Gilles de Kerchove has been the EU Counter-Terrorism Coordinator since September 2007. From 1995 to 2007, he was Director for Justice and Home Affairs at the Council Secretariat. From 1999 to 2000, he was deputy secretary of the convention that drafted the charter of the fundamental rights of the European Union. Between 1986 and 1995, he worked for the Belgian government. He is also a European law professor at the Catholic University of Louvain, the Free University of Brussels, and the Université Saint Louis-Brussels, and has published a number of books and articles on European law and security issues.
CTC: What role does the European Union’s Counter-Terrorism Coordinator play?
De Kerchove: The position was created by the Heads of State and Government in the wake of the 2004 Madrid bombings, and I am the second incumbent, having been in the job for 13 years. The aim is to contribute to the implementation and evaluation of the E.U.’s counterterrorism strategy as well as to ensure coordination between the various relevant policy strands. This implies, on the one hand, to support coherence between the E.U.’s internal and external counterterrorism (CT) policies and to foster better communication and cooperation between the E.U., third countries,a and international organizations such as U.N., NATO, IMF, WB, etc.; and, on the other, to present policy recommendations and propose priority areas for action to the European Council and to the Council,b informed by threat analysis and reports not least from INTCENc and Europol.1
Heads of State and Government wanted someone to look into every aspect of CT and identify loopholes in cooperation, not only at the E.U. institutions level in Brussels, but also between Brussels and member states. Additionally, they wanted an independent voice to assess policy and inject new ideas as well as identify and anticipate problems. I have always tried to spot looming problems to allow the system to start to prepare. I think I was probably the first to raise the issue of foreign terrorist fighters (FTFs) within an E.U. context, and I presented a package of ideas as early as 2013. Now I am focusing on what I call the effect of disruptive tech and extremist ideology, but I will explain that later. Our goal in the EU Counter-Terrorism Coordinator’s office is to alert the system and come up with relevant policy proposals.
In doing so, I am engaging with many different communities (intelligence, law enforcement, criminal justice, diplomats, development, humanitarian, Defence, Finance, private sector, non-profit sector, academia) inside Europe with its 27 member states, close allies, international organizations, as well as other external partner nations.
I do not really have a single counterpart in the American system. My counterpart in Washington could be said to be within the State Department, but when I visit, I also have meetings with senior officials in several other departments, depending on the issues: DOJ (access to digital evidence, encryption, cooperation between the FBI and Europol), DHS (aviation security, access to travel data (PNR,d APIe), counter violent extremism), Treasury (sanctions, terrorism financing). And then I also interact with the relevant parts of the intelligence community, including the ODNI [Office of the Director of National Intelligence], the NCTC [National Counter Terrorism Center], and the relevant counterterrorism person within the White House.
At the end of the day, I am not involved in operations but am rather looking at policy. But it is extremely important to be very close to the operational people, from intelligence, law enforcement, and prosecution. When I visit member states of the E.U., I always see the head of police, the head of the prosecution service, the head of the internal security service, and sometimes the head of the external intelligence service as well. The difference between the U.S. and E.U. is that the E.U. is not a federal state, as most of the policies in the areas that I am looking at are in the member states’ hands. The role is one that is very much in support of member states, but it has transformed a great deal in the past five years. After the Daesh [the Islamic State] attacks in Paris and Brussels, member states asked for a much more ambitious involvement of the E.U. in CT, which led to an increase in my office’s role and responsibilities to help coordination, as those attacks highlighted deficiencies in the system.
CTC: What is the biggest terrorist threat you see to Europe at the moment?
De Kerchove: The threat from terrorist organizations like Daesh and al-Qa`ida remains high, but it has morphed in different forms. The fact that the number of Daesh-inspired attacks has declined in the E.U. does not mean that the threat has disappeared. It primarily means that we have got better at detecting and breaking up terrorist plots, as demonstrated by continuing arrests of terrorist suspects in E.U. member states. Home-grown radicalization remains a challenge. Daesh’s presence on the internet remains strong. Extremist Islamist proselytization and violent right-wing propaganda create a fertile ground for terrorism. There are several additional risks which are of growing concern such as the hundreds of prison leavers convicted for terrorism-related offenses but who have served short sentences, FTF returnees, and FTFs and families still in Syria and Iraq, who—be they E.U. nationals or otherwise—need to be prevented from entering the E.U. undetected.
Over the course of the last two or three years, we have become increasingly concerned about the rise of attacks perpetrated by right-wing violent extremists. In 2019, Europe faced several terrorist attacks motivated by right-wing violent extremism. We’re also witnessing a dramatic rise of right-wing violent extremist propaganda on the internet and increasing cross-border connectivity (notably online) between right-wing violent extremists. Right-wing extremist terrorists in Norway, Germany, the United States, and New Zealand have all referenced previous atrocities and attempted to broadcast their own attacks online.
Finally, I worry about instability in Europe’s immediate neighborhood in the Middle East and North and West Africa, especially in Syria and Iraq as well as in Libya and the Sahel because the presence of terrorist groups there constitutes a threat to the EU’s security.
The threats from violent separatists in Europe is much reduced. In Northern Ireland, there is still a low level of what the British call national security incidents (attacks on police and prison officers), but these threats do not seem to have extended across the sea to Great Britain. Whilst the numbers of incidents have been low in recent years, the level of capability retained by terrorist groups in Northern Ireland remains serious. There was a concern that the potential reestablishment of a border between the north and the Republic of Ireland would maybe have a negative impact on security and inflame tensions; this has not materialized significantly to date, but concerns remain and recent arrests indicate that police and security services continue to work hard to keep the threat under control. The Spanish terrorist group ETA is completely over as an entity, thanks to the relentless efforts of the Spanish security apparatus. Two E.U. instruments have helped in this fight: the European Arrest Warrant (EAW), which changed completely the way Spain was able to secure arrests and deal with Basque terrorists hidden in other member states, and the Joint Investigation Teams (JITs), which facilitated the way in which the French and Spanish were able to crack down on the organization.
And I hope that I am wrong, but we may see the development of other forms of extremism like technophobia or something like that in the coming years. With the development of disruptive technologies, some people may feel disenfranchised or marginalized by this rapid evolution of technology and its impact on society, and they might react violently. We have maybe already started to see this develop during the COVID crisis, where we have seen 5G masts being burned2 and the offices of telecom companies being attacked. This is something that we have to monitor; it may evolve in a more worrying direction. And let us suppose that it is linked to environmental violence, people who believe that the world is close to collapsing and government is not taking the right decisions to address the warnings on global warming. They might believe that they need to use violence to wake the government up. You could see developments around this technophobia linked with some sort of ecological extremism. But this is not the core of the threat, which remains foremost violent Islamists and to a much lesser extent the rising right-wing violent extremism.
CTC: Thousands of Europeans are believed to have joined the Islamic State or al-Qa`ida-affiliated terrorist groups as foreign terrorist fighters (FTF) in Syria and Iraq. How is the European Union working to manage the potential threat they pose?
De Kerchove: This is a priority for me. Tens of thousands of people have left their own countries and joined Daesh, including about 5,000 Europeans. About 25 percent of them have returned to Europe and another 25 percent have died on the battlefield, but others could in the future perpetrate terrorist attacks at home or in third countries.
Internally within the European Union, we are working to implement agreed arrangements on our border security to ensure that known foreign terrorist fighters (both E.U. citizens and non-citizens) are detected and stopped at the EU’s external borders. Furthermore, as part of an interoperability project, the E.U. is connecting six centralized E.U. databases in the fields of security, migration, and borders so that border guards and police officers can, under precisely defined circumstances, check data in a comprehensive fashion, detect identity fraud, and hence better spot third-country terrorist suspects. The E.U. is also strengthening the use of biometric data in this context. For those who already returned, E.U. supports sharing of good practices (through a Radicalisation Awareness Network (RAN)f handbook). And a number of member states have specialized programs for children.
The E.U. has also been working on better access to battlefield information to support investigations, prosecutions of FTF returnees, and border security. We must ensure that foreign terrorist fighters can be investigated and tried in a court of law. To this end, we are studying how information gathered by coalition armed forces on the battlefield in Syria and Iraq can be made available to investigators and prosecutors, in ways that are useful during trial procedures. For the material collected by the Iraqi forces, we have been pushing a program for all the information collected to be indexed and digitalized so that it can be analyzed and processed properly. One of the reasons our member states are so wary of repatriating FTFs is a lack of evidence of the acts they committed on the battlefield in Syria and Iraq, which can be used against them in a court of law. If someone gets back to Europe and we do not have enough evidence, the best you can secure is three or four years in prison for the crime of participation in a terrorist organization, even if, based on intelligence information, you know he or she may have killed people. So, it is very difficult to tell the population that you are bringing back someone who is a real murderer and he will be back on the streets of Paris, Brussels, or Madrid three years after his return. The more we can get access to evidence, the more likely we will be to secure long-term sentences and the more likely the public and governments are to accept repatriation.
As this is material and information primarily collected by coalition military personnel on the battlefield, it is not easy for investigators and prosecutors in Europe to locate it and then introduce it into criminal proceedings in courts in member states. Prosecutors and judges are used to a specific forensic treatment of material, which battlefield information often lacks as it is not collected by police officers who are forensically trained but rather is picked up in a battle situation. The material or information is often fragmented and can only be used as a lead or supplement to other evidence. U.S. authorities have gained a lot of experience in the use of battlefield information in criminal proceedings since 9/11. In addition, the U.S. military has been able to collect battlefield information from important theaters such as Afghanistan and Iraq. For these reasons, the U.S. government is an important partner for us in this particular issue.
It is also important to address the legacy of the caliphate in Syria and Iraq. Member states are deciding on repatriations on a case-by-case basis; the E.U. is not involved. Some member states do seek to repatriate children but on a case-by-case basis, and they try to start with orphans. But the problem here is that sometimes the Kurdish-led Syrian Democratic Forces do not want to repatriate the children alone and want to send them back with their mothers.
Several member states are working to find a solution so that their nationals can be tried in the region where they committed their crimes. There is currently an ongoing negotiation between these member states and Iraq to try them in Baghdad courts. There are numerous challenges: the death penalty, fair trial, what to do post-conviction, who will detain them, and who will pay for all of this. The Kurds in Syria recently suggested they could do it themselves. They want to get international support to set up a court themselves, but this is not something the E.U. is involved in.
While we wait for an outcome of this negotiation or possible repatriation, the E.U. is exploring how to improve the situation in the camps and prisons in Kurdish-held territory in northeastern Syria. It is indeed important to reduce radicalization in the camps, in particular Al-Hol and its international annex, which is in the hands of the most radical women, and prevent them from becoming a time bomb for radicalization. The camps are a mess, and there is some money that is coming in through crowdfunding so the women can bribe the guards and arrange escapes. The kids are forced to follow sharia classes and are getting more and more radicalized in some cases. We should focus on trying to reduce these particular problems, as some of these children may end up going home one day and they will be a lot more radicalized than they were at the beginning. In addition, the sanitary conditions in the camps and prisons are very bad, including problems around tuberculosis, and we are very worried that COVID-19 may enter.3 This may lead to riots and prison breaks. We know Daesh is very keen to support flights and prison breaks.
The E.U. has just adopted a support package for the prevention of radicalization in northeastern Syria, which does include support for the camps. The following additional measures are currently being analyzed. First, we are trying to find ways to decongest Al-Hol by helping the return of Syrian women and children to their Sunni tribes in northeast Syria. There is a system of sponsorship for their return, similar to something that was run in Afghanistan, and we can support that process. I am also in contact with senior officials in Iraq to see if we can speed up the return of some of the Iraqi women and children currently in Al-Hol to Iraq. Second, we have been working to encourage a Prevent-type programg in Al-Hol through NGOs, focused in particular on children. Third, we are working to improve the detention conditions in the prison, something that the International Committee for the Red Cross (ICRC) in particular has asked us to do. There are currently several hundred young people detained with adults. They should never have been placed in a prison facility. The global coalition suggests that an existing youth rehabilitation center is expanded to be able to receive these young people. Fourth, an evaluation of the women in the international annex of Al-Hol would allow us to obtain a better picture of what is actually going on and to separate the most radicalized women from the rest, and offer more assistance, including psycho-social support and rehabilitation to the less radicalized women and their children.
There is still a window of opportunity to act right now. A new escalation could lead to the dispersal of terrorists, including possible travel of some FTFs to Europe. My efforts are focused on what we can do in the short- and medium-term to make sure the situation does not worsen.
The E.U. is also providing assistance to third countries to deal with FTF returnees and their families, including via the U.N. We have developed several programs to help Tunisia, the Western Balkans, and many other countries to do that in the best way possible.
CTC: In April 2020, German authorities thwarted a plot against U.S. military facilities by a network of Central Asians who, according to prosecutors, had contacts with high-ranking Islamic State figures in both Syria and Afghanistan.4 Can you talk us through how this plot fits into your sense of the threat in Europe, including from the Islamic State in Afghanistan?
De Kerchove: This plot shows, once again, that we should remain vigilant about the threat of Daesh attacks in Europe and that the threat does not come only from individuals who are inspired by terrorist propaganda online and act independently. Daesh continues to seek contact with potential attackers in Europe whenever it spots an opportunity to do so, to guide them in their attack plans. This should inform our response as well. The threat from Daesh remains diverse, and we need to prepare for a range of attack methodologies with widely divergent levels of sophistication and for attackers whose profiles vary a great deal.
Afghanistan does not represent the same level of terrorist threat to Europe as Syria. That said, we should never be complacent about the threat of armed terrorist groups, even if they are located far away from the E.U. Many Daesh and AQ affiliates do not currently focus on attacks in the West but would not hesitate to support or facilitate one if they had the chance. This applies to Daesh in Afghanistan, but also to Daesh and al-Qa`ida affiliates in Africa.
We have been working on the Central Asian threat picture for some years. Part of the problem of why a lot of Central Asians were joining Daesh in Syria and Iraq was that a lot of them were working in Russia and lost their jobs because of the economic crisis there. Many of the Central Asian countries they come from are not wealthy, making it difficult for them to return home to find employment or continue to support their families remotely with remittances. When these individuals lost their jobs and became disenfranchised, they started to become attracted by Daesh rhetoric. There was a very active Russian language propaganda effort from Daesh in Syria and Iraq, which drew some people there. That was not the E.U.’s top priority in 2015. The main focus was on the E.U.’s immediate neighborhood. Now there is a wide consensus to do a lot more in Central Asia. We have deployed a CT expert in the region, we have supported a number of UN projects in the region, and I have myself visited many of these countries.
CTC: There has long been concern about al-Qa`ida reemerging as a global threat, and it appears the group’s Yemeni affiliate had a significant role in the December 2019 shooting in Pensacola, Florida.5 What kind of threat does al-Qa`ida pose today? Would you place it as a higher or lower risk than the Islamic State or an ideology like the extreme right-wing?
De Kerchove: This is an important question because we sometimes underestimate the continuing threat from al-Qa`ida. AQ remains an important threat to Europe today. Core AQ, as well as affiliates such as AQ in the Arabian Peninsula, have long planned for mass-casualty attacks in the West, notably on aviation. Core AQ is still present in Afghanistan. Admittedly, the peace agreement between the Americans and the Taliban has explicitly foreseen that the link between AQ and the Taliban should be completely severed, but I do not know if this will happen. History shows that the Taliban have always lied on that front, so it is still a concern. AQ in the Islamic Maghreb and the organizations it controls are killing European soldiers in the Sahel through sophisticated attacks. They constitute a serious threat to countries in the region. In some regions, AQ’s branches are often stronger than Daesh affiliates.
Ranking the threat of terrorist organizations is not an exact science. There is little point in stating that one terrorist group represents a slightly higher threat than another. My general assessment is that the threat from Daesh and AQ to Europe remains high and that the threat from right-wing violent extremism has risen quite significantly.
The current threat within Europe is mainly from people who have no formal link to Daesh or al-Qa`ida and are inspired by the ideology. For these groups, attacks by people who endorse their ideology and who they later praise represent a low-cost attack strategy. The threat now comes more from inspired attacks rather than the kind of directed attacks we saw in the 2015 and 2016 attacks in Paris and Brussels.
In the past, the threat from AQ in the Arabian Peninsula, in particular to aviation, was very strong. At the moment, my assessment is that neither AQ nor Daesh have the capability to launch a major attack in Europe, but they still have the intent. They will not hesitate to attack if we let down our guard. There is still a threat to European citizens when they travel to other countries, and of course, there is a threat to the countries themselves where the groups are still active. If they are able to destabilize and make countries such as Mali and Burkina Faso ungovernable, it would pose a serious problem for everyone. This is why we have to help countries overseas to address the threats from al-Qa`ida and Daesh.
There are several places around the world where AQ keeps developing, and in fact, they have learned from their mistakes and become much more patient than Daesh. They understood that using extreme and indiscriminate violence was not the best way to attract hearts and minds. In the period when we focused on Daesh, AQ continued building, focusing on local grievances
In Syria, and Idlib in particular, where HTS [Hayat Tahrir al-Sham] and Hurras al-Din are active, there are a lot of violent people who are AQ related. And of course, you have AQ affiliated al-Shabaab in East Africa.
CTC: There is a lot of talk of a reemergent extreme right-wing as a major threat, yet the attacks we have seen remain predominantly lone-actor type attacks. Can you sketch out whether you see the potential for this escalating into something more organized?
De Kerchove: Right-wing violent extremist groups realize that lone-actor terrorism is more beneficial to them than any form of violence that they organize themselves. Structured right-wing violent extremist groups often know exactly how far they can go in their statements and in their activities to remain just within the limits of what is legal. In the meantime, they leave it to ‘fanboys’ on the internet to take action by themselves, without any risk to the organization.
Unorganized right-wing violent extremists, who used to get together at concerts, motorcycle gatherings and other events in the past, now meet online. I do not know whether the spate of lone-actor attacks could escalate into something more organized, but I think that—from the perspective of the violent right-wing extremist scene—a sustained campaign of lone-actor attacks can be far more effective. I am certainly expecting more of those.
In recent years, we have witnessed a growing number of right-wing violent extremist attacks. The extent of violent acts motivated by racism, xenophobia, and other forms of bigotry may actually be underestimated in Europe, as we do not have a uniform method of classification. Some attacks are counted as hate crimes; others are treated as ordinary forms of criminality. At [the] E.U. level, we need to agree on a methodology to systematically count and classify these attacks in order to appreciate the extent of the problem and to combat it better.
We see increased international connectivity between right-wing extremists, notably via the internet. Individual right-wing violent extremists often imitate and reference previous attackers when carrying out a violent act. A formerly disparate group of marginal extremists thus increasingly turn themselves into a well-connected movement with a coherent ideology structured around the notion of the “Great Replacement.”
There are some differences between the right-wing violent extremism in the U.S. and Europe, but I think they all share the common rhetoric with the Great Replacement book written by Renaud Camus.6 It is also notable how much jihadi rhetoric and ideology share with right-wing violent extremism rhetoric. It is often about misogyny, with Incel7 a good example of this particular aspect of the phenomenon. It is a lot about a rejection of globalization. It is often about projecting a black-and-white vision of the world, hatred of Jews and anti-Semitism. Anti-Semitism is not just linked to the right-wing, by the way; Islamist extremism is a case in point, but there is a strong strain of anti-Semitism on the far left as well, but this is linked to anti-Zionism and an anti-Netanyahu feeling rather than the exact same strands of ideology linked to the far right. There are some survivalists amongst those on the far right, and I acknowledge there is a wide diversity of elements in the right-wing violent ideology, but what is interesting is that there are some key ideas that tie them together—hatred toward Arabs and Jews, misogyny, anti-globalization, for example.
There are also foreign powers that are playing into this and extending their outreach into Europe as part of a hybrid warfare, which focuses on destabilizing Europe. There is an interesting confluence in online ideas at the moment. Terrorism speech, hate speech, and disinformation are all coming together. Disinformation has been pushed both by state actors and non-state actors. One of the policy answers I draw from that is that we need to have a greater coordination between various strands of policy work in the online space. We currently have three separate dialogues with internet companies: one on terrorism speech, which we will soon result in legislation; a separate one on hate speech; and a third one on disinformation. To be more efficient in our dialogue with technology companies, we should be bringing these three together, as the strands and necessary responses are likely interlinked.
We have not looked enough at the phenomenon of foreign fighters going to Ukraine. I was very impressed by the figures produced by the Soufan Center recently about the many hundreds of right-wing Europeans who had gone to fight in Ukraine on both sides of the conflict.8 There are more and more people traveling in Europe to rally and train around right-wing violent extremism groups in different parts of Europe. Fears around globalization, migration, “the Great Replacement,” and the threat to the white community are key elements that tie the right-wing violent extremists together on both sides of the Atlantic.
CTC: What other ideologies do you see on the horizon or at the moment that have the potential to pose a major terrorist threat to Europe?
De Kerchove: The potential future rise of new forms of terrorism, rooted in conspiracy theories and technophobia, is a cause for concern. Disinformation is not necessarily rooted in political ideologies, although it is often amplified by right-wing and left-wing extremists. We have already seen small-scale acts of violence caused by a belief in conspiracy theories—for example, as I already noted, against telecom masts—and given the amount of disinformation online, we could see more serious examples of this in the future. I am also concerned about increasingly violent ecologist and animal rights groups.
In parts of Europe, left-wing violent extremism is already a threat. Left-wing violent extremists are responsible for a large number of non-lethal attacks. Depending on how the economic crisis develops in the wake of the health crisis we are currently facing, inequality is going to be exacerbated, and this might inspire more violent left-wing extremism that could have the potential to become more lethal and more geographically dispersed than it currently is.
CTC: What indicators do you see of these kind of threats that are developing as a result of the impact of COVID-19?
De Kerchove: I do not have many indicators around these threats at the moment. But if I take only my country, Belgium, it is one which is always split along the border between the Flemish part and the Walloon. It is interesting to see that telecom company Proximus has had a lot of problems trying to deploy 5G in the southern part of the country, in contrast to the more economically dynamic northern part. This could be an interesting indicator.
We are just at the beginning of a major change in society. I do not think we realize how different the world will be in five years’ time thanks to artificial intelligence. A lot of it we can see coming very quickly and will have deep-reaching impacts. The way justice will be delivered in the future will no longer be the same. The delineation between law enforcement and intelligence might be a bit blurred, and the digitalization of everything will have an impact across society and security.
In the last two decades, the left-wing violent extremism menace was more located in Italy and Greece, and we still have some groups there, but the truth is Europe is not homogenous when it comes to left-wing and right-wing violent extremism. Right-wing violent extremism is, for the time being, a major concern in the northern part of Europe, Scandinavia, Germany, and the U.K., on top of what is happening in the United States, where some assess it is now a bigger threat than jihadism. Other countries, like France, emphasize left-wing violent extremism, like the ultra-gilets jaunes, the violent segment of the group.h
It is interesting because there was something like that going on just before 9/11, in the form of a very active anti-globalization movement. This was the main topic on the agenda when discussing emergent extremisms in Europe. You had groups of violent left-wing extremists traveling all over Europe to disturb G7 meetings, meetings of the European Council, and so on, and it was definitely a growing movement. And then 9/11 happened, and this disappeared completely for many years. But now we can see left-wing violent extremism coming once again. We have seen it in Germany last year, we see it at some big international events, and the French in particular are raising the issue as one of growing concern. And we may see, but of course this is just speculation for the time being, that it starts to grow once again because of the COVID-19 crisis and the economic fallout. I am in the midst of doing some work on this, in much the same way as I did some work on the right-wing violent extremism threat before. It is not at the same level of intensity as the right-wing violent extremism, but if you take the economic concerns and add those to some of the criticism that we see online with the debate around COVID-19 tracing apps and the perception that there is a big-brother society that is gathering data on people to control everything, we could maybe see this develop into something more coherent and growing dramatically.
CTC: We are entering a moment of great-power tension. This can have repercussions in the non-state actor space through the use of proxies. Do you see a rising threat in Europe from state-supported terrorist actors? For example, from Russia or Iran?
De Kerchove: No. But that is not to say that there are no violent consequences resulting from some third countries’ deliberate interference to weaken our democracy and undermine the European Union. While they do not use terrorist proxies, some foreign powers deliberately spread disinformation and conspiracy theories to divide us. Their support to ultra-nationalist and right-wing extremist worldviews indirectly fosters violence because this sort of propaganda also fuels the actions of violent extremists and terrorists.
The current stance of the E.U. is that we only placed the military branch of Hezbollah in Lebanon on the E.U. list of terrorist organizations in the wake of the attack in Burgas and a plot in Cyprus.i Some of our member states have chosen recently to go further than just the military branch.9 In Germany, it is not a formal listing, like in the U.S., but a ban, which is legally a bit different. I am not sure we would follow our American friends and expand to a listing for the whole organization, but it is important to note that the E.U. proscription is not a precondition for prosecution and anyhow we are active and vigilant on the organized crime aspect of the organization. The organization is indeed collecting money from all over the world with sophisticated money-laundering schemes with links to Africa, Latin America, using drugs and the like. Europol, working closely with the American law enforcement agencies, conducted a major operation called Cedarj a few years ago in which millions, if not hundreds of millions, of euro being laundered between cartels in America, Latin America, Europe, and Africa were traced and linked to the Lebanese Hezbollah group. We are not soft on the organization, but there is no unanimous decision to list the whole organization.
On Iran, the E.U. put a directorate within the Ministry of Intelligence [and Security] (MOIS) on the list of terrorist organizations, as well as two members of the Iranian government.10 This was done after a foiled attempt to murder an exiled Iranian from the Arab Struggle Movement for the Liberation of Ahvaz (ASMLA)k in Denmark, and the disruption of a plot to blow up the yearly meeting of the Mujahedeen-e-Khalk (MeK)l in Paris, which was due to be attended by Rudy Giuliani, President Trump’s close adviser. This is a new development, placing a part of the State of Iran and officials of Iran on the EU’s list. We have had several recent cases of proxy fights between Gulf States and Iran in the Scandinavian countries.11 This does not quite qualify as terrorism, but it is criminal behavior. It is, of course, unacceptable that other states use European soil as a place to target each other by proxy.
As to Russia, we have had several cases of major concern around killings of Chechens in Europe. The Germans are currently prosecuting someone for the killing of a Chechen commander on their soil.12 And there are cases like Sergei Skripal.m But these again are cases which do not meet the criteria of being terrorism. They are not done to influence the population or the host government into changing its policy. These incidents and attacks are more about internal Russian and Iranian domestic politics, targeting dissidents, with Europe simply the location where they are taking place.
CTC: Could you talk us through some of the impact of Brexit on European counterterrorism?
De Kerchove: It is always a bit difficult for me to express myself on this topic because we are in the middle of a difficult negotiation and I do not want to say anything which could have a negative impact on these negotiations. The starting point is what former Prime Minister Theresa May said, “Brexit means Brexit.” Brexit has consequences. Once you are no longer a member state, this means you no longer have the same rights as a member state. So that is the starting point, and I am sorry for that. The relationship will have to be different to that of other non-E.U. states who are in Europe like Norway or Switzerland as they are part of the Schengen free-movement space within Europe.
The second aspect, a lot of what we have been developing over the past 20 years in the field of justice and home affairs, like mutual recognition of criminal justice decisions or the availability of information, have only been able to develop as a result of very strong safeguards in place, and these safeguards are linked to human rights. We have the charter of fundamental rights, the human rights convention, and very strong rules on data protection and privacy. Some believe we are going too far in this direction, but that is where we are. And so it is difficult to have the same agreements in place with non-E.U. members who might not have the same safeguards in place in the future.
Having said this, I have spent the last 25 years of my life working in the field of security and justice in transatlantic affairs, going back to when Janet Reno was the U.S. Attorney General. During that time, we have built an amazing amount of cooperation between the U.S. and Europe. I would be very surprised if we did not do the same with the U.K. outside the European Union. I do not see why the U.K. would end up in a lesser position than the U.S. in this regard. So, it could be a U.S.-type relationship, and it is in our mutual interest to have a strong relationship. But there are legal constraints on what we can do, and I am sorry for that.
It is worth noting that intelligence is outside the E.U. framework. The E.U. 27 member states plus Norway, Switzerland, and the U.K. are working outside the E.U. framework already through the Counter-Terrorism Group (CTG) where they all meet. They have developed common platforms and databases, and there will not be any impact on this from Brexit. So, on the intel front, I do not see any impact. Where we will lose something—and I hope the negotiator will find a smart way to compensate for this—is the outstanding and very impressive input of the Brits on the policy side. I have myself worked very closely for the past 13 years with the U.K. in this regard, with numerous Home Secretaries, National Security Advisers, MI5, MI6, and others. In terms of ideas and shaping the policy, they were very creative and helpful. But we will keep talking to each other.
The U.K. has been and will remain an important partner in the fight against terrorism. Counterterrorism depends on swift and effective exchange of information, and on close operational and political cooperation. The E.U. and the U.K. are currently negotiating their future relationship, including a framework for cooperation in law enforcement and judicial cooperation in criminal matters, which will be the basis for future CT cooperation between the E.U. and the U.K. as a third country.
A lot of technical details are being addressed in the negotiations. Many E.U. instruments relevant for CT are based on the principles of mutual recognition and availability of information, which require certain essential safeguards (such as equivalent data protection standards, respect of the E.U. Charter of Fundamental Rights, supervision by the European Court of Justice), some of which are redlines for the U.K., which means that different ways for cooperation need to be found. As I already noted, there are models for cooperation with third countries in a similar situation, such as the U.S., where we have created a strong CT partnership over time. The Union’s ambition is clearly that the counterterrorism relationship with the U.K. will remain strong; it is in the interest of both sides.
CTC: You recently wrote a paper for the Council of the European Union looking at how terrorist threats were evolving as a result of COVID-19. What are the key takeaways?
De Kerchove: While the current health crisis appears to have had only a limited impact on the terrorist threat to date, there is an increased risk of terrorism in the future. We must prevent the current health and economic crisis from becoming a security crisis as well.
The terrorist threat depends on three factors: intent, capabilities, and resilience. Terrorists had the intent to stage mass-casualty attacks long before the current crisis. The diminished resilience of targeted countries as a result of the pandemic is already a cause for concern, and this could reinforce terrorists’ capabilities in the longer term. Extremist propaganda could resonate more as a result of the economic and sanitary crisis, strengthen terrorists’ morale, and expand the breeding ground for radicalization. COVID-19 might result in a diminished focus on CT among our law enforcement and armed forces and disrupt military and intelligence operations.
Right-wing violent extremism and terrorism was already on the rise before the pandemic. Violent right-wing extremists have been particularly shrewd in exploiting the coronavirus crisis, blaming minority groups, and spreading disinformation. Right-wing extremist hate speech and incitement to violence on the internet has increased dramatically since the start of the coronavirus crisis. Violence against minorities—particularly Jews—has increased during the pandemic. We need to tackle these problems and counter anti-Semitic hate speech and violence.
The pandemic has also sparked conspiracy theories that have no direct link to existing extremist ideologies. As I’ve already noted, as a result of such theories, telecommunications masts have been set on fire in several member states. The motivation behind this is linked to a movement of technophobes with indirect links to right-wing and left-wing violent extremists, which is gaining in strength.
CTC: Do you think there will be a reduction in CT and CVE (countering violent extremism) funding and attention post-COVID-19?
De Kerchove: I acknowledge that allocating the same level of resources to CT and CVE post-COVID-19 might be challenging, but I hope that policymakers will recognize that the prevention of terrorism remains crucially important. The E.U. is analysing the impact of COVID on terrorism and security more broadly in our neighborhood and beyond, and is providing COVID-related additional assistance. Given the probable rise in radicalization resulting from the health and socio-economic crisis, prevention and CVE will be even more important than before. Money spent on CVE is money well spent, especially in a time of crisis. Health, the economy, and security influence each other. Hence, we should prevent the emergence of a vicious circle of mutually reinforcing sanitary, socio-economic, and security problems.
CTC: Technology continues to advance rapidly, with disruptive technologies increasingly the norm from online innovations, artificial intelligence, quantum computing, robotics, novel materials, the internet of things (IoT), space, and more. These are impacting our daily lives with ever greater frequency. How do you think this will impact the terrorist threat picture and E.U. response?
De Kerchove: Around three years ago, I began to worry that at the E.U. level, not necessarily at the member state level, we may have overlooked the impact of digitalization and disruptive tech on security and criminal justice. We have not properly assessed the threats that they potentially pose. Nor have we understood or yet maximized the opportunities they provide for delivering security and justice in the future.
Disruptive technologies can be indeed looked at under three different angles: the threat that they create/amplify, the potential they offer to increase the effectiveness of the law enforcement agencies/justice, and the impact they have on the way we will provide security and justice in the future. It is important therefore that the security community devotes more attention to these techs.
From a threat perspective, terrorist and violent extremist groups are harnessing new technologies. For example, those groups use increasingly cryptocurrencies to raise funds in an undetected way. Online gaming is another new field which deserves to be looked at. The scale is unbelievable, with about two billion people playing games online, who could be potentially targeted by terrorist and violent extremist propaganda. Another example, COVID may inspire people to use bioweapons, having seen the impact that the virus has had.13 If I were the head of a terrorist organization, I would say, that is clearly the best way to cause chaos and disrupt the West. But at the moment, it is quite difficult to weaponize the virus. You may send some ricin or anthrax by letter, which people have tried, but with COVID, this is going to be much harder.
But I do not exclude that in the coming years, it will be possible for a lone actor to mount an attack with catastrophic consequences. The current assessment is that the lone actor will just use a knife or a car and mount a low-cost attack. But for someone with the relevant education, armed with the democratization of knowledge, it might be much easier to process a virus in a cloud lab.n So, when you look at the convergence of these threats, you see a quite dangerous potential threat on the horizon. Someone could process a virus in a cloud lab, take a drone and use a GPS geolocation system to steer the drone, and go to a football stadium to spread the virus created and kill 50,000 people. So, my point is that we need to properly assess every possible threat that these new disruptive techs might pose.
At the same time, the opportunities provided by big data analytics, notably to find weak signals on the internet, artificial intelligence, facial recognition technology, robots, drones, and more are already helping police as well as justice, and will likely do more in the future. From a European perspective, the key will be to make sure this takes place across the E.U.
There is also the transformative impact. For instance, within five years, we might lose a significant percentage of the workforce in the field of justice because machines will do some jobs better than humans. I have worked hard to try to convince E.U. institutions to invest a lot more on this, because we were a bit lagging behind.
Disruptive techs raise several huge challenges. First, we should ensure that law enforcement and the judiciary maintain their lawful tools of interception. On 5G, the E.U. is working towards ensuring that lawful interception remains possible, and is active in standardizing processes for such interception across the continent. The E.U. has worked on encryption for several years, in particular device encryption, via Europol and the European Commission’s JRC.o I believe there is a need for a more comprehensive, legislative solution.
Second, we see more and more the importance of data protection and privacy, with consequences on security. The question is, how much can we rebalance this relationship? One of the reasons why the Americans or the Chinese are much more advanced in AI than Europe is because every day, their firms get billions of data points from you and me. They get this information for free and can process it to help with their machine learning. In Europe, it is much harder for companies to get access to the volume of data necessary to train their algorithms because they are protected by GDPR [the European Union General Data Protection Regulation]. GDPR is a great achievement to curb the loss of control on personal data by Europeans, but its implementation should at the same time seek to foster innovation. It is then important to work closely with regulators and supervisors of data protection and fundamental rights, to take full profit of GDPR’s flexibilities to experiment, through regulatory sandboxes and testing facilities (where companies can test out new potentially disruptive technologies, and reflect on adapting/adopting regulation), [and] see how this might be used in the justice space as well as putting oversight mechanisms.
Third, disruptive techs also raise issues of sovereignty, and where information and data are kept. The COVID crisis has highlighted what current supply chains and dependencies look like with greater clarity, and in particular how dependent Europe had become on non-E.U. countries like China. To some degree, we are lagging behind the Americans and Chinese in most of these disruptive techs, and there is therefore a need to bolster transatlantic cooperation on this. Fortunately, this European Commission has decided to invest a lot into research technology and digitalization to catch up.
Turning back again to the threat that disruptive technologies create/amplify, there is a direct impact from internet companies and the degree to which social media companies have amplified the jihadist and right-wing violent extremist propaganda. We have started working on this, but not enough.
I’m worried by what I call algorithm amplification, whereby these companies—YouTube, Facebook, TikTok, and so on—design their algorithm in a way that they keep you online as long as possible because their business model is based on watch time for selling ads. And the issue is to hook people by giving them a lot more problematic content. I am not suggesting illegal content, but a lot more conspiracy theories, a lot more titillating material. It is like junk food. It is not by coincidence that junk food is full of salt to keep you coming back. It is the same with the internet; they bring stuff that is exciting and interesting and will draw you in. If you are interested in violent, hateful speeches, you will get more of the same and often more and more extremist content. It creates a common dynamic between disinformation, hate speech, and terrorist content.
There is a lot more we can do in this space. I have been working with the European Commission on looking at how we can bring the law enforcement and criminal justice community more into all these files and create an innovation hub at Europol which brings together all the interior and justice ministries from member states, as well as all the many European agencies that cover related security issues (Europol, Eurojust,p Frontex,q CEPOL,r eu-LISA,s etc.), with the ambition to later connect to cyber, space, and defense actors. We need people (at policy as well as operational levels) who understand all of the different issues to be able to deal with them.
CTC: There has been considerable debate about the threat posed by terrorist recidivism and whether prison sentences for terrorism offenders should be extended. A recent study in this publication by Thomas Renard that focused on Belgium argued that the phenomenon of terrorist recidivism, while a problem, has been “overblown.”14 What is your view on this issue?
De Kerchove: It is good that Thomas Renard has systematically looked at recidivism rates among terrorist convicts. His conclusions are reassuring, but of course, any terrorist attack committed by somebody previously convicted for a terrorist offense is one too many. In this context, it should also be borne in mind that terrorist acts have a very serious impact on society—more serious, in fact, than most ordinary crimes.
The fact that several hundred inmates convicted for terrorist-related offenses will be released from European prisons in the very near future also compels us to prioritize rehabilitation and disengagement efforts. Even if only a small number of them reoffend, then the sheer magnitude of the wave of prison releases still creates a significant additional security risk and pressure on security forces.
That is why I think the EU Council conclusions of 6 June 2019 on “preventing and combatting radicalisation in prisons, and on dealing with terrorist and violent extremist offenders after release”15 are important. The E.U. is supporting risk assessment and rehabilitation programs in prisons in member states and sharing of good practices and lessons learned.
CTC: What is the role of mental health and other personality disorders, and how does this affect the threat picture and response?
De Kerchove: This is a subject that attracts increasing attention among CT practitioners and policymakers, including at E.U. level. There is no clear profile or prototype of a terrorist. It is clear that mental disorders do not cause terrorist acts, but they sometimes influence terrorist behavior in connection with other—political, sociological—factors. There may be a greater than average prevalence of mental disorders notably among lone-actor terrorists. A number of lone actor terrorist attacks in Europe in the last two years—for example, in France, the U.K., and the Netherlands—were committed by lone actors with underlying mental health problems.
Given the increase in lone-actor attacks in the West, we should pay more attention to mental health issues in our policy response. The COVID-19 crisis, which is likely to exacerbate mental health problems in some individuals and to make them spend more time online, makes this an even more important topic.
How can we use knowledge on mental health in CT? We can, for instance, look at risk assessment tools: while psychopathology in itself is not predictive of terrorist behavior, mental health issues play a useful role in risk assessments, in combination with other factors. It is worth looking at it in rehabilitation and disengagement programs—using customized treatment to rehabilitate former terrorists or to achieve disengagement of radicalized individuals.
I know that much research on the role of mental health issues in radicalization and terrorism has been conducted with regard to jihadist radicalization. But we need to understand better what role mental health problems play in driving the men responsible for right-wing violent extremist attacks as well. The E.U.-sponsored Radicalisation Awareness Network (RAN) recently published a very useful handbook for practitioners on dealing with mental health in the context of CT.16
Finally, I am concerned about the mental health of the women and children in the camps in northeastern Syria with a risk of future radicalization and involvement in terrorism. I already talked about what we’re doing to prevent this from happening and why. On a case-by-case basis, member states are repatriating minors from the camp. It is important that they receive good psychiatric and psychological care.
CTC: What do you see as the biggest outstanding problems in CT and CVE?
De Kerchove: I have touched upon several of the biggest outstanding issues in CT during this interview. The fight against the rising threat of right-wing violent extremism and terrorism is certainly one of those. Contrary to the U.S., the E.U. legal framework applies to all forms of terrorism. I expect that the EU Internet Referral Unit at Europol will soon start flagging violent right-wing extremist content in addition to its current work on jihadi content. We also need to look into ways to curtail financing of right-wing violent extremist propaganda and step up prevention, rehabilitation, and exit programs; some member states have an interesting experience in this context.
We have been working for many years in the area of prevention of terrorism. The E.U. has been funding projects, for instance, among vulnerable youngsters to prevent radicalization. The E.U. is facilitating exchange of best practices between policymakers and practitioners (such as teachers, social workers, police personnel, etc.). We have always included all forms of radicalization in these programs, but we need to focus even more on right-wing and left-wing violent extremism in the near future.
Additionally, we need to do more to counter the ideologies that fuel terrorism, in particular Islamist extremism. While there is a range of factors that drive people to become terrorists, terrorism would not exist at all without underlying extremist ideology. Hence, we should not avoid this difficult subject, but talk about it. Many mainstream Muslims are worried about Islamist extremism dominating the dissemination of Islamic religious texts, supported by wealthy donors from the Gulf area. This is a problem for integration in the E.U., which the E.U. has started to analyse within its borders and beyond, and has initiated a dialogue with relevant third countries. It is important to take note of the many European Muslims raising concern about extremist Islamist influences which challenge the values, fundamental rights, and rule of law which bind Europe together.
We should do more to combat terrorist content, hate speech, and disinformation online while protecting the right to free speech. The E.U. is working on a new Regulation on Terrorist Content Online, which will oblige digital companies to block terrorist content within one hour when they are alerted to such content. At the same time, digital companies should do more to enforce their own terms and conditions on hate speech and disinformation. They need to stop the amplification of sensationalist hateful content via algorithms aimed at generating as much user traffic as possible.
Last but not least, the many threats that stem from the rapid digitalization of our society and the quick development of disruptive technologies, as I have explained above, call for a major investment of the security community in this field. The excellent communication on the EU Security Union Strategy that the European Commission adopted at the end of July17 illustrates the strong determination of the E.U. to rise to the challenges. CTC
[a] Editor’s note: Defined by the European Union as “a country that is not a member of the European Union as well as a country or territory whose citizens do not enjoy the European Union right to free movement.”
[b] Editor’s note: The European Council consists of “the heads of State or Government of the 27 EU Member States, the European Council President and the President of the European Commission” and “defines the EU’s overall political direction and priorities.” See https://www.consilium.europa.eu/en/european-council/. The ‘Council’ (full name: The Council of the E.U.) “is the institution representing the member states’ governments. Also known informally as the EU Council, it is where national ministers from each EU country meet to adopt laws and coordinate policies.” See https://www.consilium.europa.eu/en/council-eu/
[c] Editor’s note: INTCEN is the EU Intelligence and Situation Centre, a central intelligence collection and assessment body that works with the European Union’s foreign service, the European External Action Service (EEAS).
[d] Editor’s note: Passenger Name Recognition
[e] Editor’s note: Advance passenger Information
[f] Editor’s note: The Radicalisation Awareness Network (RAN) is an E.U.-sponsored network of practitioners across Europe that seeks to bring together best practices in counterterrorism and countering violent extremism (CVE) work.
[g] Editor’s note: “Prevent” is the pillar of the U.K. counterterrorism strategy that seeks to stop people from becoming terrorists or supporting terrorism.
[h] Editor’s note: The gilets jaunes (literally, yellow jackets) are a protest movement active across France.
[i] Editor’s note: In July 2012, a Hezbollah-linked suicide bomber targeted a busload of Israeli tourists in Burgas, Bulgaria, killing seven, including the bomber. The same month, Israel accused Hezbollah of plotting to attack Israeli citizens in Cyprus. Angel Krasimirov, “Bulgaria says clear signs Hezbollah behind Burgas bombing,” Reuters, July 18, 2013; Dan Williams, “Israel PM accuses Hezbollah of Cyprus attack plot,” Reuters, July 15, 2012.
[j] Editor’s note: According to congressional testimony by analyst Emanuele Ottolenghi, “DEA revealed the full extent of Hezbollah’s terror-crime nexus and its centrality to Hezbollah’s organizational structure in 2016, when it announced multiple Hezbollah arrests across Europe in an operation, codenamed Operation Cedar, involving seven countries. According to a former U.S. official familiar with the case, the targeted ring involved shipments of cocaine to Europe, which were paid for in euro, and were then transferred to the Middle East by couriers. Hezbollah made more than €20 million a month selling its own cocaine in Europe. It also laundered tens of millions of euro of cocaine proceeds on behalf of the cartels via the Black Market Peso Exchange, retaining a fee.” Emanuele Ottolenghi, “State Sponsors of Terrorism: An Examination of Iran’s Global Terrorism Network,” Testimony Before the House Homeland Security Committee Subcommittee on Counterterrorism and Intelligence, April 17, 2018.
[k] Editor’s note: The Arab Struggle Movement for the Liberation of Ahvaz (ASMLA) was established in 1999 seeking to establish an independent Arab state from Iran’s southwest. Iran classifies ASMLA as a terrorist group, and it has been linked to violent incidents within Iran, as well as in Europe where a number of the group’s members reportedly reside. For more information, see “The Story behind Iran’s ‘murder plot’ in Denmark,” BBC, October 31, 2018, and Nada Bashir, Euan McKirdy, and Kara Fox, “Denmark arrests suspect over Iranian ‘assassination’ plot,” CNN, October 31, 2018.
[l] Editor’s note: MeK is an Iranian group that opposes the regime in Tehran.
[m] Editor’s note: Sergei Skripal, a former Russian intelligence officer recruited by the British as a spy, was, according to the U.K. government, targeted for assassination by Russian military intelligence agents in the United Kingdom, but he survived the attempt to kill him with a military grade nerve agent. “UK blames Russian military intelligence agents for Skripal attack,” Financial Times, September 5, 2018; Michael Schwirtz and Ellen Barry, “A Spy Story: Sergei Skripal Was a Little Fish. He Had a Big Enemy,” New York Times, September 9, 2018.
[n] Editor’s note: Cloud labs refer to automated labs using AI to synthetize genetic sequences that can become the basis to produce a toxin or a bio-agent. See Eleonore Pauwels, “The new geopolitics of converging risks – The UN and prevention in the era of AI,” UN University, 2019.
[o] Editor’s note: The European Commission’s Joint Research Centre (DG JRC)
[p] Editor’s note: European Union Agency for Criminal Justice Cooperation
[q] Editor’s note: European Union Border and Coast Guard Agency
[r] Editor’s note: European Union Agency for Law Enforcement Training
[s] Editor’s note: European Union Agency for the Operational Management of Large-Scale IT Systems in the Area of Freedom, Security and Justice
 Editor’s note: For more on Europol, the European Union’s law enforcement agency, see Paul Cruickshank, “A View from the CT Foxhole: Catherine De Bolle, Executive Director, Europol,” CTC Sentinel 12:6 (2019).
 Editor’s note: See, for example, Nazia Parveen and Jim Waterson, “UK phone masts attacked amid 5G-coronavirus conspiracy theory,” Guardian, April 4, 2020.
 Editor’s note: For more on this issue, see Audrey Alexander, “The Security Threat COVID-19 Poses to the Northern Syria Detention Camps Holding Islamic State Members,” CTC Sentinel 13:6 (2020).
 “Attorney General William P. Barr and FBI Director Christopher Wray Announce Significant Developments in the Investigation of the Naval Air Station Pensacola Shooting,” U.S. Department of Justice, May 18, 2020.
 Editor’s note: For more on Camus, see Norimitsu Onishi, “The Man Behind a Toxic Slogan Promoting White Supremacy,” New York Times, September 20, 2019.
 Editor’s note: For more on the Incel subculture, see Zack Beauchamp, “Our incel problem: How a support group for the dateless became one of the internet’s most dangerous subcultures,” Vox, April 23, 2019.
 Editor’s note: For more on this, see Christopher F. Schuetze and Melissa Eddy, “Germany Hardens Ban on Hezbollah,” New York Times, April 30, 2020.
 Editor’s note: “Fight against terrorism: Council renews the designations on the EU terrorist list and adds two Iranian individuals and one Iranian entity in response to recent foiled attacks on European soil,” European Council press release, January 9, 2019. See also Jacob Gronholt-Pedersen, Robin Emmott, Anthony Deutsch, “In shift, EU sanctions Iran over planned Europe attacks,” Reuters, January 8, 2019.
 Editor’s note: For example, see Sune Engel Rasmussen, “Trial Exposes Iran-Saudi Battle in Europe,” Wall Street Journal, June 26, 2020.
 Editor’s note: For more on the potential implications of COVID-19 for counterterrorism, including in relation to bioterrorism, see Paul Cruickshank and Don Rassler, “A View from the CT Foxhole: A Virtual Roundtable on COVID-19 and Counterterrorism with Audrey Kurth Cronin, Lieutenant General (Ret) Michael Nagata, Magnus Ranstorp, Ali Soufan, and Juan Zarate,” CTC Sentinel 13:6 (2020).
 Editor’s note: “Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions on the EU Security Union Strategy,” COM(2020) 605 final, July 24, 2020.