With the development of digital technology，Cross-border bet365 horse racing odds flows become increasingly frequent。Since 2016，The Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) led by the United States and the West、Digital trade agreements such as the Digital Economy Partnership Agreement (DEPA) begin to include rules for cross-border bet365 horse racing odds flows，However, these rules are subordinate to trade negotiations that focus on the economic dimension，Does not address major concerns such as national security caused by cross-border bet365 horse racing odds flow。Especially in recent years，Some countries try to use economic means to win over some countries to form exclusive "small circles" and "build walls and barriers"。This not only ignores the legitimate concerns of China and most other countries，Global governance in a more complex international context is getting worse。

The report of the 20th National Congress of the Communist Party of China pointed out: "China actively participates in the reform and construction of the global governance system，Practice the global governance concept of extensive consultation, joint contribution and shared benefits，Adhere to true multilateralism，Promote democratization of international relations，Promote global governance in a more just and reasonable direction。”For cross-border bet365 horse racing odds flow governance，On the one hand，Our country actively improves domestic legislation，Formally apply to join CPTPP、DEPA etc.，Actively promote international cooperation in digital governance，Strive to “follow” and “run alongside”，Deserves high recognition。On the other hand，It is also necessary to start from the common non-economic concerns of cross-border bet365 horse racing odds flow，Explore with yourself，Propose a new issue framework and China’s plan in addition to trade negotiations，Actively promote the reform of the global governance system for cross-border bet365 horse racing odds flow，Strive to “lead” in exploring international rules for digital governance。

　　Limitations of digital bet365 horse racing odds rules

First，Cross-border bet365 horse racing odds flow will not only involve cross-border trade，It will also involve national security、Sovereign jurisdiction、Private rights protection and other non-economic concerns。Cross-border bet365 horse racing odds flow involves personal information，Also involves business bet365 horse racing odds、Public bet365 horse racing odds，Even involving bet365 horse racing odds related to national security。This gives it an economic aspect of promoting trade，It will also bring about a series of non-economic challenges。The first is the national security challenge。After the Snowden revelations of mass surveillance programs，Countries are increasingly paying attention to the national security risks caused by cross-border bet365 horse racing odds flows，Start restricting or banning finance、Cross-border flow of bet365 horse racing odds in sensitive fields such as medical and health care。Secondly，Large-scale cross-border flow of bet365 horse racing odds，Great impact on traditional national sovereignty based on national boundaries and territorial jurisdiction，Especially the judicial enforcement jurisdiction of a country。To this，Countries have introduced legislation to safeguard sovereign jurisdiction，Including "blocking clauses" that prohibit overseas judicial law enforcement agencies from accessing bet365 horse racing odds without the consent of the country，Also includes "bet365 horse racing odds localization storage requirements" for retaining bet365 horse racing odds in certain important fields within the country。Finally，Enterprise bet365 horse racing odds、Cross-border flow of personal information，It will also raise concerns about the protection of cross-border private rights。

Second，Digital trade rules are limited because they only focus on the economic and trade dimension，Unable to solve the national security issues of various countries caused by the cross-border flow of bet365 horse racing odds、Significant concerns and regulatory differences in aspects such as sovereign jurisdiction，There is an urgent need to discuss the formulation of a new global governance framework。The current digital trade negotiations initiated by the United States and the West only cover some of the above concerns，In addition to incorporating personal information protection issues that the EU strongly advocates，National security concerns only serve as "exceptions" to free trade，It does not involve judicial law enforcement jurisdiction at all。National security concerns regarding the cross-border flow of bet365 horse racing odds，Despite CPTPP、DEPA and others provide special exceptions，That is, “restrictive measures may be adopted or maintained on the cross-border flow of information to achieve legitimate public policy objectives”，But the connotation of “legitimate public policy objectives” is not clear，And the national security exception under this model is only an "exception" to free trade，It is often very difficult to apply，Therefore, it is generally believed that these exceptions cannot be used as a legitimate basis for implementing general regulatory measures on cross-border bet365 horse racing odds flows based on national security。

　Third，Some countries intentionally set issues that tie “free flow of bet365 horse racing odds” and “free flow of trade”。Take the United States as an example，The United States was the first to bundle the two and discuss them，And ignore other concerns such as national security on the grounds of trade negotiations。The reason，On the surface it is limited to digital trade topics，But considering the high concerns and extensive legislation on bet365 horse racing odds security and bet365 horse racing odds jurisdiction in the United States，For example, the "Foreign Investment Risk Review Modernization Act", the "Clarification of Lawful Foreign Use of bet365 horse racing odds Act" and the "Protecting Americans' Sensitive bet365 horse racing odds from Foreign Adversaries" executive order promulgated in recent years。The profound meaning behind this is that the United States borrows the conceptual framework of "free flow of trade"，Proposed the confusing slogan of “free flow of bet365 horse racing odds”，By advocating for complete cross-border free flow of bet365 horse racing odds，Support its advanced digital technology companies to develop global markets，Making massive amounts of bet365 horse racing odds flow back to the United States，Thus maintaining its dominant position in the global digital market and cyberspace。

　　Building a Chinese solution with a compatibility framework

Our country has long recognized the limitations of discussing cross-border bet365 horse racing odds flow only from a trade perspective。In recent years，my country proposes the concept of “safe cross-border bet365 horse racing odds flow”，Launched the Global bet365 horse racing odds Security Initiative，Start with major concerns about cross-border bet365 horse racing odds flow，Constructed a "dual-track parallel" institutional framework for bet365 horse racing odds export regulation: First, the "Cross-border provision system of personal information" stipulated in the "Personal Information Protection Law" to protect individual rights and interests，Provides multiple legal channels for cross-border flow of personal information，Conducive to promoting my country’s integration with other economies。The second is the "Important bet365 horse racing odds Outbound Security Management System" stipulated in the "bet365 horse racing odds Security Law" and the "Cybersecurity Law" to safeguard national security，From a global perspective, this system exploration has greatly developed the legal framework for regulating cross-border bet365 horse racing odds flows based on national security concerns，Provides new institutional options for the global response to this challenge。

Based on the exploration of our country’s system，Promote changes in the global governance system for cross-border bet365 horse racing odds flow，We should adhere to the “coordinated promotion of domestic rule of law and foreign-related rule of law” emphasized in the report of the 20th National Congress of the Communist Party of China，We must consider regulating "bet365 horse racing odds outflow"，Prevent bet365 horse racing odds from being improperly obtained overseas，We must also simultaneously consider the impact of regulatory measures on the "bet365 horse racing odds inflow" of Chinese enterprises，To prevent our country from being misunderstood as obstructing the flow of bet365 horse racing odds and creating trade barriers on the grounds of "security"，Only in this way can we truly adapt to my country’s comprehensive layout in the globalization of the digital economy。This should be based on the "respect for network sovereignty" proposed by our country、Building a community with a shared future in cyberspace” is the basic premise，Promote countries to reach a compatibility framework for global governance on common concerns。

First，Establish basic governance concepts: Promote legitimate and controllable cross-border bet365 horse racing odds flow。From the perspective of the "bet365 horse racing odds Security Law"，The “security” of “cross-border secure flow of bet365 horse racing odds” proposed by our country，In fact, it has surpassed the traditional understanding of bet365 horse racing odds security，The connotation also includes bet365 horse racing odds utilization security。This kind of utilization security emphasizes the legitimacy and controllability of large-scale bet365 horse racing odds flow and utilization in the digital economy era，And legitimacy and controllability should completely cover national security、Sovereign jurisdiction、Shared legitimate concerns such as protection of private rights。In order to accurately express common governance concerns and have more appeal，It is recommended to upgrade the concept of "safe flow" of cross-border bet365 horse racing odds to the concept of "legitimate and controllable flow" of cross-border bet365 horse racing odds。This concept is compared to the "Trust-based Cross-border bet365 horse racing odds Flow" in the 2019 "G20 Osaka Digital Economy Declaration"，More emphasis on objectivity、Legitimate and inclusive，More conducive to promoting global governance that promotes win-win cooperation among countries。

Second，Prevent national security risks: clarify the scope of important bet365 horse racing odds to clarify the “negative list”。At the international level，It should be done in order to safeguard national security、The control of important bet365 horse racing odds in the public interest is raised as an independent issue，It is no longer considered to be an “exceptional clause”。In digital trade negotiations，A separate “Important bet365 horse racing odds Clause” can be drawn up and proposed。Given that important bet365 horse racing odds may seriously affect national security、Public interest，In terms of regulatory means, prior supervision should be the main focus、Supervision during and after the event is supplemented，my country’s recently introduced bet365 horse racing odds export security assessment system is an important starting point for prior supervision。In terms of system compatibility，Due to important bet365 horse racing odds related to national security，Inseparable from a country’s national conditions，The specific scope can be determined by each country，But some basic principled consensus should be established，Such as "must not hinder legitimate and controllable bet365 horse racing odds flow", etc.。At the domestic level，The scope of important bet365 horse racing odds should be clarified as soon as possible under the guidance of the overall national security concept，Clear the “negative list” for my country’s bet365 horse racing odds export。Considering the complexities of different industries and fields，Instead of directly enumerating the specific scope of important bet365 horse racing odds, the important bet365 horse racing odds identification system can be stipulated。

　Third，Maintain judicial enforcement jurisdiction: focus on bet365 horse racing odds access rights instead of relying on localized storage。Traditional judicial assistance procedures need to be communicated and handled through the specialized agencies of both parties，Often complex, lengthy and inefficient，It has become increasingly unsuitable for the global development of the digital economy and the need for rapid resolution of disputes。In this case，There is a pattern of directly retrieving bet365 horse racing odds from the "bet365 horse racing odds controller"，This model of focusing on bet365 horse racing odds access rights has greatly improved the efficiency of judicial enforcement，Worth for reference。Actually，For cross-border bet365 horse racing odds retrieval for judicial law enforcement，The location of bet365 horse racing odds storage is not critical，The key is to ensure access to bet365 horse racing odds。To protect this bet365 horse racing odds access，The legal liability that the obligated subject shall bear when it fails to provide bet365 horse racing odds in a timely manner can be stipulated。So，Can greatly reduce the localized storage of bet365 horse racing odds required by judicial law enforcement jurisdiction。

　Fourth，Protecting personal information rights and interests: improving cross-border accountability system to ease ex-ante regulatory pressure。Personal information flows in countries or regions with different levels of protection，The key is how to promote the compatibility of different levels of protection systems。As far as our country’s cross-border personal information rules are compatible with other countries，We can learn from the practices of the European Union and the United States，Adopt both ex-ante supervision model and ex-post accountability model，Establish a "white list" system based on the principle of reciprocity in bilateral or multilateral negotiations；Considering the pressure of prior supervision、The need for supervision during and after the event and the cost of prior approaches such as certification by professional organizations，We should also simultaneously study and improve the accountability mechanism for overseas processors，To avoid over-reliance on ex-ante mechanisms and causing undue obstruction to bet365 horse racing odds flow；This ex post facto accountability mechanism should be included in bilateral or multilateral judicial assistance agreements concluded between our country and other countries，To enhance the execution of post-event accountability。Also，For scientific research needs such as vaccine research，We should also consider formulating special rules for the export of personal information in the field of scientific research。

　(This article is a phased result of the China Law Society’s ministerial project “China’s plan to improve the global governance system for cross-border bet365 horse racing odds flows” (CLS (2022) C56)) (The author is a researcher at the Rule of Law Institute of the China Law Society)