Collaborative Organization of Transnational Cyber Fraud Crimes: A
Focus on Deepfake Scams
Aijia He
1
, Wenyi Li
2
and Haoyu Wu
3,*
1
Tianjin University of Finance and Economics, Tianjin, China
2
Southwest University of Political Science and Law, Chongqing, China
3
Renmin University of China, Beijing, China
Keywords: Collaborative Organization, Transnational Cyber Fraud Crimes, Deepfake Scams.
Abstract: The abuse of deepfake technology has propelled transnational cyber fraud towards a more technologically
driven and cross-border collaborative form. This paper focuses on the reconfiguration of the transnational
fraud criminal ecosystem by deepfake technology and its governance challenges. By employing a
comprehensive approach that includes literature review, legal hermeneutics analysis, and empirical research
methods , the paper systematically explores the technical characteristics, scale of harm, and governance
dilemmas associated with deepfake technology. The study reveals that deepfakes have broken through
biometric identification barriers, exacerbating the autonomy and precision of fraud schemes. Meanwhile,
international cooperation efforts are constrained by jurisdictional conflicts, legal disparities, and difficulties
in cross-border evidence collection. In light of these findings, the paper proposes governance
recommendations such as restructuring international treaties, optimizing jurisdictional coordination, and
establishing a global information-sharing mechanism. It highlights China's key role in aiding international
fraud governance and rule-setting.
1 INTRODUCTION
With the deep application of artificial intelligence
technology, transnational cyber fraud crimes have
broken through geographical limitations, forming a
new type of criminal ecosystem driven by technology
and cross-border collaboration. Compared with
traditional models, the core difference lies in the
breakthrough of biometric barriers by technological
tools (such as deep fakes and voice cloning), and the
evolution of the criminal process towards autonomy
and precision (Zhang, 2018). Criminal organizations
build transnational criminal networks through
technologies such as cloud database sharing and real-
time translation tools, leading to a doubling of
difficulties in cross-border electronic evidence
collection and judicial cooperation (Qiao, 2018).
The current cross-border network technology-
based scams primarily manifest in four categories of
technical crimes: Firstly, video forgery crimes, such
as the fake video in March 2022 that purportedly
showed Ukrainian President Volodymyr Zelenskyy
"announcing surrender" which spread on Facebook
(Wu, 2023). Secondly, audio forgery crimes, where
voice cloning is used to mimic specific individuals'
voice commands for transfers; thirdly, image forgery
crimes, exemplified by the 2023 Guangzhou Metro
incident where a woman was falsely portrayed using
"AI one-click undressing"; and fourthly, text forgery
crimes, which involve generating false financial
information through natural language processing to
induce transfers.
This article focuses on cross-border scams driven
by deepfake technology, primarily based on three
reasons: Firstly, there has been a significant increase
in the penetration rate of the technology. Deepfake
technology, which started in 2017 with an anonymous
user u/deepfakes on Reddit synthesizing celebrity
pornographic videos, has seen a surge in related
research papers reaching 1,207 by 2019. The open-
source nature of the technology has accelerated its
global spread (Jia, 2021). Secondly, the harm caused
by individual cases has dramatically increased. In
2018, a forged video of Obama attacking Trump
received 2 million views and 50,000 likes, directly
impacting international political security (Long,
He, A., Li, W. and Wu, H.
Collaborative Organization of Transnational Cyber Fraud Crimes: A Focus on Deepfake Scams.
DOI: 10.5220/0014293000004859
Paper published under CC license (CC BY-NC-ND 4.0)
In Proceedings of the 1st International Conference on Politics, Law, and Social Science (ICPLSS 2025), pages 5-12
ISBN: 978-989-758-785-6
Proceedings Copyright © 2026 by SCITEPRESS Science and Technology Publications, Lda.
5
2019). Thirdly, the technology chain has matured.
The emergence of tools like FakeApp and Faceswap
has greatly facilitated the creation of false identities
for carrying out scams (Long, 2024).
As such, deepfake technology has evolved beyond
being a mere tool for criminal activities; it has
become a strategic variable driving the evolution of
the transnational fraud ecosystem. The strong
correlation between its technical characteristics and
the scale of harm it causes makes it a central research
subject in the governance of cybercrime in the digital
age. Based on this, this article will systematically
analyze how deepfake technology is reshaping the
operational paradigms and governance challenges of
transnational fraud, and use this analysis as a
theoretical basis to optimize the transnational
cooperation organizations for combating cyber fraud
crimes.
2 LITERATURE REVIEW
The rapid advancement of internet technology has led
to a surge in transnational cyber fraud, with the
emergence of deepfake technology presenting novel
challenges to global legal frameworks and
international cooperation. Scholars have investigated
deepfake technology from various perspectives,
including its underlying principles, application risks,
legal regulation, and the jurisdictional aspects of
transnational cybercrime. These studies have
provided in-depth analyses of transnational cyber
fraud, offering a rich theoretical foundation and
practical guidance for establishing international cyber
cooperation mechanisms.
Researchers have detailed the generation
principles of deepfake technology, highlighting its
use of autoencoders, generative adversarial networks,
and other deep learning tools to create highly realistic
facial and voice forgeries. The proliferation of open-
source tools and commercial software has
significantly lowered the barrier to entry for this
technology. Despite advancements in deepfake
detection technologies, significant challenges remain,
such as dependence on specific datasets and
generation algorithms, as well as insufficient
detection capabilities for unknown types of
manipulation (Li, 2021). This indicates that the
misuse of deepfake technology poses substantial
harm to society, while existing countermeasures are
demonstrably limited, necessitating more effective
solutions.
Another study delves into the role of deepfake
videos in the context of the Russia-Ukraine conflict,
illustrating the technology's function in the
manipulation of public opinion (He et al., 2023).
The research highlights the targeted nature of these
videos, both in terms of their release timing and
thematic content, which are often designed to counter
each other. This underscores the detrimental impact
of deepfake technology on public perception and
international relations in transnational scenarios,
emphasizing the urgency of addressing this issue.
Scholars have also examined jurisdictional
conflicts in transnational cybercrime, noting that the
characteristics of such crimes—their transnational
nature, virtuality, and scale—challenge traditional
jurisdictional rules based on territorial sovereignty.
Conflicts frequently arise between territorial and
personal jurisdiction in cases of transnational cyber
fraud. To resolve these issues, the international
community should advocate for priority jurisdiction
rules, and nations must actively engage in criminal
justice cooperation. China should also reconstruct its
territorial jurisdiction rules and establish international
collaboration mechanisms, which is crucial for
resolving jurisdictional challenges in transnational
cyber fraud (Su, 2020).
Scholarly analysis has also been conducted on the
current state, collaborative approaches, constraints,
and potential solutions concerning cross-strait
telecommunications fraud. While the incidence of
such crimes has decreased, significant cases persist,
with increasingly sophisticated techniques and a
growing professionalization of criminal activities.
Despite existing cooperation between the two sides,
challenges remain, including incomplete cooperation
agreements and significant differences in judicial
systems (Wang, 2021). Therefore, it is imperative to
further refine cooperation agreements, innovate
police cooperation models, resolve conflicts in
criminal jurisdiction, and establish joint asset
recovery mechanisms to enhance the collaborative
fight against transnational cybercrime.
In conclusion, deepfake technology and
transnational cyber fraud are closely linked and pose
significant threats, yet current countermeasures are
demonstrably insufficient. Future research on the
organizational aspects of combating transnational
cyber fraud should further explore the construction of
more effective international cooperation frameworks.
This involves, on the one hand, defining the
responsibilities of cooperative organizations in terms
of technical prevention, information sharing, and the
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development of detection technologies, considering
the characteristics and harms of deepfake technology.
On the other hand, it necessitates clarifying the role
of cooperative organizations in coordinating national
jurisdictions and promoting judicial cooperation,
based on solutions to jurisdictional conflicts in
transnational cybercrime, thereby providing stronger
support for combating transnational cyber fraud.
3 RESEARCH QUESTIONS
3.1 Empirical Analysis of Existing
International Cooperation
Organizations for the Governance
of Transnational Cyber Fraud
3.1.1 The Current Situation of
Transnational Cyber Fraud Involving
Deepfake Technology
In recent years, deepfake technology, as a new
technology based on deep learning and Generative
Adversarial Networks (GAN) models, has been able
to create highly realistic forgeries of videos, audio,
and images. It can even replace one person's facial
features and voice with those of another scene or
character, thereby producing effects that are
indistinguishable from reality (Jasserand,2024). This
technology first gained attention through social media
platforms in 2017 and quickly sparked widespread
interest. It has not only altered the credibility of
traditional media and personal information but also
brought serious legal and ethical challenges to the
fields of entertainment, politics, and personal privacy
(He, 2023).
With the advancement of technology, the
application scope of deepfakes is continuously
expanding, and its role in fraudulent activities is
becoming increasingly significant. According to a
report released by Dutch company Deeptrace, as of
September 2019, the number of deepfake videos
globally had reached 15,000, a stark contrast to the
less than 8,000 videos in December 2018, indicating
a rapid growth in the application of this technology.
Especially in 2017, when the anonymous online user
u/deepfakes began uploading and widely
disseminating related content, it enabled non-
professionals to quickly produce fake videos with the
help of open-source code (He, 2023). The
proliferation of this technology not only poses a threat
to the entertainment industry and the reputation of
public figures but is also being exploited by criminals
for financial fraud, political propaganda, and the
spread of misinformation on social networks,
gradually evolving into a new trouble that impacts
cybersecurity and social order.
In this context, the three case examples presented
in Table 1 vividly illustrate the application of
deepfake technology in fraudulent activities and the
challenges in its governance.
Table 1. The case summary.
Case Name Time Summary Challenges in Governance
vZAO software
incident
August 2019
China's Momo company has launched a
"one-click face swap" application, which
has sparked controversy due to excessive
requests for personal information and
data leakage risks in its user agreement.
The technology could potentially be used
for creating fake videos for scams.
Balancing privacy protection with
technological innovation is challenging;
legal regulation lags behind, and there is
a gap in preventing the misuse of
technology.
Balancing privacy protection
with technological innovation is
challenging; legal supervision
lags behind, and there is a gap in
preventing the misuse of
technology.
Ukraine-Russia
conflict fake video
March 2022
Using GAN technology to forge videos
of Ukrainian and Russian leaders making
speeches, spreading misinformation
through social media, and misleading the
The spread of misinformation is
rapid and its source is difficult to
trace; there is a lack of
international joint governance
Collaborative Organization of Transnational Cyber Fraud Crimes: A Focus on Deepfake Scams
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Case Name Time Summary Challenges in Governance
global public and policymakers'
understanding of the conflict.
mechanisms, and cross-border
cooperation is complex.
Deepfake
pornographic video
Since 2017
Anonymous users utilize deepfake
technology to replace the faces of
celebrities in pornographic videos for the
purpose of blackmail or illegal profit,
with the content being disseminated
across borders through the dark web.
Regulating anonymous networks
(such as the dark web) is
challenging; international law
enforcement cooperation is
inefficient, and technical
evidence collection is complex.
These cases demonstrate that scammers,
leveraging deepfake technology, significantly
enhance their deceptive effectiveness by generating
highly realistic audio and video content through deep
learning and GANs, in conjunction with social
engineering tactics and rapid dissemination channels
such as social media. The target groups are both broad
and specific: the general public is susceptible due to
insufficient technical discernment, while high-value
targets such as celebrities and public figures are
prioritized due to their social status and public
attention. Simultaneously, scammers often exploit the
anonymity of the internet and the open-source nature
of technology for international collaboration, thereby
multiplying the difficulty of tracking and governance
efforts.
Specifically, the challenges in governance mainly
manifest in the following aspects: Firstly, the high
level of realism in deepfake content makes it difficult
for ordinary users and traditional detection methods
to distinguish between truth and falsehood (Yang,
2024). Even when informed beforehand about the
possibility of forgery, a large number of people may
still misjudge its authenticity. Secondly, the current
legal system lacks specific punitive measures for
deepfake scams, and the differences in laws among
countries and inadequate law enforcement
cooperation further exacerbate the difficulty of
governance. Additionally, the rapid dissemination of
false information on the internet and social media
means that once published, misinformation spreads
quickly. For example, false videos about the Russia-
Ukraine conflict have had a significant impact on
global public opinion in a short time, making it
difficult for regulatory authorities to respond
promptly. Finally, the public's insufficient
understanding of deepfake technology provides
opportunities for fraudulent activities, and the risk of
future scams may further increase (He, 2023).
3.1.2 Current Cooperation Organizations in
Governing Transnational Cyber Fraud
Crimes
The current international community's cooperation
organizations in governing transnational cybercrimes
primarily include INTERPOL and Europol.
INTERPOL provides member states with information
sharing and technical support through global police
communication services, crime intelligence centers,
and specialized databases, and assists in the pursuit of
transnational criminals through Red Notices and Blue
Notices. However, its operational effectiveness is
limited by factors such as voluntary cooperation from
member states, insufficient funding, and trust crises
(Yang, 2024). Europol effectively combats
transnational organized crime and cybercrime
through information sharing systems, joint operations,
and professional support, but its operations also face
challenges such as resource disparities among
member states, inconsistent legal systems, and
political interference (Shang, 2023). Bilateral and
multilateral cooperation demonstrates high efficiency
in coordinating judicial resources and clarifying
jurisdiction, but differences in legal systems, conflicts
of national interests, and the imperfection of
international criminal judicial assistance mechanisms
limit its practical effects.
Overall, although these cooperation
organizations have achieved certain results in
combating transnational cybercrimes, further
improvement in governance effectiveness is still
needed by strengthening member state collaboration,
improving the international legal framework, and
promoting the formulation of global conventions.
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3.1.3 Challenges for Cooperation
Organizations Against Transnational
Cyber Fraud
Jurisdictional Conflict. A primary challenge for
cooperation organizations in combating transnational
cyber fraud is jurisdictional conflict. This conflict
manifests primarily as overlaps between national
territorial jurisdictions, intersections between
territorial and personal jurisdictions, and
contradictions between protective jurisdiction and
territorial jurisdiction. Territorial jurisdictional
conflicts are particularly prominent in cyber fraud, as
the location of the crime's consequences may involve
multiple countries. The widespread adoption of broad
territorial jurisdictional standards by various nations
complicates jurisdictional claims. Although scholars
have proposed limiting the scope of territorial
jurisdiction by increasing the connecting factors for
determining the crime's location or by referencing the
"minimum contacts"these conflicts remain difficult
to fully resolve in practice. Furthermore, conflicts
between territorial and personal jurisdiction are
common in cyber fraud, especially when perpetrators
refuse to return to their home countries. While
criminal justice cooperation through extradition and
repatriation can partially alleviate these conflicts,
differences in substantive laws among countries still
provide opportunities for perpetrators to evade legal
responsibility. Protective jurisdiction, although
significant in combating cybercrimes that endanger
national security from abroad, has its role weakened
by its intersection with territorial jurisdiction, and the
coordination effects of the reasonableness principle
are also relatively limited (Su, 2020).
Structural Misalignment Dilemma in Cybercrime
Legislation. The structural misalignment in
cybercrime legislation exacerbates the challenges in
governing transnational cyber fraud. Despite the
increasing transnational nature of cybercrimes, the
international community has yet to establish a unified
global convention. Existing regional treaties, such as
the Budapest Convention, are limited by their
membership scope and high entry barriers, failing to
meet global demands. Some countries advocate for
utilizing the United Nations Convention against
Transnational Organized Crime, but its provisions are
insufficient to address the specific characteristics of
cybercrimes. Countries like China and Russia have
called for the formulation of a global convention
within the UN framework, but this has been resisted
by some signatories of the Budapest Convention,
leading to increased fragmentation of rules.
Simultaneously, the United States, through unilateral
actions like the CLOUD Act, attempts to establish a
"network" for cross-border electronic evidence
retrieval, further intensifying the inconsistencies in
regulations. Although the UN has prioritized
combating cybercrime, negotiations for a global
convention are progressing slowly, and international
cooperation in cybercrime governance still faces the
challenge of structural misalignment in legislation
(Wu, 2020).
Challenges in the Collection and Conversion of
Cross-Border Evidence.
First, the international
judicial assistance mechanism suffers from low
efficiency. Taking the "Zhang Kaimin
Telecommunication Fraud Case" as an example,
although Kenya transferred physical evidence to
China, the extraction and identification of electronic
evidence was time-consuming, increasing the risk of
data tampering or loss. Furthermore, China has only
signed bilateral judicial assistance treaties with 86
countries, which have limited coverage, and some
treaty contents are not perfect, making it difficult to
carry out effective cooperation in countries without
treaties. Complex multi-agency coordination and
lengthy procedures further delay case investigation,
forming an "inverted U-shaped" efficiency bottleneck.
Second, the role conflict of network service
providers. As shown in the "Gao's Shared Bicycle
Accident Case," enterprises need to cooperate with
law enforcement while also bearing the obligation of
protecting user data. Due to the lack of clear legal
norms, enterprises often weigh compliance risks and
respond passively, even refusing to provide key
evidence. This collaborative dilemma not only delays
the progress of the investigation but may also lead to
the inability to solve the case due to the lack of
evidence.
Finally, unilateral cross-border evidence
collection presents conflicts between sovereignty and
privacy. In the "Hu Zijia Online Gambling Case,"
Chinese police were deadlocked because they could
not directly obtain data from overseas servers.
Although unilateral evidence collection is efficient, it
may infringe on the network sovereignty of other
countries and excessively collect irrelevant personal
data, violating the principle of proportionality. For
example, when evidence is obtained across borders
through technical means, it is easy to involve the
privacy of third parties other than the suspects,
Collaborative Organization of Transnational Cyber Fraud Crimes: A Focus on Deepfake Scams
9
triggering legal disputes (Chen, 2023).
The Dilemma Between Intelligence Sharing and
Data Privacy Protection. In the governance of
transnational cyber fraud, striking a balance between
intelligence sharing and data privacy protection
presents a significant challenge. Intelligence sharing
is crucial for combating transnational cyber fraud;
efficient information exchange enables law
enforcement agencies to more accurately identify,
track, and combat criminal activities. However, data
privacy protection is equally important, especially in
cross-border data flows, where personal privacy and
data security face considerable risks. Existing
mechanisms, such as the European Union's General
Data Protection Regulation (GDPR), China's
Cybersecurity Law, and India's Personal Data
Protection Bill, attempt to balance intelligence
sharing and privacy protection through data access
controls, encryption technologies, and legal
constraints. Nevertheless, these mechanisms still face
serious challenges. Differences in legal systems,
privacy protection standards, and technical
capabilities among countries make it difficult to fully
reconcile the conflicts between privacy and security
in cross-border data flows. For example, some
countries, based on national security or law
enforcement needs, require access to data from other
countries, which may conflict with the privacy
protection laws of the data source country.
Furthermore, technical vulnerabilities and the risk of
cyberattacks exacerbate the dilemma of data security
and privacy protection. Therefore, despite the
achievements of existing mechanisms, further
optimization of intelligence sharing mechanisms is
needed through enhanced international cooperation,
unified data protection standards, and improved
technical security to achieve more effective
governance of transnational cyber fraud (Wang,
2020).
3.2 Optimization of Cooperative
Organization of Transnational
Fraud Governance
3.2.1 Push for International Treaties,
Legislative Systems, and Optimized
Jurisdiction
Under the framework of the United Nations,
international cooperation organizations should
actively promote countries to reach consensus on the
governance of cybercrimes, formulate a Convention
on the Jurisdiction of Transnational Cybercrimes,
fully take into account the interests and needs of
different countries, balance the differences between
developed and developing countries, lower the
threshold for accession like the Budapest Convention,
and expand the scope of application of the
Convention. The international community should
jointly resist unilateral actions, advocate bilateral
cooperation and regional law enforcement, set up
transnational joint investigation coordination centers,
achieve efficient transfer of jurisdiction through
regional mutual legal assistance agreements,
strengthen coordination of legislation on cyber crimes,
and strengthen the construction and refinement of
extradition treaties and treaties on criminal judicial
cooperation.
Secondly, efforts should be made to optimize
jurisdiction on the basis of the United Nations
Convention against Transnational Organized Crime.
Countries should consult together at the international
level to formulate unified, clear and more operational
jurisdiction standards, mainly based on the principle
of limited expansion of territorial jurisdiction, and
apply the principle of jurisdiction of ownership and
protection respectively for different transnational
cyber fraud crimes, supplemented by the principle of
priority admissibility (Wang&Liu, 2024).When a
number of countries claim territorial jurisdiction, they
should adopt the double standard of "place of main
crime + place of material damage result" to reduce the
uncertainty of law application. At the same time, they
can learn from the asset recovery mechanism of the
United Nations Convention against Corruption,
establish a system of sharing the proceeds of cross-
border crimes, and solve the practical contradiction
between protective jurisdiction and territorial
jurisdiction.
3.2.2 Innovate Cross-Border Forensics
Models and Strengthen Technology
Empowerment
First of all, big data policing is the foundation of
modern development. China can use big data
technology to analyze and mine criminal clues, build
a "blockchain + smart contract" electronic evidence
storage system, and solve the problem of easy
tampering of electronic data. Second, establish a fast
track for cross-border forensics, formulate cross-
border emergency forensics rules, enable a "green
channel" for cases involving major public security,
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and establish a judicial big data analysis center to use
AI technology to automatically convert forms of
evidence in different jurisdictions, such as converting
"hearsay evidence" in the common law system into
"written testimony" in the civil law system. At the
same time, China can provide technical support in
transnational cybercrimes, share technical tools and
databases related to cybercrime governance with
other countries, develop new cloud control, and carry
out regional cooperation by relying on computers, the
Internet and cloud computing. China can also provide
its self-developed network monitoring software and
malicious code analysis tools to countries in need. To
help them improve their ability to monitor and
analyze cyber crimes, and promote a more effective
governance mechanism for transnational cyber fraud
crimes.
3.2.3 Establish a Privacy-Focused Intel
Sharing Mech to Build a Secure Data
Ecology
In terms of cross-border cooperation, the strategy of
sharing threat intelligence is at the core of enhancing
cooperation. Real-time information sharing enables
countries and organizations to detect and respond to
cyber threats more effectively. Platforms such as the
European Union's Cybersecurity Agency (ENISA)
and the US Cybersecurity and Infrastructure Security
Agency (CISA) have demonstrated the value of
collective intelligence-sharing mechanisms in
reducing risk (Qudus, 2025). China can set up
regional data security alliances to build a global data
governance community that balances security and
efficiency. At the same time, China can publicize its
experience and propositions on cybercrime
governance by holding international conferences and
participating in international forums, encourage
cooperation among countries on the basis of equality
and mutual trust, and promote the establishment of a
fair and reasonable international cybercrime
governance system.
4 CONCLUSION
Through a systematic analysis of the application of
Deepfake technology in transnational cyber fraud and
its governance challenges, this study reveals the key
role of deepfake technology in promoting the
ecological upgrading of transnational fraud crime.
The study found that the abuse of deepfake
technology has evolved from a single criminal tool to
a strategic variable driving the upgrade of
transnational fraud ecology, and the strong correlation
between its technical characteristics and the scale of
harm makes it difficult for traditional legal
framework and governance measures to effectively
deal with it. The governance of transnational cyber
fraud crimes faces multiple challenges, including
jurisdictional conflicts, differences in legal systems,
difficulties in cross-border forensics, and the balance
between intelligence sharing and data privacy
protection. Although international cooperation
organizations such as Interpol and Europol have
achieved some success in combating transnational
cybercrimes, their operational effectiveness is still
limited by factors such as voluntary cooperation
among member states and the disunity of legal
systems. This paper puts forward governance
suggestions such as reconstructing international
treaties, optimizing jurisdiction, strengthening
cooperation among international organizations, and
building information sharing mechanisms, and
emphasizes China's positive role in promoting the
Belt and Road Initiative, participating in the
formulation of international rules on cybercrime
governance, and providing technical assistance.
However, this study also has some limitations,
such as the data source mainly relies on public
literature and cases, and lacks first-hand empirical
data; The legal analysis is limited by the differences
in the legal systems of different countries, and it is
difficult to fully cover the application of law in
transnational cases; in addition, deep counterfeiting
technology is developing rapidly, and this paper may
not be able to fully cover the latest technological
progress and criminal methods. Future studies should
strengthen the collection of empirical data, deepen the
comparative analysis of transnational laws, and pay
close attention to the technological frontier to propose
more forward-looking governance strategies.
AUTHORS CONTRIBUTION
All the authors contributed equally and their names
were listed in alphabetical order.
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