Prohibition, Due Diligence and the Risk of Gaps: Regulating AI-based Online Violence

Generative AI models are increasingly exploited to produce synthetic media that facilitate image-based abuse, extortion, and grooming. Their public availability has been linked to a rise in the generation and circulation of abusive material, and to more sophisticated grooming techniques. Criminal law, however, largely targets the offender: the person who generates or disseminates the abusive image. This talk moves beyond the offender to the actors that supply the infrastructure, namely AI system providers and online platforms, who remain largely in a regulatory grey zone. It assesses how far prohibitions and due diligence obligations can effectively reach this supply chain. The analysis considers international instruments (the Council of Europe Convention on Cybercrime and the UN Convention against Cybercrime) and EU law (the AI Act, as amended by the Digital Omnibus, the Digital Services Act, and the proposed EU KIDS Act).

The talk argues that EU and international law reach the infrastructure of AI-based online violence only partially, and maps the gaps that open between prohibition, due diligence, and enforcement.

Irene Kamara is an Associate Professor and Research Coordinator at the Tilburg Institute for Law, Technology, and Society in the Netherlands, and a qualified attorney-at-law. Since 2026 she coordinates Digital Legal Studies, a research partnership of four Dutch law schools under the Law Sector Plan of the Dutch Ministry of Education. Irene is member of the European AI Board, the advisory body on the EU AI Act. Her research collaborations include the European Commission, the European Cybersecurity Agency, the Dutch National Cyber Security Agency, and the Dutch Ministry of Justice and Security. Irene was honoured with the 2021 Standards+Innovation Individual Researcher award from the European Standardisation Organisations CEN/CENELEC and an Early Career Partnership from the Royal Netherlands Academy of Arts and Sciences (KNAW) in 2025. Her monograph, Standardizing Data Protection, published by Oxford University Press, has received a best book award by the American Society of International Law (IL&TEch Interest Group).

Moderator: Marianne von Blomberg, Global Academic Fellow, The University of Hong Kong Faculty of Law

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