ZAKAZAĆ CZY KONTROLOWAĆ? ANALIZA PORÓWNAWCZA POSTAW ADMINISTRACJI STANÓW ZJEDNOCZONYCH I UNII EUROPEJSKIEJ WOBEC APLIKACJI TIKTOK .......... 136

TO BAN OR TO CONTROL? COMPARATIVE ANALYSIS OF USA AND EU APPROACHES TOWARDS TIKTOK

Recent developments regarding the TikTok ban in the US have sparked a debate over threats posed by this social media platform and the possible ways to mitigate them. Governments approach this in a twofold manner. The application is either outright banned or systematically regulated. This article argues that the United States and the European Union exhibit distinct approaches to regulating online platforms. To support this claim, the analysis focuses on the possible risks of using TikTok and the regulations of this social media application introduced in the US and the EU. In the first part of the article, the platform is characterized with regard to its main functions and the number of worldwide users. Then, the main threats posed by TikTok, i.e., the spread of disinformation and conspiracy theories, risks to mental health, and problems with national security and digital sovereignty, are analyzed. The final part of this article examines legislative solutions to these threats proposed by the US and the EU. Anti-TikTok narratives are analyzed in documents such as the key executive orders, legislative proposals, and the PAFACA Act, as well as several acts of the EU, namely the GDPR, the DMA, and the DSA. Overall, the analysis points out differences between American and European attitudes toward TikTok.