<![CDATA[The development of information and communication technology has increased the complexity of transnational cybercrime, posing new challenges for the criminal justice system in ensuring effective law enforcement. Although Indonesia has regulated various forms of cybercrime through the Electronic Information and Transactions Law and its amendments, the effective implementation of these regulations still faces various obstacles, particularly related to legal harmonization, enforcement capacity, and international cooperation. This study aims to analyze the characteristics of the cybercriminal legal systems in Indonesia, the United States, and Singapore, identify similarities and differences, evaluate the effectiveness of their implementation, and formulate a reform model relevant to Indonesia. The study uses a normative legal method with a comparative law approach, through an analysis of legislation, legal doctrine, court decisions, and national and international scientific literature. The results show that the United States implements a federal approach that emphasizes investigative capacity and inter-agency coordination through the Computer Fraud and Abuse Act, while Singapore prioritizes an integrated and responsive regulatory model through the Computer Misuse Act and a strong national cybersecurity strategy. Indonesia has a relatively comprehensive regulatory framework, but still faces challenges in enforcement, institutional coordination, and adaptation to evolving digital crime modes. The novelty of this research lies in the formulation of a cybercriminal law enforcement reform model based on regulatory integration, institutional capacity building, and increased international cooperation. These reforms are expected to improve the effectiveness of Indonesia's cybercriminal legal system in addressing the dynamics of global digital crime.]]>
