countries criminalized “possession”, with almost 40 per cent including provisions on “accessing” child pornography.271 One issue surrounding the criminalization of child sexual abuse material relates to its inadvertent possession. Some States have resolved this by broadly interpreting possession to include any exercise of dominion or control over images, including such contained in digital Internet “cache” files. Policymakers in the United States and South Africa have also noted, for instance, that punishment of non-contact offenders in these countries is based on the concern that the distribution and viewing of child sexual abuse material may incite more contact abuse.272 One of the most prevalent distinctions made by national legal systems is that between contact and non-contact offences. National laws against child sexual abuse material are primarily grounded in the suffering caused by the original sexual abuse, and so tend to mainly focus on contact offences. A number of countries, however, give weight to both contact and non-contact offences, taking into consideration not only the original abuse, but also its implications in the form of the suffering of victims from the potentially infinite dissemination of abuse images. Finland and Slovakia,273 for example, have some of the most restrictive laws in this regard.274 Some States have also successfully prosecuted citizens for contact sexual abuse offences conducted through live web streaming of child sexual abuse material, holding that directing live UNODC, 2013. Pp. 100-104; ECPAT, 2008. Pp. 81-88. Ibid. 273 A/HRC/12/23. Paragraphs 56-57. 274 Arguably these countries may treat as criminal acts of possession, the watching of online child sexual abuse material because the material is temporarily stored in the computers’ cache of viewers; see ECPAT, 2008. Pp. 8388; UNODC, 2013. P. 103. commercial sexual exploitation via the Internet is equal to rape of a child.275 Some States may have no laws that specifically criminalize child sexual abuse material.276 Countries without specific laws may nonetheless criminalize the production, distribution or possession of this type of material under broader laws related to obscenity, decency and vice.277 Countries also vary in their treatment of “virtual” and “simulated” child sexual abuse material. “Virtual” child sexual abuse material generally refers to visual material that appears to depict children engaged in sexual acts but that is actually the product of digital creation, animation, morphing or composite making. “Simulated” child sexual abuse material refers to materials featuring adults who are disguised to look like children. Whereas some States penalize possession of virtual child sexual abuse material to a lesser extent than that of real child sexual abuse material, ­others do not make such a distinction. Results from the Cybercrime Study showed that national laws on child porno­ graphy use a range of terminologies, but only in around onethird of countries do they include simulated material.278 Countries such as Sweden and the United States, for example, do not criminalize simulated child sexual abuse material because children were not involved in its production, while other countries do criminalize this material because the simulated material is difficult to distinguish from real child sexual abuse material and may stimulate the market for the latter. 271 272 EUROPOL, 2013. A/HRC/12/23. Paragraph 53. 277 UNODC, 2013. Pp. 100-101. 278 Ibid. Pp. 102. 275 276 42 STUDY ON THE EFFECTS OF NEW INFORMATION TECHNOLOGIES ON THE ABUSE AND EXPLOITATION OF CHILDREN