From Silicon Valley to Shiraz: Examining Legal and Ethical Gaps in Cross-Border Interactions of Artificial Intelligence Chatbots for Cognitive Behavioral Therapy

AI driven cognitive behavioral therapy (AI-CBT) platforms promise scalable, low-cost mental health care accessible across borders. However, even human-delivered CBT requires significant cultural adaptation when delivered to non western patient. The global reach of AI-CBT magnifies the risks when harm occurs in jurisdictions different from where the provider is based. The title reflects a plausible scenario: an AI-CBT app developed in Silicon Valley reaches a user in Shiraz through social media or gaming ads. Persuasive design nudges the user into sharing personal struggles, assuming protections similar to domestic therapy, while in reality the foreign-based provider may lack both legal obligations and the cultural context to respond effectively. This paper investigates the legal and ethical gaps of such cross-border deployments, drawing on documented cases of harm from Belgium, the United Kingdom, and the United States. The research employs a mixed-methods approach, combining comparative legal analysis of U.S., EU, and Iranian frameworks with a doctrinal review of statutes, policies, and relevant AI regulations. Ethical evaluation is grounded in principles of informed consent, patient safety, and cultural sensitivity. The study concludes with proposals for international cooperation, enforcement mechanisms, and AI-specific ethical guidelines.

کلیدواژه ها:

Cbt ، Ai ، cross-border regulation ، legal liability ، ethical standards