[DEADMINCE]

> it's effectively the same

Nope. Not even close.

Practically the GDPR law has no teeth at all because its claim of extraterritorial jurisdiction is nothing but nonsense.

FATCA applies because the US has a carrot or stick to enforce it.

Also, the US law as written is entirely reasonable and doesn't try to claim the law applies to US citizens anywhere in the world.

[shkkmo]

> US law as written is entirely reasonable and doesn't try to claim the law applies to US citizens anywhere in the world.

It absolutely does.

The USA has laws that govern what it's own citizens do abroad like. You aren't allowed to have sex with minors or pay bribes when abroad.

The USA also recently passed a law that allows it to prosecute foreign officials who solicit bribes from USA entities. https://www.ropesgray.com/en/insights/alerts/2023/12/us-cong...

[DEADMINCE]

> It absolutely does.

Absolutely, absolutely, it does not.

The USA law is saying US law applies to US persons wherever they may be in the world.

The EU law is saying EU laws applies to ANYONE in the world if an EU person interacts with them via the internet.

You realize those two things are not the same, right?

[bmicraft]

> The USA law is saying US law applies to US persons wherever they may be in the world.

"The USA law is saying US law applies to ANYONE (bank in this case) in the world if a US person interacts with them."

See how you can put the exact other way without changing the meaning at all?

[DEADMINCE]

I haven't changed the meaning, I simply stated things accurately.

Here, though, you've misstated things inaccurately. You seem to think the points are interchangeable, and the only issue here is semantics. You couldn't be more wrong.

[bmicraft]

If you think I changed the meaning, please tell me what the difference is.

[shkkmo]

Perhaps you should re-read what you wrote. You specifically stated that US law does not apply to US citizens abroad.

In addition, one of my examples specifically allows the prosecution of non-us citizens for their actions abroad toward US citizens. This directly contradicts the point you claim you were making but didn't accurately state.

[DEADMINCE]

You're right, I noticed the inconsistency due to my error, but I had no way to edit and refine it.

I didn't know that it is illegal to pay bribes overseas, and as someone who has traveled extensively and knows it is necessary sometimes, I'm curious how enforced that law actually is. Either way though, that example and the illegal sex one are both US law applying to US persons, not US law applying to non-US persons.

> In addition, one of my examples specifically allows the prosecution of non-us citizens for their actions abroad toward US citizens.

I apologize for not giving this specific point more attention. That law is interesting, and to quote the wiki page, "The law is quite specific in that it is intended to be extraterritorial in nature".

This seems to be the first law of its kind, as unlike the other examples you gave, it explicitly applies worldwide o any foreign officials.

In response to this law I would make two points. One, it hasn't been signed into law yet, and two, this is significantly more narrow in scope than the EU law which applies to anyone running a site that an EU citizen visits.

[shkkmo]

> I'm curious how enforced that law actually is.

Enforcement of the anti-bribery laws isn't really targeted at individuals traveling for fun. It is more meant to stop businesses from bribing officials.

> this is significantly more narrow in scope than the EU law which applies to anyone running a site that an EU citizen visits.

If you are looking for broad scopes, copyright and espionage are both areas where the US asserts it's right to prosecute non-citizens for acts committed outside the country. For specific high-profile examples, look at Kim DotCom and Julian Assange.

In the age of the internet, pretty much every country would like to be able to prosecute non-citizens for acts they commit while outside the country. Hackers, scammers and fraudsters frequently commit crimes against citizens of other countries and the countries where the victims reside have a clear interest in prosecuting those criminals. The limitations of doing so depends on their ability to get that criminal expedited.

With this understanding, the EU laws aren't really any different.

[DEADMINCE]

> Enforcement of the anti-bribery laws isn't really targeted at individuals traveling for fun. It is more meant to stop businesses from bribing officials.

That's fair enough. But then it isn't really comparable, is it? If I host a site for fun in the US that targets as much data as I can about EU citizens and targets EU citizens but doesn't break any US laws, I would still be targeted, right?

Not to mention, bribery is likely illegal in all or at least most countries.

> If you are looking for broad scopes, copyright and espionage are both areas where the US asserts it's right to prosecute non-citizens for acts committed outside the country.

These still are not good examples. Every country has laws to prosecute spies, and copyright has numerous international treaties.

These areas still don't compare, at all, to the EU saying EU law applies to anyone in any country if a EU citizen visits it and the site collects their data and targets them in a way Europe doesn't like.

> With this understanding, the EU laws aren't really any different.

You say in the age of the internet a lot of countries would like to persecute people outside their borders for offenses that take place, to some extent, in their borders.

The thing is, the EU is the first to actually claim the power to do so. The other examples you or anyone else gives just don't map for one reason or another.

[account42]

If the GDPR has no teeth and the EU no stick to enforce it with then US commpanies following it would not be reasonable like you have claimed.

[DEADMINCE]

The GDPR has no teeth to enforce fines outside of its jurisdiction. Which is why it never has despite finding violations.