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Introduction:

This Op-ed sheds light on the perspectives of the US and China regarding cyber espionage. Additionally, it seeks to analyze China's response to the US accusation regarding cyber espionage.

What is Cyber espionage?

Cyber espionage or cyber spying is the act of obtaining personal, sensitive, or proprietary information from individuals without their knowledge or consent. In an increasingly transparent and technological society, the ability to control the private information an individual reveals on the Internet and the ability of others to access that information are a growing concern. This includes storage and retrieval of e-mail by third parties, social media, search engines, data mining, GPS tracking, the explosion of smartphone usage, and many other technology considerations. In the age of big data, there is a growing concern for privacy issues surrounding the storage and misuse of personal data and non-consensual mining of private information by companies, criminals, and governments. 

Cyber espionage aims for economic, political, and technological gain. Fox example Stuxnet (2010) cyber-attack by the US and its allies Israel against Iran’s Nuclear facilities. Three espionage tools were discovered connected to Stuxnet, such as Gauss, FLAME and DuQu, for stealing data such as passwords, screenshots, Bluetooth, Skype functions, etc.

Cyber espionage is one of the most significant and intriguing international challenges globally. Many nations and international bodies, such as the US and China, have created their definitions and have always struggled over cyber espionage norms.

The US Perspective

In 2009, US officials (along with other allied countries) mentioned that cyber espionage was acceptable if it safeguarded national security, although they condemned economically motivated cyber espionage. Even the Director of National Intelligence said in 2013 that foreign intelligence capabilities cannot steal foreign companies' trade secrets to benefit their firms. This stance is consistent with the Economic Espionage Act (EEA) of 1996, particularly Section 1831, which prohibits economic espionage. This includes the theft of a trade secret that "will benefit any foreign government, foreign agent or foreign instrumentality. 

Second, the US advocates for cybersecurity market standards and strongly opposes transferring personal data extracted from the US Office of Personnel Management (OPM) to cybercrime markets. Furthermore, China has been reported to sell OPM data on illicit markets. It became a grave concern for the US government when the Chinese government managed to acquire sensitive details of 22.1 million US government workers through cyber intrusions in 2014.

Third, Cyber-espionage is acceptable unless it’s utilized for Doxing, which involves disclosing personal information about someone online without their consent and using it as a tool for political influence operations. However, Western academics and scholars have endeavoured to distinguish between doxing and whistleblowing. They argue that whistleblowing, exemplified by events like the Snowden Leaks and Vault 7 disclosures, serves the interests of US citizens. In the US, being regarded as an open society, certain disclosures are not promoted but rather required by mandate.

Fourth, the US argues that there is no cyber espionage against critical infrastructure during peacetime. According to the US, there are 16 critical infrastructure sectors, including chemical, nuclear, energy, defence, food, water, and so on. These sectors are considered essential to the US, and any disruption or harm would impact security, national public health and national economic security.

The US concern regarding China’s cyber espionage

According to James Lewis (a senior vice president at the Center for US-China Economic and Security Review Commission), the US faces losses between $ 20 billion and $30 billion annually due to China’s cyberespionage. The 2018 U.S. Trade Representative (USTR) Section 301 report highlighted instances, where the Chinese government and executives from Chinese companies engaged in clandestine cyber intrusions to obtaining commercially valuable information from the U.S. businesses, such as in 2018 where officials from China’s Ministry of State Security, stole trade from General Electric aviation and other aerospace companies.    

China's response to the US accusations of cyber espionage

China's perspective on cyber espionage is outlined by its 2014 anti-espionage law, which was revised in 2023. Article 1 of this legislation is formulated to prevent, halt, and punish espionage actions to maintain national security. Article 4 addresses the act of espionage and does not differentiate between state-sponsored cyber espionage for economic purposes and state-sponsored cyber espionage for national security purposes. However, China doesn't make a clear difference between government-to-government hacking (spying) and government-to-corporate sector hacking, unlike the US. This distinction is less apparent in China due to its strong state-owned enterprise (SOE) sector. However, military spying is considered part of the national interest in the US, while corporate spying is considered a crime.

China asserts that the US has established cyber norms concerning cyber espionage to normalize public attribution as acceptable conduct. This is achieved by targeting China for cyber operations, imposing sanctions on accused Chinese individuals, and making political accusations, such as blaming China and Russia for meddling in US elections. Despite all this, Washington D.C has never taken responsibility for the infamous Flame and Stuxnet cyber operations, which were widely recognized as part of a broader collaborative initiative known as Operation Olympic Games between the US and Israel. Additionally, the US takes the lead in surveillance activities conducted against China, Russia, German Chancellor Angela Merkel, the United Nations (UN) Secretary-General, and several French presidents. Surveillance programs such as Irritant Horn, Stellar Wind, Bvp47, the Hive, and PRISM are recognized as tools used by the US to monitor both allies and adversaries to maintain global hegemony.

China urges the US to cease its smear campaign associated with Volt Typhoon’s cyberattack for cyber espionage, citing the publication of a report titled “Volt Typhoon: A Conspiratorial Swindling Campaign Targets with U.S. Congress and Taxpayers Conducted by U.S. Intelligence Community” by China's National Computer Virus Emergency Response Centre and the 360 Digital Security Group on 15 April. According to the report, 'Volt Typhoon' is a ransomware cyber criminal group self-identified as the 'Dark Power' and is not affiliated with any state or region. Multiple cybersecurity authorities in the US collaborated to fabricate this story just for more budgets from Congress. In the meantime, Microsoft and other U.S. cybersecurity firms are seeking more big contracts from US cybersecurity authorities. The reality behind “Volt Typhoon '' is a conspiratorial swindling campaign to achieve two objectives by amplifying the "China threat theory" and cheating money from the U.S. Congress and taxpayers.

Beijing condemned the US claims of cyber espionage without any solid evidence. China also blames the US for economic espionage by citing the European Parliament report that the National Security Agency (NSA) was also involved in assisting Boeing in beating Airbus for a multi-billion dollar contract. Furthermore, Brazilian President Dilma Rousseff also accused the US authorities of spying against the state-owned oil company “Petrobras” for economic reasons.

Conclusion

In 2015, the US and China marked a milestone as both President Xi Jinping and Barack Obama signed an agreement, committing that neither country's government would conduct or knowingly support cyber-enabled theft of trade secrets, intellectual property, or other confidential business information to grant competitive advantages to firms or commercial sectors. However, the China Cybersecurity Industry Alliance (CCIA) published a report titled 'US Threats and Sabotage to the Security and Development of Global Cyberspace' in 2024, highlighting the US escalating cyber-attack and espionage activities against China and other nations. Additionally, there has been a considerable increase in the volume and sophistication of Chinese hacking since 2016. According to a survey by the Center for International and Strategic Studies, out of 224 cyber espionage incidents reported since 2000, 69% occurred after Xi assumed office. Therefore, China and the US must address cybersecurity issues through dialogue and cooperation, utilizing bilateral and multilateral agreements.

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Introduction

Misinformation spreads differently with respect to different host environments, making localised cultural narratives and practices major factors in how an individual deals with it when presented in a certain place and to a certain group. In the digital age, with time-sensitive data, an overload of information creates a lot of noise which makes it harder to make informed decisions. There are also cases where customary beliefs, biases, and cultural narratives are presented in ways that are untrue. These instances often include misinformation related to health and superstitions, historical distortions, and natural disasters and myths. Such narratives, when shared on social media, can lead to widespread misconceptions and even harmful behaviours. For example, it may also include misinformation that goes against scientific consensus or misinformation that contradicts simple, objectively true facts. In such ambiguous situations, there is a higher probability of people falling back on patterns in determining what information is right or wrong. Here, cultural narratives and cognitive biases come into play.

Misinformation and Cultural Narratives

Cultural narratives include deep-seated cultural beliefs, folklore, and national myths. These narratives can also be used to manipulate public opinion as political and social groups often leverage them to proceed with their agenda. Lack of digital literacy and increasing information online along with social media platforms and their focus on generating algorithms for engagement aids this process. The consequences can even prove to be fatal.

During COVID-19, false claims targeted certain groups as being virus spreaders fueled stigmatisation and eroded trust. Similarly, vaccine misinformation, rooted in cultural fears, spurred hesitancy and outbreaks. Beyond health, manipulated narratives about parts of history are spread depending on the sentiments of the people. These instances exploit emotional and cultural sensitivities, emphasizing the urgent need for media literacy and awareness to counter their harmful effects.

CyberPeace Recommendations

As cultural narratives may lead to knowingly or unknowingly spreading misinformation on social media platforms, netizens must consider preventive measures that can help them build resilience against any biased misinformation they may encounter. The social media platforms must also develop strategies to counter such types of misinformation.

• Digital and Information Literacy: Netizens must encourage developing digital and information literacy in a time of information overload on social media platforms. 
• The Role Of Media: The media outlets can play an active role, by strictly providing fact-based information and not feeding into narratives to garner eyeballs. Social media platforms also need to be careful while creating algorithms focused on consistent engagement.
• Community Fact-Checking: As localised information prevails in such cases, owing to the time-sensitive nature, immediate debunking of precarious information by authorities at the ground level is encouraged.
• Scientifically Correct Information: Starting early and addressing myths and biases through factual and scientifically correct information is also encouraged. 

Conclusion

Cultural narratives are an ingrained part of society, and they might affect how misinformation spreads and what we end up believing. Acknowledging this process and taking counter measures will allow us to move further and take steps for intervention regarding tackling the spread of misinformation specifically aided by cultural narratives. Efforts to raise awareness and educate the public to seek sound information, practice verification checks, and visit official channels are of the utmost importance.

References

• https://www.icf.com/insights/cybersecurity/developing-effective-responses-to-fake-new
• https://www.dw.com/en/india-fake-news-problem-fueled-by-digital-illiteracy/a-56746776
• https://www.apa.org/topics/journalism-facts/how-why-misinformation-spreads

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Introduction

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Law grows by confronting its absences, it heals through its own gaps. States often find themselves navigating a shared frontier without a mutual guide or lines of law in an era of expanding digital boundaries and growing cyber damages. The United Nations General Assembly ratified the United Nations Convention against Cybercrime on December 24, 2024, and more than sixty governments were in attendance in the signing ceremony on 24th & 25th October this year, marking a moment of institutional regeneration and global commitment. 

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A new Lexicon for Global Order

The old liberal order is being strained by growing nationalism, economic fracturing, populism, and great-power competition as often emphasised in the works of scholars like G. John Iken berry and John Mearsheimer. Multilateral arrangements become more brittle in such circumstances. Therefore, the new cybercrimes convention represents not only a legal tool but also a resurgence of international promise, a significant win for collective governance in an uncertain time. It serves as a reminder that institutions can be rebuilt even after they have been damaged. 

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In Discussion: The Fabric of the Digital Polis

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The digital sphere has become a contentious area. On the one hand, the US and its allies support stakeholder governance, robust individual rights, and open data flows. On the other hand, nations like China and Russia describe a “post-liberal cyber order” based on state mediation, heavily regulated flows, and sovereignty. Instead of focusing on ideological dichotomies, India, which is positioned as both a rising power and a voice of the Global South, has offered a viewpoint based on supply-chain security, data localisation, and capacity creation. Thus, rather than being merely a regulation, the treaty arises from a framework of strategic recalibration. 

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What Changed & Why it Matters

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There have been regional cybercrime accords up to this point, such as the Budapest Convention. The goal of this new international convention, which is accessible to all UN members, is to standardise definitions, evidence sharing and investigation instruments. 72 states signed the Hanoi signature event in October, 2025, demonstrating an unparalleled level of scope and determination. In addition to establishing structures for cooperative investigations, extradition, and the sharing of electronic evidence, it requires signatories to criminalise acts such as fraud, unlawful access to systems, data interference, and online child exploitation. 

For the first time, a legally obligatory global architecture aims to harmonise cross-border evidence flows, mutual legal assistance, and national procedural laws. Cybercrime offers genuine promise for community defence at a time when it is no longer incidental but existential, attacks on hospitals, schools and infrastructure are now common, according to the Global Observatory.

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Holding the Line: India’s Deliberate Path in the Age of Cyber Multilateralism 

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India takes a contemplative rather than a reluctant stance towards the UN Cybercrime Treaty. Though it played an active role during the drafting sessions and lent its voice to the shaping of global cyber norms, New Delhi is yet to sign the convention. Subtle but intentional, the reluctance suggests a more comprehensive reflection, an evaluation of how international obligations correspond with domestic constitutional protections, especially the right to privacy upheld by the Supreme Court in Puttaswamy v. UOI (2017). 

Prudence is the reason for this halt. Policy circles speculate that the government is still assessing the treaty’s consequences for national data protection, surveillance regimes, and territorial sovereignty. Officials have not provided explicit justifications for India’s refusal to join. India’s position has frequently been characterised by striking a careful balance between digital sovereignty and taking part in cooperative international regimes. In earlier negotiations, India had even proposed including clauses to penalise “offensive messages” on social media, echoing the erstwhile Section 66A of the IT Act, 2000, but the suggestion found little international traction. 

Advocates for digital rights such as Raman Jit Singh Chima of Access Now have warned that ensuring that the treaty’s implementation upholds constitutional privacy principles may be necessary for India to eventually endorse it. He contends that the treaty’s wording might not entirely meet India’s legal requirements in the absence of such voluntary pledges. 

UN Secretary-General Antonio Guterres praised the agreement as “a powerful, legally binding instrument to strengthen our collective defences against “cybercrime” during its signing in Hanoi. The issue for India is to make sure that multilateral collaboration develops in accordance with constitutional values rather than to reject that vision. Therefore, the path forward is one of assertion rather than absence, careful march towards a cyber future that protects freedom and sovereignty. 

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Sources: 

• https://www.icwa.in/show_content.php?lang=1&level=3&ls_id=12244&lid=7470 
• https://www.medianama.com/2025/10/223-72-nations-un-first-cybercrime-treaty-india-abstains-privacy/ ‍
• https://therecord.media/us-declines-signing-cybercrime-treaty