AI governance and data privacy in cross-border contexts: A comparative analysis of regulatory frameworks

Abstract

The implications of artificial intelligence (AI) in cross-border relations include major issues regarding data privacy, jurisdiction, regulatory consistency and accountability. This paper includes a comparative analysis of AI frameworks in four jurisdictions including the US, the European Union (EU), Singapore and the United Arab Emirates (UAE). The paper also analyses the regional AI governance frameworks and cross-border AI governance mechanisms of these regions and their effectiveness in addressing AI-related challenges. This review has gathered data from published articles from different peer-reviewed journals and popular databases including Web of Science, IEEE Springer, Scopus and Google Scholar, from the past six years. The study brings into focus the differences in AI governance approaches, compliance challenges and gaps in privacy protection across these regions, highlighting the importance of harmonised standards, transparency, accountability and ethical considerations in AI deployment. The potential solution includes mutual recognition agreements (MRAs), whereby nations reciprocate one another’s standards of AI regulation if they share similar levels of privacy and risk management. Matching frameworks to the Organisation for Economic Co-operation and Development (OECD) AI Principles, with its focus on transparency, fairness and accountability, can support promoting uniform global standards. This article is also included in The Business & Management Collection which can be accessed at https://hstalks.com/business/.