underscored that there is also a need for states to comply with international human rights law while countering terrorism. To be in conformity with international standards, any limitations to the right to freedom of association, including with respect to funding, must not only pursue a legitimate aim but also be necessary and proportionate to that aim. As the Special Rapporteur pointed out, it is a violation of international law to use counter-terrorism or “anti-extremism” measures as a pretext to constrain dissenting views or independent civil society.311 214. In some participating States, NGOs that receive foreign funding are labelled as “foreign agents” or otherwise subjected to negative portrayals of their work and overall role in society. Regulatory measures “which compel recipients of foreign funding to adopt negative labels constitute undue impediments to the right to seek, receive and use funding”.312 Such labelling may create an atmosphere of mistrust, fear and hostility towards the affected individuals and organizations and lead to their extensive stigmatization. This hinders the efficiency of independent human rights work and may threaten the dignity, integrity and security of human rights defenders. Such laws and practices “undoubtedly represent an interference with the exercise of the right to freedom of association and of freedom of expression without discrimination”313 and should be promptly amended or repealed. In some participating States, the non-compliance with such regulations may lead to heavy fines or even criminal charges against human rights defenders and result in their imprisonment. 215. Participating States should facilitate the access of NGOs and other associations to both domestic and foreign funding and other resources by assisting them and supporting their efforts to seek and obtain funds for independent human rights work. Participating States should refrain from imposing restrictions that directly or indirectly discriminate against certain groups of human rights defenders, and should ensure equal and non-discriminatory access to public funding. Necessary measures should be taken to make the relevant procedures transparent and fair and to circulate calls for applications as widely as possible, without excluding particular NGOs owing to the particular human rights issues on which they work. Government funding or other means of support shall not be used as a tool to put pressure on NGOs to influence their activities or internal decision-making processes. 311  A/HRC/23/39, 24 April 2013, paras. 22 and 23. 312  A/HRC/23/39, 24 April 2013, para. 82(d). 313  Venice Commission and OSCE/ODIHR, “Joint Interim Opinion on the Draft Law amending the Law on Non-Commercial Organisations and other Legislative Acts of the Kyrgyz Republic”, CDL-AD(2013)030, 11-12 October 2013. Guidelines on the Protection of Human Rights Defenders 99