A/HRC/40/52 shielding them from any risk of liability under counter-terrorism legislation. Overregulation has translated into refusal to deal with civil society actors operating in or with “high-risk” environments or actors,90 limits on access to financial services, refusal to open or arbitrary closure of bank accounts, inordinate delays or termination of transactions, and onerous administrative requirements.91 52. The processes that involve delegations of regulatory powers in the complex field of terrorism – where national legal requirements are in themselves overly broad and vague – should, in the view of the Special Rapporteur, not be left to private actors that may not have the ability and resources to develop human-rights based rules that fully comply with the rule of law and that provide sufficient accountability mechanisms should allegations of human rights violations emerge. H. Overlapping, cumulative and sustained forms of harassment 53. Civil society actors of all walks of society – academics, prominent human rights defenders, such as Amal Fathy, a member of the Egyptian Commission for Rights and Freedoms, 92 Cemil Tekeli, professor of law at Medeniyet University in Istanbul and a member of the International Jurists Union,93 Taner Kilic, Chair of Amnesty International Turkey,94 and Saeed Baloch, the Secretary General of the Pakistan Fisherfolk Forum and a member of the Human Rights Commission of Pakistan, 95 as well as individuals working for national and international NGOs, bloggers, writers, lawyers, translators, doctors, artists and film directors, such as Oleg Sentsov, 96 representatives of indigenous and minority groups, trade union activists and refugees, as well as entire groups, such as women and lesbian, gay, bisexual, transgender and intersex activists, and religious and indigenous groups, even populations of entire countries 97 – are increasingly subjected to a range of overlapping harassment measures broadly linked to countering terrorism. Importantly, multiple allegations dealt with under the mandate point to the layered, overlapping and sustained nature of the measures taken to target members and groups of civil society. The ensuing exponential cumulative impact serves to discredit civil society as a whole. I. Media campaigns 54. Contained within concerted efforts to silence civil society, legislative restrictions have sometimes been reinforced by governmental smear campaigns, through Statecontrolled media or through statements by public officials, including Heads of State, 98 whose objective is to delegitimize civil society and tarnish the reputation of its actors, by loosely characterizing them as “terrorists”, implying that they are “threats to national security” or “enemies of the State”, even by lobbying other States or through international forums. Such methods increase the vulnerability of all civil society actors, contributing to the perception that they are legitimate targets for abuse by State and non-State actors.99 J. Physical harassment 55. An extensive range of civil society actors are increasingly subjected to serious violations of non-derogable rights. Multiple communications received by the mandate 90 Martin Arnold and Sam Fleming, “Regulation: banks count the risks and rewards”, Financial Times, 13 November 2014. 91 A/HRC/23/39/Add.1, para. 84. EGY 14-2018 ISR 5-2018 TUR 1-2018. PAK 4-2016. RUS 16-2018. USA 2-2017. PHIL 4-2018. A/HRC/13/22, para. 27. 92 93 94 95 96 97 98 99 15