Operation Cumberland: Europol’s Fight Against AI-Generated Child Sexual Abuse Material

On February 28, Europol announced the arrest of 25 individuals from 19 countries in a large-scale strike operation against child sexual exploitation. The investigation was led by Danish law enforcement. Operation Cumberland was a worldwide undertaking, resulting in the identification of 273 suspects, 25 arrests, and 173 electronic device seizures. Throughout the investigation, Europol, the Joint Cybercrime Action Taskforce (J-CAT), and Europol’s European Cybercrime Center helped coordinate law enforcement action and operational analysis to national investigators.

Operation Cumberland is “one of the first cases involving AI-generated child sexual abuse material (CSAM).” This large-scale hit highlighted the lack of national legislation on AI-generated child sexual abuse material. The novelty and rapidly evolving nature of this offense has led the international community (specifically the European Union) to consider proposals to best combat this abuse. Sophisticated AI-models are manipulated to produce images that are nearly indistinguishable from genuine material, posing challenges for law enforcement to identify victims of sexual exploitation.

The international legal community is making strides to address the legal issues resulting from AI-created child sexual abuse material and the gaps in national legislation. Child sexual abuse materials are increasingly accessible due to internet access and the development of “pay-as-you-go streaming solutions, which provide a high degree of anonymity to the viewer.” Peer-to-peer networks available on the dark web are used by offenders, disseminating egregious materials online. The European Cybercrime Center (EC3) supports Member States in both the prevention and detection of sexual exploitation of children, and is involved in the Virtual Global Taskforce, attacking online child sexual abuse.

Europol’s strategy to prevent future crimes includes “launching an online campaign in the coming days to highlight the consequences of using AI for illegal purposes and targeting potential offenders where they are most active: online.” It will also target purchases of the content through online messages and through traditional law enforcement strategies such as “knock-and-talks, social media messages and warning letters.”

The main suspect in this case was a Danish national, who became the center of this investigation through an online platform system in which he distributed AI-generated child sexual abuse materials. Users around the world would produce payment to obtain a password which would unlock the material depicting children being abused. The Danish law enforcement identified the subscribers and notified the law enforcement entities of each respective country. Danish law enforcement notified the Australian Center to Counter Child Exploitation (ACCCE), launching an investigation into two men who were alleged subscribers. Law enforcement executed search warrants, where police allegedly located child abuse material on electronic devices, leading to the arrest of both suspects. Both suspects were charged with possession of child abuse material accessed or obtained through the internet.

Operation Cumberland and the collaboration demonstrated by Europol are a positive indication of future progress in punishing and preventing the online dissemination of Child Sexual Abuse Materials.

Written by Jessica Jacobs

Sources:

25 arrested in global hit against AI-generated child sexual abuse material, EUROPOL (Feb. 28, 2025), available at https://www.europol.europa.eu/media-press/newsroom/news/25-arrested-in-global-hit-against-ai-generated-child-sexual-abuse-material (last visited March 3, 2025).

Crime Areas: Child Sexual Exploitation, EUROPOL, available at https://www.europol.europa.eu/crime-areas/child-sexual-exploitation (last visited March 3, 2025).

Bureau Report, Two Australians charged in global AI child abuse crackdown, The Australia Today (March 2, 2025), available at https://www.theaustraliatoday.com.au/two-australians-charged-in-global-ai-child-abuse-crackdown/ (last visited March 3, 2025).