98. International case law has affirmed the unlawfulness of exploiting gaps in the law to silence human rights defenders. In the case of one human rights defender sentenced to administrative detention for holding an unauthorized assembly, in spite of the fact that the domestic law required no such authorization, the ECtHR held that there had been a violation of freedom of assembly, among others, given the existence of a legislative gap concerning this right.139 99. The UN Special Rapporteur on the situation of human rights defenders has noted with concern “a disturbing trend towards the criminalization of activities carried out by unregistered groups.”140 Moreover, in this context, groups whose attempts to register are repeatedly rejected become easy targets for criminal prosecution when they continue to operate. In the participating States that require prior authorization for NGO funding received from abroad, human rights defenders may face criminal penalties if they fail to comply with the authorization requirement. This practice has been condemned by the UN Human Rights Committee, which has pointed out that non-governmental organizations should be able “to discharge their functions without impediments which are inconsistent with the provisions of article 22 [freedom of association] of the Covenant, such as prior authorization, funding controls and administrative dissolution.”141 Similarly the UN Committee on the Rights of the Child has expressed concern at the criminalization of members of NGOs operating without being registered.142 100. Similarly, laws designed to prevent and prosecute terrorism and “religious extrem- ism” have often been invoked to criminalize activities by human rights defenders. The above-mentioned restrictions on NGO funding have been abused in order to silence human rights groups under the guise of combating terrorism financing and money laundering.143 Concerning national security legislation, the UN Special Rapporteur on the rights to freedom of peaceful assembly and of association has reiterated the concern about the use of “an amorphous concept of national security to justify limitations on the enjoyment of human rights”, a concept that “is broadly defined and is thus vulnerable to manipulation by the State as a means of justifying actions that target vulnerable groups such as human rights defenders, journalists or activists.”144 139  See European Court of Human Rights, Vyerentsov v. Ukraine, Application no. 20372/110, Judgement of 11 April 2013. 140  Report of the Special Rapporteur on the situation of human rights defenders, A/HRC/25/55, para. 68. 141  “Concluding Observations of the UN Human Rights Committee on Egypt”, UN Doc. CCPR/CO/76/EGY, 28 November 2002, para. 21. 142  Concluding Observations of the UN Committee on the Rights of the Child on Belarus”, CRC/C/BLR/CO/34, 8 April 2011, paras. 23-24. 143  See for example, Report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association, UN Doc. A/HRC/20/27, May 21, 2012, para. 94; and Report of the Special Rapporteur on the situation of human rights defenders, UN Doc. A/64/226, August 4, 2009, para. 94. 144  See Report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association A/ HRC/23/40, para. 60. 56 Guidelines on the Protection of Human Rights Defenders