Independence of National Preventive Mechanisms (NPMs) butions to the cantons for parts of the operational costs, in the form of per diem allowances for the detention of asylum-seekers, it is also able to exert de facto influence on detention conditions.68 Various other services within the FDJP are involved in other related areas and in their capacity as the ordering authority are authorized to arrest individuals, detain them, and to order other forms of deprivation of liberty. Specifically, the FOJ is responsible for the ordering of pre-deportation detention69 and in that capacity is also responsible for the enforcement procedures applied in such cases. Similarly, the SEM is responsible in certain cases for issuing pre-deportation detention orders and detention orders within the framework of the Dublin procedure.70 The SEM also shares responsibility with the cantons for air repatriations, in the course of which the application of measures of restraint is a regular occurrence.71 The foregoing list of examples amply demonstrates that the Confederation and, in particular, the FDJP holds authority in various areas that also fall within the scope of the NCPT’s mandate72 and over which it exercises oversight within the framework of its monitoring activities. This also means that the NCPT addresses a portion of its recommendations in the areas mentioned directly to the Head of the FDJP or to the directors of the respective FDJP services and is in direct and regular dialogue with them. Although the risk of substantive interference with the work of the Commission presently appears to be low, the potential for interest conflicts together with the Commission’s administrative proximity to the FDJP could be seen by outside observers as impairing its appearance of independence and have an impact on its credibility. Cf. Federal Act of 16 December 2004 on Foreign Nationals (Foreign Nationals Act, FNA) (SR 142.20) Art. 82. 68 Federal Act of 20 March 1981 on International Mutual Assistance in Criminal Matters (Mutual Assistance Act, IMAC) (SR 351.1), Art. 47. 69 Cf. AsylA Art. 111 (d), in conjunction with FNA Art. 76, para. 1 (b) (5) and FNA Art. 76a. 70 Cf. Art. of the Federal Act of 20 March 2008 on the Use of Police Control and Restraint Techniques and Police Measures under Federal Jurisdiction (Use of Force Act, UFA) [Zwanganwendungsgesetz, ZAG], UFO, Ordinance of 11 August 1999 on the Enforcement of the Refusal of Admission to and Deportation of Foreign Nationals (ERADO) [Verordnung vom 11. August 1999 über den Vollzug der Weg- und Ausweisung von ausländischen Personen, VVWA]. 71 FANCPT Art. 2 72 42 Activity Report NCPT 2017