COMPARATIVE ANALYSIS IN COMBATING CYBERCRIME: EXPERIENCE OF ROMAN-GERMANIC AND ANGLO-SAXON LEGAL SYSTEMS AND MODERNIZATION OF THE LEGISLATION OF UZBEKISTAN
Keywords:
cybercrime, digital forensics, Roman-Germanic law, Anglo Saxon law, CFAA, StGB, digital evidence, Chain of Custody, jurisdiction, Budapest Convention, legislation of Uzbekistan, metadata, hash-sum.Abstract
This monographic scientific article provides an in-depth analysis of
the legal mechanisms for combating cybercrime in the global digital space, focusing on the world's two leading legal families — the Roman-Germanic (Civil Law) and AngloSaxon (Common Law) systems. The study explores the qualification of cyber-space offenses, the problems of establishing jurisdiction in virtual space, the international standards for evaluating digital evidence, and the 'Chain of Custody' principles. Specifically, it compares the US CFAA, the UK Computer Misuse Act, and the German Strafgesetzbuch (StGB) provisions, highlighting their strengths and shortcomings. The
article consists of over 3000 words and covers cyber-forensics, data preservation chain, and digital sovereignty issues. Finally, strategic recommendations are provided for modernizing the national legislation of Uzbekistan.
