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Ida Ayu Nuh Kartini; Diah Ayu Susilaningtias; Jeslin Cecelia Thunggal; Revalia Wulan Suryani; Teresya Dwigantara Wega

Jurnal Bisnis Kreatif dan Inovatif 2025 Asosiasi Riset Ilmu Manajemen dan Bisnis Indonesia

This study analyzes the effectiveness of using BNI Bank’s QRIS in improving transaction convenience and efficiency at the canteen of Universitas 17 Agustus 1945 (UNTAG) Surabaya. The research was conducted by a team led by Ida Ayu Nuh Kartini, S.E., M.M., together with students of the Management Study Program, during November–December 2025. The rapid development of digital banking has encouraged the adoption of QRIS as a standardized non-cash payment system regulated by Bank Indonesia. This study aims to examine the level of QRIS BNI utilization, assess ease of use (application access and QR code scanning), and evaluate transaction efficiency, including time savings, queue reduction, and error minimization. A descriptive quantitative approach was employed using a survey method with a five-point Likert scale questionnaire distributed to 36 respondents consisting of students, lecturers, and administrative staff who had used QRIS at the canteen. Primary data were analyzed descriptively using averages and percentages, supported by relevant literature. The results show that QRIS is perceived as highly effective, with scores above 90% for ease of use (95%), transaction speed (92.78%), reduction of change-related issues (97.78%), support for digitalization (97.22%), and security (91.11%). The main limitation identified is dependence on internet connectivity (85%). Overall, respondents strongly support the full implementation of non-cash payment systems at the campus canteen.

Anugrah Mardiah Putri; Dito Aditia Darma Nst; Dinda Widayanti; Lutfiah Adinda Azahara; Juli Arti Waruwu +2 more

Jurnal Bisnis Kreatif dan Inovatif 2025 Asosiasi Riset Ilmu Manajemen dan Bisnis Indonesia

Financial management, both in public and private organizations, is highly vulnerable to fraud and misappropriation of funds. The risk of fraud in financial reporting not only jeopardizes an organization's long-term financial health but also damages the reputation and trust of stakeholders. Professional ethics and integrity are key factors in ensuring good, efficient, and effective financial governance. Weak internalization of professional ethical values ​​among financial practitioners, such as manipulation of financial reports and unauthorized use of official funds, is often a major cause of misappropriation of funds. These cases can significantly harm an organization, as seen in violations of codes of ethics in various large companies. Therefore, strengthening professional ethics in financial management practices is crucial to prevent misappropriation of funds, fraud, or financial manipulation. A strong internal control system, coupled with a good ethical culture, can play a significant role in preventing and detecting these conditions. This study aims to identify factors that support and hinder the implementation of professional ethics in financial management and provide recommendations for improving integrity and accountability in fund management. It is hoped that the results of this study will help organizations strengthen governance, increase transparency, and reduce the risk of fraud through better implementation of professional ethics.

Zarafat Risian Rafli; Kusuma, Mochamad Iqbal Hadi Jaya; Muafa, Muhammad Mahdi; Ocktaviani, Dina Ayu; Aini , Zahra Qudratul

JURNAL RISET MANAJEMEN (JURMA) 2025 Institut Teknologi dan Bisnis (ITB) Semarang

This study aims to analyze cost and time optimization in project management through a case study of developing a QR Code–based Digital Warehouse Management System. The project was carried out by a team of students from the Logistics Management Study Program as a practical implementation of modern project management concepts in an academic environment. The research employed a descriptive qualitative case study approach, including observation, documentation, and literature analysis. The results indicate that the use of QR Code technology significantly improves time efficiency in stock recording by up to 80% and reduces the risk of human error. In terms of cost, the project successfully optimized resources by utilizing personal devices and open-source software, eliminating the need for additional infrastructure investment. The project also demonstrated effective implementation of the Work Breakdown Structure (WBS), risk management, and evaluation based on the Triple Constraint principle. These findings highlight that simple digital innovations can greatly enhance operational efficiency and project management performance, making them a strategic solution for SMEs in the digitalization of warehouse operations.  

April Naufal Anggraeni; Aldi Darmawan; Ismi Rusyanti

International Journal of Law, Crime and Justice 2025 Asosiasi Penelitian dan Pengajar Ilmu Hukum Indonesia

The right to immunity for advocates is an important instrument to ensure that advocates can practice their profession freely, especially in defending clients' interests in court, without being disturbed by legal threats. However, this right is not absolute and can be lost if the advocate violates the code of ethics or harms the dignity of the court, as in the case of Razman Arif Nasution, which raised questions about the balance between professional protection and ethical responsibility. This paper aims to examine the limits of the right to immunity for advocates in the context of violations of professional ethics, as well as explore its legal implications for the disciplinary mechanisms of advocate organizations. The method used is normative juridical, with a statute approach and a case study approach. The study findings indicate that advocate protection must still be linked to compliance with professional ethics, so that in practice disciplinary mechanisms have a strategic role in upholding professionalism.

Nugrah Gables Manery

Referendum : Jurnal Hukum Perdata dan Pidana 2025 Asosiasi Peneliti dan Pengajar Ilmu Hukum Indonesia

This study aims to examine the analysis of unilateral contract termination. The method used in this study is normative juridical. The approaches used in this study are the statutory approach and the conceptual approach. The results of this study indicate that the provisions for contract termination as stipulated in Article 1338 paragraph (2) of the Civil Code should not override the provisions of Article 1266 of the Civil Code, which governs the conditions for annulment in reciprocal agreements. Termination clauses in contracts are generally unilateral, disregarding the provisions of Article 1266 of the Civil Code. The Civil Code does not explicitly regulate the distinction between damages resulting from breach of contract and damages resulting from unlawful acts. Therefore, what is needed is a clear understanding of the concept of contract termination, so that in the future there will be regulations that provide legal certainty to the parties involved.

Mielda Khasanah; M. Sudirman; Mardi Candra

International Journal of Education and Literature 2025 Lembaga Pengembangan Kinerja Dosen

In social life, buying and selling are fundamental mechanisms for transferring rights, beginning with an agreement. According to Articles 1313 and 1338 of the Indonesian Civil Code, agreements are legally binding acts with the force of law for the parties involved. One high-value transaction is the sale and purchase of apartment units, which involves developers as sellers. In practice, developers often fail to deliver units within the agreed timeframe. This study examines (1) the developer’s responsibility toward buyers when units are not delivered and (2) the legal protection available for buyers under such circumstances. The research applies Hans Kelsen’s Theory of Responsibility and Satjipto Rahardjo’s Theory of Legal Protection, using a normative juridical method based on library research. Primary, secondary, and tertiary legal materials were analyzed through statutory, conceptual, analytical, and case approaches, employing grammatical and systematic interpretation, legal analogy, and legal refinement. Findings reveal that developers are primarily responsible for delivering fully paid units. Failure to fulfill this obligation, due to breach of contract or negligence, triggers legal liability in the form of performance or compensation. Legal protection for buyers ensures their rights are safeguarded, and even in cases of developer negligence or bankruptcy, consumers are legally entitled to receive the apartment units they have purchased.

Adtila Prawoko; Ab’dan Syukur; Nadia Putri Kustiono; Anita Nur Amaliyah; Kuswan Hadji

Presidensial : Jurnal Hukum, Administrasi Negara, dan Kebijakan Publik 2025 Asosiasi Peneliti dan Pengajar Ilmu Hukum Indonesia

The enactment of Law Number 1 of 2023 concerning the Criminal Code brought fundamental changes to the regulation of the crime of adultery in Indonesia. The expansion of the scope of criminalization, including regulations regarding extramarital relationships, has given rise to debate regarding its compliance with the principles of the formation of laws and regulations and its impact on criminal law enforcement. This study aims to analyze the provisions of the adultery article in the new Criminal Code from the perspective of the principles of the formation of laws and regulations and assess its implications for the effectiveness of the criminal justice system. This study uses a normative legal research method with a legislative and conceptual approach. Legal materials were obtained through literature studies and analyzed qualitatively and juridically. The results show that the regulation of the crime of adultery in the new Criminal Code has a clear normative purpose, but still leaves issues regarding the clarity of formulation, legal certainty, and potential human rights violations. Furthermore, the application of the adultery article has the potential to create obstacles in law enforcement practices, particularly related to evidence, caseload, and the legitimacy of the criminal justice system. Therefore, further evaluation is needed to ensure that these regulations align with the principles of sound legislative development and ensure legal justice.

Mohammad Rafi Shidqi; Efan Andika Putra; Abdul Hasib; Mu'alimin

Jurnal Arjuna : Publikasi Ilmu Pendidikan, Bahasa dan Matematika 2025 Asosiasi Riset Ilmu Pendidikan Indonesia

Educational quality is a strategic issue that plays a crucial role in determining the competitiveness of human resources in the global era. The main factors influencing its achievement include effective leadership and the implementation of Total Quality Management (TQM). However, previous studies reveal diverse approaches and findings that require a more comprehensive synthesis. Therefore, this article aims to systematically examine the role of leadership and quality management strategies in improving educational quality and to address the following questions: (1) how leadership contributes to the improvement of educational quality, and (2) how quality management strategies can be implemented to address global challenges. The method employed is a literature review through a systematic search of articles using Google Scholar and Publish or Perish (PoP). The keywords “conflict resolution” and “quality leadership” were used to identify relevant literature. Out of 50 articles identified, 19 articles were selected based on publication year criteria (2022–2025), open-access availability, and topic relevance. The selected articles were then coded and categorized into thematic groups. The main findings reveal three dominant patterns: (1) visionary, transformational, and authentic leadership significantly influence educational quality; (2) TQM strategies serve as an innovative framework for quality improvement; and (3) a quality-oriented culture is essential in addressing global challenges. In conclusion, this synthesis emphasizes the importance of quality-based leadership and provides directions for future research related to the implementation of TQM in the digital era.

Rizky Gry Fandhi; Silvia Margaret

Proceeding of the International Conference on Management, Entrepreneurship, and Business 2025 Asosiasi Riset Ilmu Manajemen Kewirausahaan dan Bisnis Indonesia

Digital payment systems have become one of the main innovations in financial transformation. Over the past few years, these systems have gained significant traction and are now at the forefront of reshaping financial landscapes globally. Currently, digital payment systems have changed global transactions by slowly replacing the transaction patterns of societies that were previously dominated by conventional transactions, offering more efficiency, security, and accessibility. This transformation is closely related to the development of fintech, which has given rise to instruments in the form of electronic money and blockchain technology. These advancements have not only changed the way payments are made but also enabled the inclusion of previously underserved populations in the financial ecosystem. This study uses a bibliometric approach to analyze scientific publications, with the main sources coming from Scopus using the keywords “digital payment systems,” “electronic money,” and “fintech.” By utilizing Biblioshiny in the VOSviewer application, this study aims to examine publication trends, contributions from various countries, institutions involved, and thematic connections between topics. In conclusion, this study contributes to expanding the understanding of the development of digital payment systems, while also presenting a global research map that can be used as a reference for academics, researchers, and policymakers involved in financial innovation.

Yemima Y Denga; Andreas Ariyanto Rangga; Felysitas Ema Ose Sanga

Mars: Jurnal Teknik Mesin, Industri, Elektro Dan Ilmu Komputer 2025 Asosiasi Riset Teknik Elektro dan Informatika Indonesia

This research aims to design and implement a village MSME website as a centralized digital promotional medium to overcome the limitations of conventional marketing and expand the market reach of local products more effectively and sustainably. The system was developed using the waterfall method, encompassing requirements analysis, design, implementation, testing, and maintenance. The system was developed using the PHP programming language and the CodeIgniter framework based on the Model-View-Controller (MVC) architecture to ensure a structured, efficient, and maintainable development process. The implementation resulted in a responsive and user-friendly website equipped with key features such as an informative product catalog, village MSME profiles, and a content management system via an admin dashboard that allows MSMEs to update data independently and flexibly. Functional testing demonstrated that all features functioned well and reliably according to user needs. Therefore, this village MSME website can be concluded as an effective digital solution for increasing the visibility of local products, strengthening MSME competitiveness, and supporting village economic growth through sustainable and integrated online promotion.

Bunga Lexsa Angelia; Devi Raisa Fauziah; Shintia Purnama Dewi; Aneza Putri Setiadi; Rosmatun Aliyah

Konsensus : Jurnal Ilmu Pertahanan, Hukum dan Ilmu Komunikasi 2025 Asosiasi Peneliti Dan Pengajar Ilmu Sosial Indonesia

The development of electronic commerce through marketplace platforms presents new challenges in civil law enforcement, particularly concerning the platform's liability for the circulation of counterfeit goods. This study aims to analyze Shopee's legal responsibility as a provider of electronic transaction services regarding the sale of counterfeit goods, based on Article 1365 of the Civil Code concerning Unlawful Acts and its relation to consumer protection principles as regulated in the Republic of Indonesia Law Number 8 of 1999 concerning Consumer Protection. The research uses a normative juridical method with a legislative approach and literature study, including provisions in the Law on Electronic Information and Transactions and Government Regulation Number 71 of 2019 on the Implementation of Electronic Systems and Transactions. The research findings indicate that although Shopee does not act as a direct seller, the platform still has a legal obligation to provide a reliable, secure, and responsible electronic system. Negligence in verifying sellers and monitoring products has the potential to fulfill the elements of unlawful acts, particularly the elements of fault and causal relationship with consumer losses. This study emphasizes that Shopee qualifies as a business actor in the context of consumer protection, thereby bearing both preventive and repressive responsibilities to ensure transaction security and prevent the circulation of counterfeit goods on its platform.

Inna Noor Inayati

Jurnal Kajian Ilmu Sosial, Politik dan Hukum 2025 Asosiasi Peneliti dan Pengajar Ilmu Hukum Indonesia

Medical emergency services demand swift and precise action; however, medical personnel are often hindered by the risk of criminalization resulting from unintended outcomes. Although Law Number 17 of 2023 concerning Health mandates the provision of assistance, the regulation has not yet provided explicit criminal protection for good-faith rescuers, thereby triggering the practice of defensive medicine. This study aims to examine the implementation of the Good Samaritan Law (GSL) concept as an alternative legal protection for health workers. The research methods employed are juridical-normative and juridical-empirical, utilizing statutory, comparative, and case approaches. The findings indicate that current regulations, including Article 531 of the Criminal Code (KUHP) and Law No. 17/2023, have limitations as they emphasize the obligation to assist rather than the protection of the rescuer. In comparison, the international GSL concept offers a standard of "limited immunity," which explicitly protects rescuers from civil and criminal liability, provided the actions are performed without gross negligence. The impact of implementing GSL in Indonesia is projected to provide stronger legal certainty than existing regulations, reduce the psychological burden on medical personnel in emergency situations, and encourage social solidarity without the fear of unnecessary lawsuits. The study concludes that the adoption of GSL is an urgent legal reconstruction to ensure the professional protection of health workers in Indonesia.

Astri Anggraeni Putri; Sidi Ahyar Wiraguna

Parlementer : Jurnal Studi Hukum dan Administrasi Publik 2025 Asosiasi Peneliti dan Pengajar Ilmu Hukum Indonesia

Indonesia’s civil dispute resolution system remains dominated by an adversarial litigation model that prioritizes legal certainty but often neglects the relational and emotional dimensions underlying conflicts. Yet, in many cases such as family, inheritance, or neighborhood disputes the restoration of social relationships is as crucial as formal legal resolution. This study explores the potential integration of restorative justice principles into Indonesia’s civil procedural law as an alternative approach centered on dialogue, accountability, and reconciliation. Employing a normative-juridical approach and qualitative analysis of primary and secondary legal sources, the research finds that restorative justice values align not only with Indonesia’s living law traditions such as musyawarah (deliberative consensus) and customary dispute resolution but also with existing provisions in civil procedure codes. Accordingly, the study proposes the Structured Restorative Mediation (SRM) Model, a procedural framework that embeds restorative principles into both court-annexed and community-based mediation. This model prioritizes relational healing while upholding legal certainty and procedural fairness. Its successful implementation requires regulatory support, enhanced mediator training, and institutional strengthening of community-based dispute resolution bodies. Thus, integrating restorative justice is not merely an innovation but a structural necessity for a more humane, inclusive, and holistically just legal system.

Susi Turti; Adi Nur Rahman

International Journal of Law, Crime and Justice 2025 Asosiasi Penelitian dan Pengajar Ilmu Hukum Indonesia

This study examines the critical role of expert opinions from the Ministry of Energy and Mineral Resources (ESDM) during the investigation phase in uncovering gold mining without permit (PETI) crimes under Article 120 of the Indonesian Criminal Procedure Code (KUHAP) in West Kalimantan. The research employs a normative-empirical approach, analyzing legal provisions, government reports, and judicial practices to assess how ESDM experts contribute to establishing the material truth of PETI cases. Findings reveal that expert opinions are indispensable for verifying the absence of permits, assessing environmental damage, and quantifying state losses, thereby strengthening evidentiary frameworks for prosecutors and judges. However, challenges persist, including coordination gaps between law enforcement and ESDM, insufficient technical capacity among investigators, and potential threats to expert independence. The study concludes that optimizing the use of ESDM expertise is not merely procedural but strategic for effective, accountable, and just enforcement against PETI, which remains a significant threat to national resource sovereignty and environmental sustainability.

Reza Reyzaldy; Dian Ekawaty Ismail; Erman I. Rahim

International Journal of Law, Crime and Justice 2025 Asosiasi Penelitian dan Pengajar Ilmu Hukum Indonesia

The purpose of this study is to analyze the settlement of criminal cases on the liability of parents for negligence that results in minors becoming perpetrators of traffic accidents. This type of research is normative legal research with a statutory approach, a case approach and a conceptual approach. The analysis used in this study is a descriptive analysis. has not explicitly regulated the criminal liability of parents for accidents committed by children, although Civil Code Article 1367 has provided a basis for civil liability, and the new Criminal Code through Article 37 opens up opportunities for the application of the principle of vicarious liability. This study recommends the need to reconstruct the Indonesian criminal law regulation which explicitly establishes a model of parental criminal responsibility based on the principle of vicarious liability and the principle of Radbruch legal certainty, without overriding the principle of child protection in the SPPA Law.

Lidia Ambu Kaka; Andreas Ariyanto Rangga; Emerensiana Dappa Ege

Router : Jurnal Teknik Informatika dan Terapan 2025 Asosiasi Profesi Telekomunikasi dan Informatika Indonesia

Posyandu (Integrated Health Post) is a public health facility that plays a vital role in providing health services for toddlers and pregnant women. However, data management and reporting often face challenges, such as limited access to information and errors in data recording. Therefore, this study aims to develop a Web-Based Posyandu Payolaumbu Service Information System using the CodeIgniter Framework to improve efficiency and accuracy in data management and reporting. In the development phase, a system requirements analysis and web-based application architecture design were conducted. The system implementation uses the CodeIgniter Framework as a framework to produce a faster, more efficient, and more reliable application. Proposed features include recording health data for toddlers and pregnant women, immunization schedules, weighing, and health reports. The results show that the Web-Based Posyandu Payolaumbu Service Information System can improve efficiency in recording and reporting health data. Users, including posyandu officers, midwives, and administrators, can easily access and manipulate data in real-time. Furthermore, this system helps improve service quality by providing more accurate and complete information on toddler health. In conclusion, the implementation of the Web-Based Posyandu Payolaumbu Service Information System using the CodeIgniter Framework provides significant benefits for data management and health services at Posyandu Payolaumbu. Suggestions for further development include maximizing system utilization, developing additional features, routine maintenance, and ongoing evaluation based on user feedback. With these steps, it is hoped that this system can contribute more effectively to improving the quality of health services at Posyandu and supporting comprehensive public health efforts.

Kaharuddin Kaharuddin; Salsabilla Salsabilla; Agnes Widya Klarisa; Syahrani Ramadhani Payapo

Jurnal Riset Rumpun Ilmu Sosial, Politik dan Humaniora 2025 Lembaga Pengembangan Kinerja Dosen

This study examines the renewal of the Criminal Procedure Code (KUHAP) Baru as an effort to synchronize with the Criminal Code (KUHP) 2023, as well as analyzing crucial articles that potentially cause legal uncertainty in the criminal justice process in Indonesia. Using a juridical-normative method with a descriptive-analytical approach, this research analyzes secondary data from primary, secondary, and tertiary legal materials. The results show that KUHAP Baru successfully addresses some of the mismatches with KUHP 2023 through regulations on alternative punishments, corporate accountability, and protection for vulnerable groups, but still faces conceptual and technical challenges such as legislative disharmony and minimal public participation. On the other hand, crucial articles such as Articles 5, 16, 74, 90, 93, 105, 112A, 124, 132A, and 137A pose risks of legal uncertainty due to the expansion of law enforcement authority without adequate oversight, which can violate the due process principle and human rights. The study's conclusion emphasizes the need for further revisions to strengthen legal certainty and harmonize the criminal justice system.

Arfa Aulia Parinduri; Nayla Lestari; Gressela Sesinta; Ida Basaria

Realisasi : Ilmu Pendidikan, Seni Rupa dan Desain 2025 Asosiasi Seni Desain dan Komunikasi Visual Indonesia

This study aims to describe the forms and social functions of code-switching and code-mixing in the film Hujan Bulan Juni and to explain how language choice represents identity and social differences among the characters. The film was chosen because it portrays interactions between characters from different cultural backgrounds Javanese and Manadonese which allows for complex patterns of language contact. The study employed a descriptive qualitative method using observation and note-taking techniques on dialogues containing Indonesian, Javanese, and Manadonese linguistic elements. The data were analyzed using the sociolinguistic frameworks of Gumperz (1982) and Wardhaugh (2015) to uncover the social functions and identity meanings reflected in the speakers’ language choices.The findings reveal that code-switching from Indonesian to Manadonese serves to reinforce ethnic solidarity, emotional closeness, and cultural pride, while switching from Indonesian to Javanese reflects politeness, intimacy, and social hierarchy. Meanwhile, code-mixing between Indonesian and Manadonese marks distinctive speech styles and expresses regional identity, whereas code-mixing between Indonesian and Javanese functions to soften utterances and portray the speakers’ courteous demeanor. Overall, language choice in Hujan Bulan Juni is not merely a communicative tool but also a representation of identity and social differentiation within Indonesia’s multilingual society.

Yolanda Fitria Salma; Ahmad Irzal Fardiansyah; Dona Raisa Monica; Tri Andrisman; Nikmah Rosidah

Jurnal Kajian Ilmu Sosial, Politik dan Hukum 2025 Asosiasi Peneliti dan Pengajar Ilmu Hukum Indonesia

The enactment of Law Number 1 of 2023 concerning the Indonesian Criminal Code (KUHP Nasional 2023) has brought significant changes to the national penal system, particularly in the regulation of sanctions imposed on children who commit criminal offenses. Children as offenders constitute a special legal subject who require a sentencing approach oriented toward protection, guidance, and rehabilitation. This study aims to analyze the regulation and concept of sentencing for children under the perspective of the KUHP Nasional 2023 and to assess its conformity with the principles of child protection and the objectives of the juvenile justice system in Indonesia. This research employs a juridical descriptive method using statutory and conceptual approaches through a literature review of primary, secondary, and tertiary legal materials. The findings indicate that the KUHP Nasional 2023 normatively accommodates a more humane sentencing approach by emphasizing the objectives of punishment and providing non-custodial sanctions and rehabilitative measures. However, these provisions remain general and have not been explicitly integrated with restorative justice principles as stipulated in the Juvenile Criminal Justice System Act. Therefore, regulatory harmonization and consistent implementation are necessary to ensure that sentencing for children truly reflects the best interests of the child and the rehabilitative goals of the juvenile justice system.

asyer, peter; Rinces Manalu, Perdana; Fajar Kuswanto, Satria; Claudilla Putri, Rizha

Synergy: Journal of Collaborative Sciences 2025 Yayasan Penelitian dan Pengabdian Masyarakat Sisi Indonesia

The development of Artificial Intelligence (AI) has generated new challenges in civil law, particularly regarding breach of contract in cross-border transactions. The autonomous decision-making capacity of AI systems raises questions concerning their legal status and the allocation of contractual liability. This study aims to analyze liability for breaches of contract caused by AI under Indonesian civil law and to examine the determination of the applicable law (lex causae) in cross-border contracts from the perspective of private international law. Using a normative juridical method with conceptual, case-based, and comparative approaches, this research draws upon the Indonesian Civil Code, the Electronic Information and Transactions Law, the Copyright Law, and relevant legal literature. The findings show that autonomous AI cannot be recognized as a legal subject in the Indonesian legal system due to the absence of free will and moral consciousness, so liability remains attributed to the human or legal entity operating the system under the doctrine of vicarious liability. The case of Quoine v B2C2 confirms that contracts executed through algorithms remain legally binding on human or corporate parties rather than AI systems. From a private international law perspective, the study affirms that the use of AI does not alter the fundamental principles for determining lex causae, which continue to rely on connecting factors such as lex loci contractus, lex loci solutionis, and party autonomy.