements a centralized strategy focused on digital sovereignty and national security; and the United States, which employs a decentralized system between federal and state levels. The study reveals fundamental divergences in legislative philosophies: the European model balances rights protection with innovation encouragement, the Chinese model links legitimacy to social stability, while the American model emphasizes direct criminal sanctions. The research emphasizes the necessity of international coordination to establish unified legal frameworks addressing the cross-border nature of these crimes and developing effective law enforcement mechanisms in modern cyberspace.