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Counter Extremism Project

CEP

The Counter Extremism Project (CEP) is a not-for-profit, non-partisan, international policy organization formed to combat the growing threat from extremist ideologies.

Lobbying Activity

Meeting with Thierry Breton (Commissioner) and

9 Dec 2020 · Roundtable with NGOs on DSA and DMA

Meeting with Radosław Sikorski (Member of the European Parliament)

7 Dec 2020 · "The Financing Of Right-Wing And Ethnically Or Racially Motivated Terrorism"

Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

29 Jun 2020

The Counter Extremism Project (CEP) welcomes the opportunity to provide feedback on the European Commission’s inception impact assessment on The Digital Services Act package: deepening the Internal Market and clarifying responsibilities for the digital services. We believe that retaining the current framework for platform regulation under the e-Commerce Directive would leave the European Union unable to effectively regulate platforms in the 21st Century. To the detriment of users and public security, online platforms continue to play a significant role in the spread of terrorist and illegal content online. Relying on the voluntary efforts of private for-profit platforms to remove terrorist propaganda has failed. Such unfettered reliance risks the safety and security of EU and global citizens. Such reliance fails to recognise that social media companies are no longer the small fish in the big pond of the internal market, but that they are billion-dollar companies that regulate content on their platforms in accordance with their own terms of service. Accordingly, CEP favours a more comprehensive legal intervention to update and modernise the rules of the e-Commerce Directive under a new Digital Services Act (DSA). Contrary to the impact assessment, we consider that the general prohibition on monitoring is a major hurdle to regulating the removal of illegal and terrorist content by platforms. CEP recognises the need to create an effective system of regulatory oversight, enforcement and cooperation across the member states with a central body at European level. Concretely, we advocate for content moderation by effective notice and takedown procedures and automated tools with human verification, as envisaged in the Commission’s impact assessment. CEP supports providing SMEs with automated decision-making systems and an increase in algorithmic transparency for platforms that deploy automated tools. The “EU Ethics Guidelines for Trustworthy Artificial Intelligence” of the EU High-Level Expert Group on AI highlighted the importance of transparency and explainability of automated decision-making systems that have a significant impact on the lives of EU citizens and others. Comprehensible transparency of automated decision-making systems would lead to improved accountability and would allow a new independent EU body to apply sanctions when appropriate. Such a body should draw on the experience of a technological expert group, comprising civil society, platforms, law enforcement and those working in research and development, to provide insights, expertise and recommendations. We consider that retaining the general prohibition on monitoring by platforms prevents them from adhering to their terms of service and the duty of care to protect users from terrorist and illegal content online. The European executive and the legislature ought to draw lessons from the use of notice and takedown procedures and the lack of over-blocking under the Network Enforcement Act (NetzDG). While CEP eagerly awaits the resumption of and development in the interinstitutional negotiations on the proposal to remove terrorist content online (TCO), we urge the European Commission to reflect on the lack of progress and to consider that the exceptions for terrorist content envisaged in the regulation may not come to fruition before the DSA is concluded. The EU must have effective rules on the moderation of terrorist and illegal content online to ensure the protection of its citizens, preferably via the TCO but ultimately recognised in and legislated for in the new horizontal DSA package.
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Response to Action Plan on anti-money laundering

11 Mar 2020

"Counter Extremism Project (CEP) and Berlin Risk have co-authored the policy paper, “Further Development of European Union Regulatory Framework for Cryptocurrencies necessary to Mitigate Risks of Terrorism Financing”. AUTHORS Dr. Hans-Jakob Schindler, Senior Director CEP and former Coordinator ISIL, al-Qaida and Taliban Monitoring Team, United Nations Security Council, in cooperation with Jennifer Hanley-Giersch, Managing Partner Berlin Risk and founding board member of Association of Certified Anti-Money Laundering Specialists (ACAMS), Germany Chapter and Dr. Daniel Eisermann, Senior Partner Berlin Risk and member of the German Council on Foreign Relations. SUMMARY Given the various cases of the misuse of cryptocurrencies by the members/supporters of terrorist groups to finance their right-wing or Islamist activities (e.g. Sri Lanka attack, 2019), maintaining the anonymity of the sender and receiver of cryptocurrencies presents a core challenge to countering the financing of terrorism (CFT). While anonymity is necessary to guarantee user privacy on the blockchain, the use of mixing services and tumblers, that break up individual transactions and re-assemble them in a different form, weakens the argument that the public record of the transactions in the blockchain sufficiently mitigates the risk of illicit misuse. The ability to transact from one cryptocurrency to another, is a risk that remains unregulated, with the single (insufficient) hurdle of the regulated fiat-to-cryptocurrency and crypto-to-fiat currency exchanges. The risk will rise with the adoption rate of this asset class. The full report with key footnotes is in the supporting documents. Queries can be directed to Marco Macori, CEP Research Fellow: mmacori@counterextremism.com; Tel. +49 30 300 149 3369. RECOMMEDNATIONS Beyond the 5th Anti Money Laundering Directive (under which the EU decided that virtual asset service providers should be regarded as obliged entities, adhering to the reporting requirements for financial institutions), EU harmonising regulation is needed to mitigate exploitation of national difference by terrorist groups, such as those migrating from the regulated U.S. approach. Four areas of action are required to mitigate CFT risks with cryptocurrencies: 1. Define crypto assets as a distinct regulatory sector in the European Supervisory Authorities' ""Risk Factor Guidelines"", to prevent only regulating the new asset class in certain sectors, thereby eliminating/reducing regulatory loopholes for other sector who have/are likely to adopt the asset. 2. Increasing cooperation between European Financial Intelligence Units (FIUs), since cryptocurrencies are specifically engineered to facilitate cross-border transactions, by building on the European Banking Authority’s (EBA) existing mandate and developing the FIU Dashboard through which the exchange investigative information and the provision of technical capabilities/capacities would be facilitated. 3. Regulating crypto-to-crypto exchange, since the 5AMLD focuses only on the exchange between fiat and cryptocurrencies. Maintaining a sole regulatory hurdle against to detect illicit misuse of cryptocurrencies seems insufficient, given the rising adoption rates of cryptocurrencies which could lead to other economic sectors adopting cryptocurrencies as tender. 4. Responding to the challenges posed by privacy coins, non-custodial wallets and exchanges, which offer enhanced protection of user data and remove intermediaries, presents serious CFT challenges. Unless and until new effective and efficient investigative technological tools are developed for general market monitoring, it is necessary to prohibit the use of coins, wallets and exchanges in the EU. The alternative approach of having FIUs directly monitor all such transactions via public private partnerships would require significant technical expertise and funding resources, which seems to not be currently feasible."
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Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson)

31 Jan 2020 · Terrorist content online

Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)

21 Sept 2018 · tackling illegal content online; onlilne platforms