breadth and lack of precision, increasing the risk that the “Security Council dictate may be used by states to nefariously target those who disagree with them”.54 The challenge for states is to define and approach the problem in a manner that avoids these pitfalls. In this context, it is crucial to underline that UNSC Resolutions 2178 (2014) and 2396 (2017) explicitly note (in several operative paragraphs and the preamble) that the obligations enshrined therein must be applied consistently with human rights, international humanitarian law and refugee law. Echoing the UN’s 2006 Global Counter-Terrorism Strategy, UNSC Resolution 2178 (2014) also stresses the complementarity of effective counter-terrorism measures and the protection of human rights by: “Underscoring that respect for human rights, fundamental freedoms and the rule of law are complementary and mutually reinforcing with effective counter-terrorism measures, and are an essential part of a successful counter-terrorism effort” and noting “the importance of respect for the rule of law so as to effectively prevent and combat terrorism”.55 The obligation to respect human rights in countering the threats posed by FTFs has been reiterated in numerous subsequent declarations and conventions, including in the 2015 European Union (EU) Joint Riga Statement following the Charlie Hebdo attack in Paris56 and the Additional Protocol to the Council of Europe Convention on the Prevention of Terrorism, which focuses on FTFs.57 The OSCE Ministerial Council Declaration on the role of the OSCE in countering the “FTF phenomenon” acknowledged the threats that FTFs may pose and made a host of specific commitments to take “resolute action to counter foreign terrorist fighters”.58 At the same time, OSCE participating States pledged to do so “in compliance with our OSCE commitments, and with all obligations under international law, including international 54  Ibid. 55  Preamble to UNSC Resolution 2178 (2014), op. cit., note 1. The “UN Global Counter-Terrorism Strategy”, consisting of a UN General Assembly resolution and an annexed Plan of Action, comprises four pillars, which include measures to ensure respect for human rights for all and the rule of law as the fundamental basis for the fight against terrorism (fourth pillar); see: UN General Assembly Resolution 60/288 adopted on 8 September 2006, UN Doc. A/RES/60/288. 56  “Riga Joint Statement”, Council of the European Union, 2 February 2015, <http://data.consilium.europa.eu/ doc/document/ST-5855-2015-INIT/en/pdf>. 57  See: “Additional Protocol to the Council of Europe Convention on the Prevention of Terrorism”, Council of Europe, adopted on 22 October 2015. Article 8 of the Additional Protocol provides that each Party shall implement the Protocol, “while respecting human rights obligations, in particular the right to freedom of movement, freedom of expression, freedom of association and freedom of religion, as set forth in, where applicable to that Party, the Convention for the Protection of Human Rights and Fundamental Freedoms, the International Covenant on Civil and Political Rights and other obligations under international law.” 58  These commitments reflected those enshrined in UNSC Resolution 2178 (2014), op. cit., note 1. They included commitments to: co-operate to find, deny safe haven to and bring to justice FTFs; to devise and adopt effective measures to prevent the financing of terrorism, and the movement of FTFs, through effective controls on borders and documentation, and to address the use of the internet for terrorism purposes, as well as to prepare for and mitigate the threat posed by FTFs upon return. 18 Guidelines for Addressing the Threats and Challenges of “Foreign Terrorist Fighters”