A/HRC/40/52 proliferation of these entities and norms – importing language from one another – contributes to increased fragmentation of global counter-terrorism regulation in ways that are not fully appreciated. 31. For example, the mandate of the Financial Action Task Force was extended to include the prevention of terrorism financing in the weeks following 11 September 2011, without any consultation with national parliaments or civil society. Its recommendation 8,52 which aims to protect non-profit organizations from terrorist financing abuse, was premised on an alleged high vulnerability that civil society organizations had to terrorism financing. 53 Many measures States were asked to take seriously limited the ability of non-profit organizations to operate (obligation to register, to maintain information on the purpose and objectives of the organization’s activities, to issue detailed annual statements and to maintain records of all transactions), while dissuasive sanctions, such as the freezing of accounts, removal of trustees, fines, decertification, delicensing and deregistration, were envisaged.54 Despite the obvious risks of this recommendation and its lack of reference to human rights, there was no consultation with civil society. The Task Force lent a veneer of legitimacy to States that, without due respect for their international human rights obligations, turned soft law to hard law by implementing the provisions of recommendation 8 through wholesale measures that strictly regulate civil society, in violation of the principles of proportionality and necessity, regardless of actual activities, evidence of collusion in terrorism financing, and risk of collusion, which has been widely disputed and its significance minimized, including by the previous mandate holder.55 32. Similarly, the Global Counterterrorism Forum is an informal regulatory body established by 29 States plus the European Union. By bringing together experts and practitioners and developing tools and strategies, it has the laudable overarching mission of reducing the vulnerability of people worldwide to terrorism. It deals with numerous issues having immediate relationship with human rights. 56 While the Forum notes its support for the United Nations Global Counter-Terrorism Strategy, which has a strong human rights component, the Forum itself, starkly and surprisingly, has no structural commitment to human rights protections. 57 Occasional and generic references to human rights in Forum documents do not assuage this profound concern. The Forum also lacks accessibility for a wide range of actors, including civil society, that ought to be meaningfully consulted on these topics. The closed nature of the Forum should spark concern for all States (particularly those excluded from that body); it also demonstrates the broader pattern of civil society exclusion from global counter-terrorism governance. The lack of inclusion has an organic relationship with the downstream targeting, marginalization and discrimination experienced by civil society actors and human rights defenders. III. National measures and trends affecting civil society 33. The security pandemic has translated into various measures that States have taken that have curbed civic space, which cannot be seen in topical, temporal or geographical vacuums. The lack of adequate definitions is central to the global closing of civic space and underpins most of the subsequent challenges at the national level. Also, there is a clear interaction between multiple measures taken to close civic space. For example, campaigns to discredit civil society can precede the adoption or arbitrary application of legislation. 52 53 54 55 56 57 10 The Task Force has issued 40 non-binding recommendations, as well as interpretative notes, best practices and a handbook for countries and assessors. In the initial (2012) interpretive note to recommendation 8, it was stated that it had been demonstrated “that terrorists and terrorist organizations exploit the [non-profit organization] sector to raise and move funds, provide logistical support, encourage terrorist recruitment, or otherwise support terrorist organizations and operations”. Interpretative note (2012), point 5(b)(vii). A/70/371, paras. 22–24 and 26. See www.thegctf.org. The Forum identifies supporting the implementation of the Strategy as a main goal, including the pillar relating to human rights, although in practice is it unclear how it does so.