Grasping the nettle: Ending Europe’s Trade in Execution and Torture Technology 53 should analyse the operation of the penalty regimes introduced by Member States, and assess whether such regimes are, “effective, proportionate and dissuasive”, in accordance with Article 17 of the Regulation. Where such penalty regimes, or their implementation, are deemed to be insufficient, the Commission should provide guidance and assistance to strengthen them. Finally, appropriate mechanisms should also be established so that information and proposals related to the effectiveness of the Regulation can be received from civil society bodies with relevant expertise (e.g. industry, academia, arms control and human rights organisations) and be considered by the review structures. Furthermore, the potential involvement of the Group of Experts established in 2012 to assist the Commission in its previous review of the Regulation, should be considered. Index: EUR 01/1632/2015 Amnesty International May 2015

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