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比较中美两国保密法规对于国家秘密的界定,无论是内涵与外延还是原则与方法,都存在较大的差异性。如果一定要寻找共性,只能说在事关国家安全和利益这一点上是相同的。但是,如何界定国家安全和国家利益,以及进一步确保国家安全和国家利益的实现,中国和美国的选择却完全不同。看似简单的是以“公开为原则”还是以“保密为原则”的争论,背后折射出的却是中美两国制度理念的巨大差异性。
Comparing the confidentiality laws between China and the United States has great differences in the definition of State secrets, both in terms of connotation and extension, as well as principles and methods. If we must look for commonality, we can only say that it is the same thing that concerns national security and interests. However, how to define national security and national interests and further ensure the realization of national security and national interests, the choices made by China and the United States are completely different. What seems simple is the controversy on the principle of “openness” or “the principle of confidentiality”. What is reflected behind this is the huge difference in the concept of system between China and the United States.