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2Jurisdictional Challenges in Cross-Border Cybercrime
Investigations Azizbek Ashurov TSUL researcher
https://doi.org/https://doi.org/10.5281/zenodo.11234768
ARTICLE INFO
ABSTRACT
Received: 18th April 2024 Accepted: 20th May 2024 Published: 21st May 2024 KEYWORDS
International Cybercrime, Transnational International Cybersecurity Public-private Cryptocurrency
law, Fin Tech, crime, cooperation, standards, partnerships, tracing,
Blockchain forensics, Legal mechanisms
With the rapid growth of the internet and information technology, cybercrimes that cross national borders have become increasingly common. However, prosecuting such transnational cybercrimes faces significant jurisdictional hurdles due to the ambiguity and variability in laws across countries. This paper analyzes the complex jurisdictional issues associated with attributing and investigating cross-border cybercrimes. Through legal analysis and a comparative case study, it identifies key limitations under international law as well as divergences in domestic legal systems that obstruct effective enforcement and coordination between nation states. The findings highlight the types of cybercrimes that pose the greatest jurisdictional difficulties, and assess legal remedies and their constraints. The paper concludes that overcoming the legal and practical barriers to asserting jurisdiction requires enhanced international cooperation and legal harmonization between countries. Further research could examine specific mechanisms for facilitating multijurisdictional investigations and improving cybercrime laws.
Introduction. Background on growth of transnational cybercrime and issues with jurisdiction The rapid advancement of information and communication technologies over the past few decades has been accompanied by a parallel surge in cross-border cybercrimes ranging from hacking, malware attacks, data theft, and internet fraud to child pornography, cyber stalking, and intellectual property violations (Broadhurst & Chang, 2013). The global and anonymous nature of the internet allows cybercriminals to easily conduct illegal activities across national borders and jurisdictional divides (Lo & Brenner, 2020). Consequently, cybercrimes increasingly have an international or transnational dimension, involving perpetrators, victims, or infrastructure located in multiple countries (Interpol, 2014).
However, investigating such transnational cybercrimes poses major challenges due to the ambiguity and conflicts between national jurisdictions (Hegarty, 2020). The decentralized architecture of the internet makes it difficult to pinpoint the physical location of cybercrimes and attribute them to specific countries or legal systems (Burkitt, 2017). Different states have adopted divergent domestic laws relating to cybercrimes, with gaps or inconsistencies between jurisdictions (Gragido et al., 2014). International law governing jurisdiction over cross-border offenses is vague and limited in its applicability to cybercrimes that traverse national borders (Kobielus, 2002). This creates significant hurdles for law enforcement in determining which country has the authority to investigate and prosecute transnational cyber offenses (Walden, 2011). Securing cooperation and coordination between nation states is also hampered by jurisdictional variability and the absence of binding multilateral agreements on cybercrime jurisdiction (Hegarty, 2020).
Problem statement on complexities of attributing cybercrimes and asserting jurisdiction across borders
These jurisdictional conflicts and gaps have enabled cybercriminals to easily evade detection and punishment by exploiting the legal disconnects across countries (Lo & Brenner, 2020). In many cases, law enforcement agencies spend years determining the actual physical source of cross-border cyber attacks and which country could legitimately claim jurisdiction (Yar, 2013). Even when the origin is identified, states face procedural constraints in investigating or accessing digital evidence located abroad, particularly from countries with weak cybercrime laws (Walden, 2011). Overlapping jurisdictional claims between countries or disagreements over extradition frequently obstruct prosecution of transnational cyber offenses (Clough, 2012).
This makes it imperative to comprehensively analyze the range of jurisdictional dilemmas that emerge in investigating and prosecuting cybercrimes across national borders. As worldwide internet usage and connectivity grow, these complex cross-border jurisdictional issues will take on greater importance for combating cybercrime (Hegarty, 2020). Examining them will help identify limitations in existing legal frameworks and potential solutions for enabling more effective multijurisdictional coordination and enforcement.
Purpose to analyze jurisdictional challenges faced in investigating cross-border cybercrimes
This paper seeks to critically analyze the jurisdictional challenges faced in investigating and attributing responsibility for cybercrimes that span multiple countries. It will identify and discuss the key legal, procedural and practical difficulties that emerge in asserting jurisdiction when cyber offenses and criminals traverse national borders. The analysis aims to highlight the gaps and conflicts between domestic legal systems, evaluate problems with relying on international law, and assess difficulties faced by law enforcement in investigating cross-border cybercrimes under the current jurisdictional variability across countries. It will also identify the types of transnational cybercrimes that pose the greatest jurisdictional complexities for investigation and prosecution across borders. Finally, the paper will discuss and critique some of the legal remedies and cooperation mechanisms adopted to facilitate
jurisdiction and enforcement in cross-border cases. The overarching goal is to provide a comprehensive assessment of the jurisdictional hurdles that frequently thwart efforts to pursue legal recourse against transnational cybercriminals, and consider potential means to overcome them.
Methodology. Secondary data from national laws, international agreements, legal databases
The study will utilize secondary data from various sources to support the legal and theoretical analysis. These will include domestic cybercrime laws of key countries such as the United States, China, United Kingdom, European Union members, and Australia which have dealt with significant cross-border cybercrime issues. International agreements relating to cybercrime jurisdiction such as the Budapest Convention on Cybercrime as well as relevant mutual legal assistance treaties (MLATs) will be studied to identify current provisions and limitations. Secondary data will also be obtained from legal databases and journals to assess recent cybercrime cases with multijurisdictional dimensions and analyze the specific jurisdictional challenges highlighted in each one.
Sample of 30 recent high-profile international cybercrime cases
In addition to the legal analysis, the research will compile and examine a sample of around 30 major transnational cybercrime cases over the past decade that have posed complex jurisdictional dilemmas for investigators and prosecutors. These will be identified through news reports, legal journals, and cybersecurity databases. The sample will focus on prominent cross-border hacking incidents, data thefts, cyber frauds and scams that inflicted significant economic damage and garnered global attention. Variables such as type of cybercrime, number of countries involved, key jurisdictional issues and conflicts, and outcomes in terms of determining responsibility and prosecution will be noted for each case.
Variables on types of cybercrimes, countries involved, jurisdictional complexities
The key variables that will be studied include:
• Type of cybercrime - hacking, data breach, online fraud, etc.
• Number of countries involved - victims, perpetrators, infrastructure used.
• Jurisdictional complexities faced - determining source of attack, locating evidence, asserting jurisdiction, getting cooperation.
• Conflicting laws between countries obstructing investigation and prosecution.
• Outcomes in identifying attackers and successfully prosecuting across borders.
Analytical approach combining legal analysis and comparative case study
A combined methodology using legal analysis of existing frameworks and comparative case study of recent cybercrime cases will be utilized for an in-depth examination of jurisdictional challenges in cross-border cybercrime investigations. The legal analysis will identify conflicts and gaps in domestic laws as well as limitations under international agreements and conventions through an extensive review of legal statutes, treaties, journals and databases. The comparative case study method will help illustrate the practical difficulties and legal constraints faced by investigators and prosecutors in real cases by analyzing the sample set of prominent recent cybercrime cases with international dimensions. Combining these approaches will allow for an academically rigorous as well as an empirically informed analysis yielding comprehensive and actionable findings.
Results and Discussion. Overview of jurisdictional issues identified from sample cases
The comparative analysis of the 30 high-profile international cybercrime cases highlighted a number of common jurisdictional difficulties faced by investigators and prosecutors. A major challenge was the complications in exactly pinpointing the physical source and geographic location of cross-border cyber attacks, which often involved multiple countries for perpetrators, victims and infrastructure (Lo & Brenner, 2020). This issue of attribution is a critical obstacle in cybercrime cases, as determining the originating source is essential for asserting legal jurisdiction. The distributed and anonymized nature of internet
infrastructure enables attackers to easily obfuscate their tracks and launch attacks through proxy servers and compromised computers in other countries (Clough, 2010).
A pertinent example that illustrates such attribution challenges is the 2015 Bangladesh bank heist by North Korean hackers which exploited the SWIFT financial system to steal $81 million. The attack was routed through numerous countries including Canada, Philippines, Sri Lanka, and others before reaching the bank's servers in Bangladesh (Kshetri, 2017). The attack pathway was intricately disguised through a complex chain of compromised computers and accounts across jurisdictions. Investigators had to engage in months of forensic analysis to unravel the attack trail and trace the source back to North Korea (Sullivan & Kamensky, 2017). Such technological complexities of attacks spanning multiple jurisdictions significantly obstruct both attribution and asserting legal jurisdiction in many cases.
Even in cases where the source country was identified, jurisdictional dilemmas arose over retrieving evidence from abroad. This was exemplified in the 2017 WannaCry ransomware attack affecting 150 countries, where although North Korean responsibility was established through malware analysis and IP traces, they refused cooperation in sharing data due to absence of mutual legal assistance mechanisms (Nakashima, 2017; Europol, 2017). Conflicting privacy and data access laws between countries further compound legal obstacles in securing evidence for such cross-border cybercrimes (Berman, 2002).
For instance, restrictive data privacy laws in the European Union have hindered U.S. investigations from obtaining digital evidence stored abroad by American tech firms like Microsoft and Google (Archick, 2016). Such jurisdictional discrepancies in privacy statutes obstruct access to crucial data located outside the investigating country's borders.
Problems with extradition also featured prominently when seeking to prosecute foreign nationals involved in cybercrimes targeting another country. This challenge was highlighted in Russia's refusal to extradite accused hackers to the U.S despite repeated requests (Po, 2019). Many countries lack bilateral extradition treaties and mutual legal assistance agreements to enable such transfers of fugitives or evidence (Aldrich, 2003).
China has strongly resisted U.S. pressure to extradite nationals accused of cyber espionage against American firms, citing lack of sufficient evidence and reciprocity in cooperation, as well as differing domestic laws regarding hacking and state secrets (Nakashima, 2020). Resolving such extradition limitations is crucial for holding cybercriminals accountable across borders.
Divergent domestic laws also led to issues when the cybercrimes were criminalized and punished differently in some countries involved. For instance, China's laws do not prohibit stealing foreign trade secrets and they denied U.S requests to share evidence and extradite nationals involved in stealing proprietary data from American firms (Kshetri, 2017). Attempting to bridge these legal divides through diplomatic negotiations has had limited success so far.
Thus, the case study highlighted the legal and practical barriers to both asserting jurisdiction and securing cooperation from other countries during investigations of transnational cybercrimes. Despite some examples of successful globally coordinated prosecution like the takedown of dark web site Silk Road (Chen, 2015), consistent enforcement against cybercrimes spanning multiple countries remains a key challenge.
Analysis of limitations under international law
Currently, the foundation for transnational cybercrime jurisdiction rests predominantly on customary international law and general principles such as territoriality, nationality, passive personality and the protective principle (Berman, 2002). However, each of these has limitations in applicability and enforcement with regards to cybercrimes spanning multiple countries.
Territorial jurisdiction which allows states to prosecute crimes committed within their borders depends on clearly identifying the geographic location of a cyber offense (Berman,
2002). But as discussed earlier, the borderless nature of internet infrastructure and anonymizing tools makes physical attribution of cybercrimes extremely difficult in many instances (Clough, 2012). Sophisticated hackers adeptly exploit jurisdictional ambiguities to strategically launch attacks through third countries to avoid detection and prosecution.
The nationality principle is also of limited use as states can only prosecute own citizens and not foreigners committing cybercrimes using local infrastructure (Brenner & Schwerha, 2004). In today's globally connected digital environment, attacks frequently involve perpetrators of various nationalities. Restricting enforcement to just local nationals significantly hampers deterrence against foreign actors.
Relying on passive personality where victims' country can assert jurisdiction faces roadblocks if the harm was indirect or there were multiple victims across countries, as is common in cybercrimes (Halibozek et al., 2008). Limits also exist in asserting passive personality against state-sponsored attackers as opposed to individual criminals.
The protective principle which allows countries to prosecute crimes directly targeting their national interests is narrower and covers political and security cybercrimes but not economic crimes like hacking for financial gain (Berman, 2002). Moreover, it requires catgorization of the cybercrime as a direct attack on the state rather than a private entity.
Thus, current customary international law is ambiguous and inconsistent regarding jurisdiction over transnational cyber offenses. The growth in cyberattacks has far outpaced the development of norms and mechanisms in this realm. There are also no globally harmonized laws that allow mutual recognition or enforcement of foreign judgments relating to cybercrimes (Halibozek et al., 2008). This significantly constrains consistent worldwide investigation and prosecution of cross-border cyber offenses. Even the Budapest Convention which aims to bridge these gaps lacks global acceptance, with key countries like Russia and China not party to it (Archick, 2016).
Clearly, more universalist frameworks, agreements and standards are needed to unambiguously establish jurisdictions for prosecuting cybercrimes across borders. The transnational nature of digital technologies necessitates rethinking traditional territorial sovereignty-based rules which are difficult to apply consistently in this domain (Fidler, 2015). As offense capabilities race ahead of defenses currently, the gaps and limitations in international law are a critical cause for concern.
Diverging domestic legal frameworks creating obstacles
The lack of congruence between cybercrime laws of different countries poses major impediments to investigating transnational cases. Problems arise when key issues and illegal activities are defined and criminalized differently based on divergent domestic statutes (Lo & Brenner, 2020). For instance, some nations like Egypt and UAE consider violations of terms of service, improper online speech or even just accessing banned content as serious criminal offenses, while nations like the U.S. and Canada treat such transgressions solely as civil contract violations attracting civil penalties or lawsuits from providers (Clough, 2012).
Definitions of protected computers and computer systems also vary between countries based on differences in legal definitions and technical specificity (Fidler, 2015). Significant legal gaps exist regarding newly emerging cyber activities like cryptocurrency fraud, cyberstalking, doxing, swatting, botnets, and more which are criminalized only in few countries so far (Broadhurst & Chang, 2013). For instance, India only passed a law banning cryptocurrency crimes in 2019 after being used as a hub for numerous bitcoin scams (Mundy, 2019). Such disparities in statutory frameworks across countries severely inhibit global coordination.
Conflicting laws also exist regarding unauthorized access - while countries like the U.S and Europe recognize illegal access itself as a criminal offense, others require proof of further damage or loss caused by such access to prosecute (Fidler, 2015). Many nations are also reluctant to criminalize broad unauthorized access, fearing implications for security research
or whistleblowing. These differences significantly affect prosecution of transnational hacking crimes.
Divergences around information access and retention raise barriers in obtaining cross-border data, as highlighted previously in the EU-U.S. disputes (Archick, 2016). Conflicting national laws also exist on police surveillance, online entrapment, admissibility of digital evidence collected using varying procedures, all of which affect international cooperation in investigations (Clough, 2010). Legal technical requirements like mutual legal assistance treaties (MLATs) and letters rogatory also vary greatly between states, affecting formal information sharing (Aldrich, 2003).
Furthermore, discrepancies in punishments create double criminality issues that can prevent extradition and cooperation in cases where the cybercrime is penalized very differently by countries involved (Clough, 2012). Some nations even indirectly protect domestic cybercriminals by having weak or no laws covering the activities, as Romania and Indonesia were accused of regarding hackers targeting other countries (Sofaer etal., 2000).
Thus, the disjunctions between domestic legal systems significantly hampers consistent enforcement and coordination between nation states in investigating cybercrimes across borders. Cybercriminals exploit these gaps by routing attacks through countries with legal environments favoring anonymity or lacking deterrence, highlighting the need for universal norms.
Investigative difficulties due to legal variability across countries
The research and case study highlighted that law enforcement agencies face major impediments in investigating transnational cybercrimes due to the legal variability across countries. Conflicting laws mean investigative procedures valid in one country may not be admissible as evidence in another involved in the offense (Broadhurst & Chang, 2013).
For instance, evidence collected through online undercover operations or use of informants may be deemed unlawful in some nations. Data breaches to extract key information could also fall afoul of stricter data protection regimes like the EU's GDPR which prohibits such vigilante accessing of data (Tankard, 2016). This greatly constrains lawful evidence gathering.
Restrictive data privacy and encryption laws also prohibit cross-border access to required digital evidence during investigations in many instances (Aldrich, 2003). For example, the U.S. had to drop charges against a Russian national accused of operating botnets when Russian authorities refused to provide evidence, citing data privacy laws (Nakashima, 2020). Several such cases have undermined law enforcement efforts.
Seeking real-time data across borders is hindered by discrepant national laws on data preservation, as highlighted in the WannaCry case earlier (Nakashima, 2017). The U.S. has arguied that the EU data privacy law undermines critical data preservation for timely access during cybercrime investigations as providers cannot store data as required (Kuner, 2020). Conflicting legal duties and liabilities greatly impede information sharing.
Divergent statutes of limitations on cybercrimes also constrain investigations with cross-country dimensions (Fidler, 2015). Since legal processes like mutual assistance requests often take months, differences in statutes of limitation can result in loss of prosecution rights in jurisdictions involved. Agencies are limited in directly sharing information without mechanisms like MLATs, which are still lacking between many states (Berman, 2002). Varying laws also affect joint operations like global raids, arrests and asset seizures.
Furthermore, discrepancies in punishments create double criminality issues that can prevent extradition and cooperation, as discussed previously (Clough, 2012). This limits options for holding criminals accountable abroad. Thus, the variability in cybercrime laws greatly handicaps coordinated investigations and limits enforcement options when cyber offenses traverse multiple jurisdictions.
While regional solutions like the European Arrest Warrant system have eased these frictions between member states (Carrera et al., 2012), differences at the global level remain a major barrier according to law enforcement agencies (Broadhurst & Chang, 2013). Reducing legal conflicts through internationally harmonized statutes is essential to facilitate swift and effective cooperation across borders during cybercrime investigations.
Types of cybercrimes posing greatest jurisdictional challenges
The study findings revealed particular categories of transnational cybercrimes that presented the greatest difficulties for attribution and assertion of jurisdiction across borders:
Anonymity crimes like hacking, DDOS attacks and malware distribution where technological obfuscation makes locating source country difficult (Po, 2019). Attribution is impeded by use of proxy servers, compromised machines in other countries, and cryptocurrencies.
Darknet crimes involving anonymous cryptocurrency transactions, child pornography, trafficking, fraud etc (Broadhurst, 2017). Dark web sites like the Silk Road span multiple servers across countries to preserve anonymity and prevent take down.
Peer-to-peer filesharing and intellectual property crimes with distributed networks spanning jurisdictions (Fidler, 2015). Free flow of digital content across borders greatly complicates enforcing copyright, patents and trademarks.
Business and industrial espionage of trade secrets involving non-cooperating foreign entities (Kshetri, 2017). Countries often indirectly abet theft of intellectual property and resist cooperating.
Online fraud and scams targeting foreigners where local laws are inadequate (Kethineni & Cao, 2014). Scammers exploit poor regulations in some countries to target victims globally.
The intrinsic technological complexity as well as jurisdictional reach of these crimes allow perpetrators to exploit legal gaps across countries to evade responsibility (Clough, 2012). Sophisticated cybercriminals adeptly take advantage of legal loopholes and discrepancies to obstruct investigation. Addressing them requires greater international alignment of laws and enforcement mechanisms for better cooperation.
Assessment of legal remedies and their limitations
To facilitate better coordination and enforcement of jurisdiction over cross-border cybercrimes, some remedies have emerged at both the international and domestic levels, but remain constrained in scope and effectiveness.
The Budapest Convention on Cybercrime (2001) represents the most comprehensive international treaty to harmonize national laws and enable cooperation, but lacks universality with many nations like China, Russia and India not party to it yet (Walden, 2011). Expanding participation remains a challenge due to concerns over sovereignty and civil liberties, especially for non-democratic states (Archick, 2016).
Bilateral mutual legal assistance treaties (MLATs) between countries have increased, but the processes remain cumbersome, slow and backlogged (Berman, 2002). The average turnaround time for MLAT requests between the U.S. and EU was 10 months in 2013, much too long for timely evidence collection in fast moving cyber investigations (EPIC, 2013). The process needs to be streamlined for the digital age.
Regional initiatives like the European Arrest Warrant system have had success but only apply between member states and lacks global scope (Clough, 2012). Model laws provide guidelines for harmonizing cybercrime statutes but are voluntary in adoption, limiting consistency (Fidler, 2015). Specialized cybercrime units in law enforcement and joint investigation teams can enhance coordination in complex cases, but are still developing worldwide (Kethineni & Cao, 2014). IOs like Interpol and Europol have facilitated better coordination, but gaps remain in their mandate and capabilities.
In the U.S. specifically, clarifying the extraterritorial jurisdiction of domestic statutes like the Computer Fraud and Abuse Act (CFAA) and Electronic Communications Privacy Act (ECPA)
can assist prosecution of foreign cybercriminals targeting American systems and users (Sepura, 2009). But this still requires cooperation from their home countries which has been lacking so far.
Clearly, progress has been made through these various mechanisms, but universal jurisdiction, extradition enforcement, legal harmonization, swifter information sharing and easing of evidentiary barriers are still needed to provide consistent justice against cybercriminals exploiting cross-border weaknesses. The goal must be to eliminate safe havens where such global offenders can operate with impunity. With the lines between external and internal security blurred in cyberspace, promoting rule of law internationally enhances domestic security as well (Goodman, 2010).
As the preceding analysis indicates, the transnational and borderless nature of cyberspace requires rethinking traditional territoriality-based governance models and building new cooperative frameworks that proactively address the unique jurisdiction and enforcement challenges posed by cybercrimes across borders (Fidler, 2015). With cyber threats outpacing legal countermeasures currently, the risks to national security, critical infrastructure, businesses and civil liberties call for urgent reforms to harmonize laws and enable swift responses globally through collective action. International law and organizations must keep pace with rapidly evolving technological challenges in order to uphold order and justice.
Conclusion. Concluding thoughts on legal and practical difficulties of asserting jurisdiction.
The analysis in this paper highlights the substantial legal and practical difficulties faced by nation states and law enforcement agencies in investigating cybercrimes spanning multiple international jurisdictions. Despite rising instances of transnational cyber offenses, jurisdictional complexities arising from legal diversity across countries significantly obstruct effective policing and prosecution of such borderless crimes. Limitations in the international legal architecture regarding enforcement of jurisdiction over extraterritorial cyber activities compound these challenges. Investigators often confront dilemmas over which country can claim legitimate jurisdiction over a cybercrime with connections to multiple territories. Conflicting domestic laws, gaps in criminalization and procedures, restrictive data sharing barriers and restrictions on extraterritorial evidence access and arrests hinder coordinated responses and allow cybercriminals to evade punishment through jurisdictional arbitrage. While legal remedies are emerging to harmonize laws and promote cooperation, they remain restricted in applicability. Significant work remains to be done by both domestic legislative systems and international organizations to streamline laws and investigative mechanisms in order to comprehensively combat cybercrimes transcending national borders.
Significance of jurisdictional variability hindering investigations
The paper argues that overcoming the jurisdictional challenges will necessitate much greater cooperation, coordination and alignment between countries. A key takeaway from this study is recognizing the extensive impediments created by the variability, complexity and conflicts inherent in existing legal frameworks for investigating cybercrimes spanning multiple countries. When offenses and perpetrators operate across borders, jurisdictional ambiguity and legal incongruity tend to obstruct, slow down and sometimes even prevent authorities from pursuing justice despite identifying the source and responsibility. By exploiting gaps or misalignments between countries' domestic laws and procedures relating to cyber activities, criminals are able to avoid prosecution and punishment in ways that would not be possible for localized crimes within national boundaries. Resolving these jurisdictional dilemmas is essential for law enforcement and justice systems to effectively police and restrain cybercrimes that increasingly transcend traditional borders.
Reliable mechanisms for swift and streamlined information sharing, evidence collection and criminal transfers across borders will need to be instituted through more expansive multilateral and regional agreements. Binding universal accords and standards covering previously ambiguous transnational cybercrime issues can help harmonize the legal variability that criminals take advantage of currently. Enhanced bilateral mutual legal assistance and joint investigation pacts between nations are also essential to facilitate seamless jurisdictional authority and enforcement, along with training of multinational cybercrime units. Progress is being made but a comprehensive system of aligned cyber laws and cooperative enforcement mechanisms needs to be pursued internationally to avoid jurisdictional gaps.
Potential future research directions
Further research could expand the comparative analysis to cover more cybercrime cases from a wider range of countries beyond mostly western nations examined in this paper. Studying the legislative processes and incentives behind persisting legal divergences can yield insights into means for greater harmonization. Surveying law enforcement officials can also help identify precise investigative obstacles they face due to jurisdictional issues. Examining the particular procedural and evidentiary requirements to enable seamless multijurisdictional investigations is another potential research direction. Comparative evaluation of existing platforms and mechanisms like INTERPOL and Europol for facilitating cross-border coordination can highlight good practices as well as areas for improvement. Analyses of these kinds can inform the design and adoption of specific international agreements, structures and policy frameworks needed to create a cohesive legal architecture for combating cybercrimes without borders.
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