terrorism is not associated with any one religion.192 In some contexts, detecting radicalized and suspicious behavior has, in practice, become interlinked with identifying more devout religious expression. Such practice raise concerns about the potential for discrimination on the grounds of religion or belief and arbitrary interference with the freedom to hold or manifest one’s religion or belief itself. The inviolability of the right to freedom of thought is likewise jeopardized when states focus their counter-terrorism policies on beliefs and ideologies rather than actual criminal conduct. Counter-terrorism measures should, therefore, be carefully focused on conduct with a proximate relationship to violence or with another unlawful act, such as incitement to discrimination, hostility or violence, as defined in accordance with international human rights standards.193 Preventive measures with a stigmatizing and discriminatory effect are counter-productive because they can be used by “violent extremist groups as propaganda to undermine these efforts”.194 Countering Violent Extremism while Protecting Freedom of Expression Concerns also arise regarding the impact on freedom of expression of steps to prevent VERLT and counter the recruitment and mobilization of FTFs. It is essential that states counter the use of social media and the Internet by groups like ISIL to recruit FTFs and promote violence. They can and must do so in full compliance with the right to freedom of expression. Over-reaching approaches to curbing free expression are also counter-productive and run counter to objectives of preventing VERLT. Freedom of expression, often described as one of the essential foundations of democracy, embraces the freedom to express ideas and opinions that “offend, shock or disturb”.195 Its significance is captured in the oft-cited judgment of the ECtHR which notes that “such are the demands of […] pluralism, tolerance and broadmindedness without which there is no ‘democratic society’”.196 The right to free expression is not absolute and can be restricted in line with strict criteria. However, restrictions must be prescribed by law, pursue one of the legitimate aims listed in relevant international standards (namely the protection of the rights or reputations of others or the protection of 192  This is consistently reflected throughout the OSCE’s terrorism-related commitments, such as the 2016 OSCE Declaration on strengthening OSCE efforts to prevent and counter terrorism, op. cit., note 152; the 2015 OSCE Ministerial Declaration on VERLT, op. cit., note 152; the 2014 OSCE Ministerial Declaration on FTFs, op. cit., note 2; the 2012 OSCE Consolidated Framework for the Fight against Terrorism, op. cit., note 59; and the “OSCE Charter on Preventing and Combating Terrorism”, adopted by the OSCE Ministerial Council in Porto on 7 December 2002, MC(10).JOUR/2. 193 See: Preventing Terrorism and Countering Violent Extremism and Radicalization that Lead to Terrorism, OSCE, p. 42-43, op. cit., note 73. 194  “The Hague-Marrakech Memorandum on Good Practices for a more Effective Response to the FTF Phenomenon”, Global Counterterrorism Forum (GCTF), <www.thegctf.org/documents/10162/140201/14Sept19_ The+Hague-Marrakech+FTF+Memorandum.pdf>, (hereafter, The Hague-Marrakech Memorandum). The GCTF is an informal multilateral counterterrorism platform, which was founded by 29 states – from within and outside of the OSCE area – and by the European Union. The GCTF “Foreign Terrorist Fighters” (FTF) Initiative drew together global policy makers who prepared the Memorandum in 2014. 195  Handyside v. The United Kingdom, ECtHR, Judgment of 7 December 1976, para. 49. 196  Ibid. Guidelines for Addressing the Threats and Challenges of “Foreign Terrorist Fighters” 55