This research involved a comparative analysis of penal laws addressing TGBV (Technology-facilitated Gender-Based Violence) across different jurisdictions. The primary objective was to elucidate the role and limitations of criminal law in combatting TGBV within a society.The research specifically examined the penal laws of South Korea, the United States, and Singapore. Mainly, the penal laws of the states in the United States, the laws on TGBV enacted or revised as a part of the “Nth Room Prevention Law” in South Korea, and the Protection from Harassment Act of Singapore, were compared in terms of their scope, benefits, and criticisms. Through this examination, this research identified several unique challenges associated with penalizing TGBV.One major challenge lies in integrating laws addressing TGBV with the existing legal framework of the respective jurisdictions. For example, in many states in the United States, TGBV-related offenses are considered violations of privacy rather than sex crimes. However, in South Korea, laws on TGBV were included as part of the existing sex crime legislation. The research, through comparison of these laws, highlighted the implications of categorizing TGBV under sex crime laws, including the need to review the protected interest for sex crimes and reconcile differences between existing sex crimes, which require physical contact, and TGBV-related offenses without physical contact.Another challenge involves defining the scope of criminal punishment for TGBV. While Singapore and South Korea penalize a broad range of acts constituting TGBV, including various forms of gender-based online harassment, the state penal laws of the United States predominantly focus on revenge porn and image-based abuse. The research revealed the importance of considering values such as free speech rights and effectiveness when expanding criminal sanctions for TGBV prevention. Additionally, the penalty for TGBV offenses needs to be balanced and weighed against relevant existing legislation on sex crime or privacy.Finally, the research emphasizes the significant role criminal law plays in addressing TGBV in society while also acknowledging its limitations in supporting victims. Therefore, in addition to providing proper criminal sanctions, it is crucial to offer civil remedies, especially for the removal of victim's sexual images and videos disseminated online.

 This research compared penal laws related to deepfake technology across various jurisdictions to identify optimal legal solutions for managing AI-facilitated crimes.  Some jurisdictions, such as South Korea and Virginia in the United States, penalize creating and distributing sexual deepfakes. However, the appropriateness of the penalties, given the grave harm to the victims, is still debated. Other jurisdictions, like Texas, penalize using deepfake technology to spread false information about public elections or politics. This has gained particular significance because deepfake videos, realistically portraying events that never occurred, can easily allow people to believe and spread false information. Analyzing penal laws related to deepfake technology reveals the challenges of developing legal frameworks that can effectively address the rapidly evolving landscape of AI-facilitated crimes.  Based on the review of the laws, three legislative recommendations are made, including (1) a periodic review of the development of socially undesirable use of AI, (2) an examination of legal frameworks that govern conventional offenses, such as sexual offenses and fraud, to ensure that they can flexibly address new types of AI-facilitated crimes, and (3) a reassessment of the appropriateness of penalties for existing laws on AI crimes.