Study Objective: This study examines how criminal law addresses legal evasion without eroding the principle of legality, and how such responses can protect the interests of vulnerable populations.Method/Approach: This study is a legal research that uses both statute and comparative approaches. comparing Indonesia's fragmented sectoral regime with Hungary's functional combination of anti-tax-abuse, budget-fraud, welfare-fraud, oversight-responsibility, and asset-oriented enforcement.Novelty: This study uses vulnerability as an analytical criterion for identifying the public interests that suffer disproportionate consequences when complex economic crime diverts public resources or distorts market access.Findings: Indonesia should not criminalize all forms of formal compliance that undermine the purpose of regulation. Such a formula w7ould be uncertain and risk turning legitimate administrative disputes into criminal cases. A more defensible approach is a two-tier model. Administrative anti-abuse measures should address both artificial arrangements and tax or regulatory evasion. Hungary offers a useful comparative lesson because its budget fraud regime consolidates several forms of fiscal fraud while maintaining identifiable behavioral elements.Conclusion: Criminal liability only applies if a scheme includes fraudulent conduct, concealment of material facts, false documentation, fictitious transactions, deliberate avoidance of a predetermined public obligation, and demonstrable fiscal or public interest harm.
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