How to criminalize espionage in the criminal system of the GCC countries and its effects on the socio-political security of Iran

Espionage, or what is sometimes called treason, is one of the crimes that is criminalized in order to protect the security of society. This crime is organized and the methods of committing it are constantly evolving. In this way, the vital information of one country is transmitted to other countries or groups. In most of the criminal laws, there is no specific definition of espionage crime and only examples of it are sufficient, and this requires that the concept and legal framework of this crime be examined, so in the form of an interpretive-comparative method and referring to jurisprudential sources. A comparative study of the elements of this crime in the Iranian penal system with the countries of the Persian Gulf Cooperation Council has been carried out. This article seeks to first determine the punishment for espionage in the GCC countries and then examine how these countries deal with spy criminals, especially (sources, informants) of the countries' intelligence services, and its severity up to What is the limit? The present study seeks to examine the elements of espionage in these countries and to discuss its commonalities and differences.