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This article thoroughly analyses international experiences in the legal support of counterintelligence activities, focusing on the approaches of the UKUSA agreement member countries, European Union states and those in Asia. The main aspects of the legal regulation of special services are discussed, including their organisational structure, mechanisms of democratic control, human rights protection and integration into the international legal system. This article also addresses how counterintelligence agencies respond to modern challenges such as cyber threats and transnational crime. Specific recommendations are offered for adapting leading global practices to Ukrainian realities to enhance the effectiveness of counterintelligence activities, ensure national security and comply with international standards.
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Biletskyi et al. (2024) studied this question.
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