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KEEP YOUR FRIENDS CLOSE, BUT YOUR ENEMIES CLOSER: THE ITALIAN MAFIA'S RELATIONSHIP WITH ISIS AND THE IMPLICATIONS FOR THE EUROPEAN UNION'S DEFENSE STRATEGIES.

I. INTRODUCTION

Since the 1860s, the Mafia has imbedded itself in the history of Italy, changing the trajectory of the country's social and political growth. (1) In the years since its establishment, the multiple Mafia groups in Italy have entrenched themselves in the country, leading to a thriving black market and a corrupt and fractured government. (2) In the early 2000s, across the Mediterranean Sea, another organized group emerged in the wake of the United States' War on Terror, the Islamic State of Iraq and Syria (ISIS). (3) Over the past few years, the Italian Mafia began to partner with ISIS through the black market trade, bringing up the question of whether these two organizations are merely business partners or ideologically compatible organizations. (4) Italy must use its Antimafia policies and prosecution efforts to suppress terrorism in its country and the European Union. (5) In order for there to be a real resolution, Europe will need to come up with joint-legislation to attempt to stop the spread of ISIS in Europe. (6)

This Note explores Italy's relationship with ISIS and the unfolding partnership between the Islamic State and the various Italian Mafia Organizations. (7) Part II will discuss the history of the Mafia in Italy, as well as the recent growth of ISIS. (8) Part III will look into ISIS's effect on the country today, the two organizations' relationship, and present dealings. (9) Part IV will look into Italy's current Antimafia policies and how these policies are essential to help develop new globalized policies to help combat ISIS and the Mafia, while also building stable states in the region. (10) Finally, Part V concludes in highlighting the need to implement Italy's Antimafia policies on a larger scale in order to diminish terrorism throughout the entire European Union. (11)

II. HISTORY

A. The Mafia in Italy

The island of Sicily and southern Italy have a storied history of dealing with foreign intruders and handling internal struggle. (12) Starting in 1812, Parliament abolished the feudal system in Sicily causing a modernization period where the social classes violently clashed as its citizens looked to establish a new social class. (13) Citizens with common interests banded together, forming clans or families in order to protect their villages and enforce their own forms of law and order. (14) These clans or families would exploit the violent conditions in southern Italy to extort its people, eventually developing into the criminal organizations known today. (15) The four main Italian criminal organizations are the Sicilian Mafia (La Cosa Nostra), the Calabrian 'Ndrangheta, the Campanian Camorra, and the Sacra Corona Unita in Puglia; each has its own identity, but collectively they are known as the "Mafia." (16)

In 1861, Italy unified all of its separate regions and though it was considered a united country, it still struggled to form a centralized government, as each local administration carried a great deal of power. (17) The developing country of Italy backed the early mafia groups as they were extremely powerful and any attempt to oppose them resulted in failure. (18) These groups continued to grow until the 1920s when Benito Mussolini came to power, as he saw the Mafia as a threat to his regime. (19) Following World War II, the Mafia flourished because of a weak postwar state and through the subsequent building boom, it entrenched itself in various legal businesses, while still maintaining a hold over these regions by providing protection, work, and stability in the area. (20) Throughout the years following the war, the Italian Mafia expanded into the illicit black market and developed the drug trade in this part of Europe, as well as drove competition amongst groups in this area. (21)

B. The Development of ISIS

ISIS declared itself the Caliphate over the Muslim world creating a borderless empire primarily in western Iraq and eastern Syria, but with smaller provinces all across the world. (22) Following the United States' invasion of Iraq in 2003, thousands of Sunni soldiers, formerly loyal to Saddam Hussein, banded together with jihadists of Al-Qaeda to form Al-Qaeda in Iraq (AQI). (23) Abu Musab al-Zarqawi started this group capitalizing off of the Sunnis anger in order to ignite a sectarian war against the Shia population in Iraq and combat the American forces within the country. (24) Concurrently, as the war in Iraq dissipated, the Arab Spring turned into civil war in Syria and AQI began to establish its presence in this area. (25) Al-Zarqawi was killed in an American airstrike, and Abu Ayyub al-Masri succeeded him and then rebranded the group as the Islamic State in Iraq (ISI). (26) Al-Masri and leader Abu Omar al-Baghdadi were then killed in a joint U.S.-Iraqi operation, and Abu Bakr al-Baghdadi became the new leader of ISI. (27)

Owing to its continued presence in the Syrian civil war, ISI absorbed an Al-Qaeda-backed group in Syria, Jubhat al-Nusra, effectively forming a group now known as the Islamic State in Iraq and Syria. (28) ISIS began to gain traction and control in both Syria and Iraq as jihadists from across the world travelled to join the fight. (29) In February 2014, Al-Qaeda renounced its ties to ISIS after an internal struggle persisted between the groups. (30) In June of 2014, ISIS declared the creation of the Caliphate, or the Islamic State, and made Al-Baghdadi, the Caliph, or leader, of the Muslim world. (31) Consequently, ISIS captured strong points throughout Iraq and Syria and demanded that all Muslims pledge themselves to their cause. (32) Though there has been some deterioration in ISIS's Caliphate in 2017, countless extremist groups that still remain have pledged allegiance to ISIS, gaining the organization notoriety through viral social media campaigns and terrorist attacks across the globe. (33)

C. Italy's Antimafia Policy

Italy has fought with the Mafia for longer than it has been a unified republic, making it no stranger to formulating policies and prosecuting organizations that are involved in crime and terror. (34) Since the 1960s, the Italian Parliament has had an Antimafia Commission organized to handle the Mafia issue and develop legislation to combat this ever growing problem. (35) The Commission's 1963 legislation titled "Dispositions Against the Mafia" marked the first time that the word "mafia" was used in legislation. (36) This Commission and ensuing legislation was the start of a fight against the Mafia, which has adapted and grown since its inception. (37) Owing to Italy's long history of dealing with the Mafia, the government has already enacted many terror policies that revolve around aggressive surveillance, wiretapping, and the prosecution of violent suspects. (38) Though Italy has had its fair share of political violence, it has evaded major terrorist attacks over the past thirty years, which many officials have associated with their Antimafia legislation. (39)

D. Italy's Relationship with the European Union

Italy, having supported the unification of Europe for decades, first joined the European Union in January 1999. (40) When the European Union was formed, the countries understood that globalization would mean the group as a whole would need to share problems collectively. (41) Despite having the third largest economy in the European Union, Italy has a history of a weak central government. (42) The Mafia is a global threat, as many of these organizations are transnational groups with a presence all over Europe, Asia, Africa, and the Americas. (43)

III. FACTS

A. Thriving on Terror: The Development of Unlikely Partners

1. The Black-Market Dealings Between the Mafia and ISIS

The Mediterranean Sea acts as a strategic environment for two groups: the Italian Mafia in southern Italy and the Islamic State in Africa and Asia. (44) The various mafia groups have a strong presence in the black market in Europe, while ISIS has an expanding position in northern Africa and southwest Asia. (45) Though these groups appear to have differing ideologies and agendas, they appear to have found a middle ground, developing a coexistence in order to maintain power in their relative regions. (46) The full extent of ISIS's and the Mafia's relationship is yet to be determined, and that leaves uncertainty about the degree of concern that the Italian officials should have when considering how to combat these two cooperating parties. (47)

The Mafia used the current migrant crisis to exploit the turmoil in Italy and grow ties with other radical organizations, such as the Islamic State. (48) Italian authorities uncovered that some of Italy's major refineries from Puglia to Venice had quantities of oil exceeding their limitations, and believe that ISIS-affiliated organizations helped to smuggle in excess oil from countries such as Libya and Syria. (49) This led Italian authorities to believe that oil is coming from ISIS-controlled refineries in these countries, but authorities find it difficult to shut down these operations. (50) The growing number of migrants travelling into Europe allows the Mafia to exploit the crisis and broaden its connections across the Mediterranean Sea, as government officials are inundated with high numbers of immigrants travelling into Italy. (51) The oil trade between the Mafia and ISIS is leaving Italy with difficulties, as law enforcement agents struggle to tie the two groups together and face an uphill battle to prosecute the organizations involved. (52)

As ISIS struggles to control its physical territory, ISIS expanded its presence internationally through its teachings, practices, and black market trade. (53) ISIS found a need to pursue new means of revenue streams going beyond oil smuggling and extortion, now venturing into the drug trade. (54) This led to the development of new smuggling routes from northern Africa and western Asia that cross through Sicily and Mafia controlled territory. (55) The two groups are using these routes to smuggle hashish and other narcotics through ISIS territories and into Europe. (56) The drug trade is seen as a relatively new venture for ISIS, as drug use is illegal under Sharia Law, and its connection with the Italian Mafia has raised questions as to whether the two groups are merely putting up with each other or forming a partnership. (57)

The Mafia's connection with ISIS goes beyond the trade of drugs and oil, as the various criminal organizations of Italy are some of the main arms dealers to ISIS. (58) The Mafia's arms trade with ISIS shows its willingness to support the ISIS's cause by providing weapons, as well as false documents and other resources. (59) Italian officials reported multiple instances of Camorra associated parties providing arms, munitions, and helicopters to ISIS affiliates, which progressed to the Mafia providing passage to known terrorists through Italy. (60) Certain Italian officials are confident that the Mafia is unwilling to let other organizations strengthen within its territory; however, the growing connections between the two groups is of great concern for Italy and the rest of the Western World. (61)

2. Shared Ideologies between the Mafia and the Islamic State

Though the Italian Mafia and ISIS differ greatly in their overall goals, both organizations recognize the value of a working relationship, leading to an admiration between the two. (62) Both organizations thrive on terror and exploit turbulent events through extortion, illegal trade, and other criminal activities. (63) Police in southern Italy saw the Mafia shift from a highly organized enterprise, into a younger, more chaotic and fractured group that is terrorizing the country through violence and crime. (64) Despite having no connection with Islam, certain mobsters in Italy have a growing respect for radical Jihadists' tactics and their "disregard for life." (65) In Naples, there have been reports of different Camorra groups fashioning themselves after ISIS members by growing beards and employing their techniques. (66)

B. Italy's Developing Anti-Terrorism Agenda

Italy incorporates an unforgiving system of handling suspected terrorists with practical prosecution methods that stem from its history of Antimafia laws. (67) Italy is well versed in extremist regimes, and its government understands the necessity of keeping individuals separated in jails, as prisons often act as breeding grounds for extremists, which can lead to the intensification of beliefs and proliferation of recidivism. (68) To combat this, Italy has incorporated strict deportation methods in an attempt to minimize extremists in the country. (69) Though Italy has strict Antimafia policies in place to handle regional terrors in southern Italy, at the moment it is facing concerns with ISIS knocking on its front door, calling for many legislators to expand its policies to an international level. (70)

C. Italy as a Member of the European Union

Since the European Union's inception, Italy has been a stark advocate and participant in the globalization of Europe. (71) As of late, Italy struggles with a stagnant economy as the government's debt continues to increase in association with the migration crisis. (72) This economic strain is felt throughout the European Union. (73) The European Union created a committee on combating the Mafia, but it needs to take further steps to unify and defeat these organizations. (74)

IV. ANALYSIS

A. The Mafia and ISIS

1. The Islamic State's Conquest of Europe and the Mafia's Protection of Southern Italy

Despite ISIS's loss of physical territory, the organization still found a way to expand its global imprint. (75) Since its peak in 2014, ISIS continues to physically lose ground as its territory shrinks to a small stronghold in the desert. (76) The group's biggest territorial loss came when it lost its capital, Raqqa, in October of 2017. (77) This marked not only a physical victory, but also a symbolic victory for anti-ISIS forces. (78) Despite its territorial losses, ISIS still controls a diverse and important portion of the region because of its large Sunni population, who were among the initial members who fueled the initial uprising. (79) As the physical battlefield has shrunken, the group's global presence intensified as other extremist groups align themselves with ISIS, conducting attacks on its behalf. (80)

Over the past few years, ISIS faced many setbacks, however, it still sees Europe as a strategically relevant area, thereby making Europe susceptible to further attacks. (81) ISIS views Rome, specifically, as the physical and symbolic capital of Europe because it is centrally located in Italy and houses the Vatican. (82) The Vatican's religious importance cannot be understated and this marks a major landmark in ISIS's global fight. (83) Italy's importance to ISIS is paramount. (84) Necessary precautions must be put in place to protect these portions of Italy and Europe that are "at-risk targets." (85)

Despite the attacks in Europe and the Americas, the Mafia in Italy still continues to aid ISIS and help its people freely travel through Europe. (86) Various mafia organizations have given aid to members of ISIS and allowed them to travel safely through Europe. (87) This is a great concern, as the Mafia is traditionally protective of its territory and hesitant to allow outsiders to travel through its territory. (88) Not only has the Mafia provided weapons and fake credentials to members of ISIS, but also it has assisted certain members with safe passage prior to and following attacks in Europe. (89) This kind of coordination cannot be ignored. (90)

Though this relationship is cause for some concern, the Mafia still actively monitors ISIS's actions abroad and there is reason to believe that it takes steps to protect its country, or at least its territory. (91) While the Mafia's partnership with ISIS weakened Italy's national security, this organization still ensures the protection of many portions of Italy. (92) Italy, and southern Italy in particular, saw significantly fewer terrorist attacks than other portions of Europe. (93) The Mafia's current relationship with ISIS could be the very thing protecting the country from outside attacks. (94) Even ISIS understands the strength and influence of the Mafia in the region. (95)

2. Allies or Competitors

The Mafia and ISIS set themselves up as partners, based on a mutually beneficial relationship because of their geographic proximity and their expertise in certain crafts. (96) Up to this point, their relationship has been equally favorable. (97) The Mafia makes the most of ISIS's attempt at global conquest by providing it with various goods, such as weapons and fake passports. (98) ISIS uses the Mafia to smuggle various contraband out of its territories and open up new streams of revenue. (99) The two organizations worked together for the past few years, despite many ideological differences. (100)

Though the Mafia and ISIS are working together, this relationship is volatile, as the two groups ultimately have differing agendas. (101) The Mafia's most important pillar is control. (102) This is something that it maintained over southern Italy, since before the country's unification. (103) Regardless of whether they are allies, the Mafia is hesitant to allow an outsider encroach on its territory based on the country's past. (104) This relationship is tenuous, as ISIS has its sights on Rome as a potential target for conquest. (105) This relationship will be short lived, as ISIS looks to continue its expansion. (106)

These disagreeing views could lead to further violence in Europe and place an even larger target on the area. (107) What is seen as a valued partnership could just as easily sour and turn into a rivalry, which would only harm Europe. (108) The Mafia has gone to great lengths to control and monitor ISIS's presence in Europe. (109) It is the hopes of many that the Mafia will continue to protect the land that it values so much, as Italy's government becomes more inundated with its own issues, making it harder for the nation to protect itself. (110)

3. The Strength of these Organizations is Contingent on their International Presence and Europe's Weak Governments

Despite their setbacks, both the Mafia and ISIS remain prevalent in their associated regions. (111) Standing the test of time, the Mafia has been a part of Italy for as long as it has been unified and remains a powerful institution within the country. (112) Since the Mafia's formation, its presence drastically expanded, developing ties throughout Europe, Africa, Asia, and the Americas. (113) The Mafia manages to thrive off of Italy's consistently weak, centralized government in order to embed itself in the country and expand outwards. (114)

Comparatively, ISIS is a relatively new organization, even though many of its sentiments reach back to the start of organized religion. (115) ISIS took an ideological stance that has its basis in the Caliphate, which many of its followers vehemently support. (116) This idea makes it hard to defeat ISIS. (117) Through the spread of these ideas, ISIS took on a greater than life stature that spread across the globe and made its belief system appealing to many extremists. (118) Following the War on Terror, governments in the Middle East were fractured, which allowed ISIS to develop into the radical group it is today with little to no opposition. (119)

The Mafia's connection with ISIS, whether friendly or adversarial, leaves Italy and Europe susceptible to its growing presence. (120) The relationship between the two organizations opened the door for ISIS to reach farther into Europe and root itself in the European Union. (121) Though their relationship is ongoing, the Mafia already allowed ISIS too much liberty by permitting ISIS members to travel through Italian territories and supplying munitions for its fight. (122) Despite their differences, it is important to understand how these two organizations are similar. (123) Much of the success of these two groups is based on their ability to expand internationally and their ability to exploit weak centralized governments that failed to quash their regimes. (124)

At this juncture, the European Union and its allies need to step in to cut off this relationship in order to protect the area from further acts of terrorism. (125) Both of these groups expanded into a large global presence, which thrived off of weak State governments. (126) These underdeveloped States are unable to suppress their citizens from becoming open to radical thinking, corruption, and antigovernment sentiment. (127) By continuing its fight against the Mafia, Italy needs to focus on state-building, which will not only address the Mafia issue, but will also limit other extremist groups in the area. (128) At the moment, there is no trust in the Italian government because of its corruption. (129) This is an issue that Italy faced for centuries, as most Italian citizens have a greater allegiance to their local government than to their country as a whole. (130)

B. Italy's Antimafia Policies Essential to Combating ISIS

1. Success of Antimafia Policies in Italy

The Italian government fought the Mafia for years and never fully eradicated this group. (131) Despite its difficulties in defeating the Mafia, over many years Italy learned how to properly prosecute and combat the Mafia. (132) Since the 1960s, the Italian government implemented an Antimafia agenda, which worked as an ever-evolving policy that the government keeps adapting and learning. (133) Many of these policies revolve around aggressive surveillance, flexible wiretapping laws, and policies geared to prosecute criminals involved in organized crime at an accelerated rate. (134) These policies are seen as controversial when compared with the laws of the United States, as they allow more government power at a cost to its people. (135) These Antimafia policies broadened the types of crimes that can be prosecuted, gave law enforcement more investigative discretion, allowed for the confiscation of Mafia assets, and incentivized citizens to speak out against the Mafia. (136)

The Mafia is entrenched in Italy's way of life, taking advantage of Italy's instability by exploiting its corrupt government. (137) The government learned to combat this by passing tougher legislation and installing special units to handle the surveillance and prosecution of major Mafia leaders. (138) Though this system is far from perfect, Italy has had more time to develop policies which prioritize national security when compared with other countries in the European Union. (139) After years of struggling, as of late, the government successfully limited some of the growth and control of the Mafia. (140)

2. Lack of Acts of Terror in Italy

Italy is known for its violent history and its government adapted to try to diminish the terrorism and violence in the region. (141) Despite the number of organized criminal organizations in southern Italy, there were a significantly small number of terrorist attacks in the past years when compared with other countries in Europe. (142) There is a belief among many Italians that the Mafia is acting as a protector of the region, which is why there have been so few major acts of terror. (143) Though there is some truth to this, based on certain factions monitoring and protecting their territory, this idea is mostly unfounded; the Mafia demonstrated a willingness to allow other extremist groups into its country. (144)

The lack of major terrorism in Italy can be attributed, in most part, to the country's Antimafia policies. (145) Italy developed a legal system adapted to investigating and prosecuting violent organizations like the Mafia, as well as radical organizations. (146) Italy is more equipped to combat terrorism because it already has strong Antimafia laws that can be superimposed onto policies regarding antiterrorism efforts. (147) While other countries in the world are rushing to develop programs to fight against terrorism, Italy perfected a method for doing so over the past few centuries. (148)

The government's knowledge of handling the Mafia can be attributed directly to the success that they have had thus far against fighting terrorist threats domestically. (149) Italy implemented its heightened surveillance and prosecution methods against the Mafia, ISIS, and other extremist groups. (150) Italy's vast intelligence system is well equipped to surveille and monitor potential members of criminal organizations. (151) Italian prisons are often separated and sectioned to limit the spread of radical thinking. (152) There are also many incentive programs for community involvement, and although there is some resistance in speaking out against the Mafia, there is some hope that Italian citizens would be more willing to protect the country against ISIS. (153)

C. Unification of European Union Necessary to Combat Widespread Organized Crime and Terrorism

1. The European Union Must Expand Upon Italy's Antimafia Policies

It is essential that the European Union not only incorporate Italy's Antimafia policies locally, but also that it incorporate these policies in a globally unified fashion. (154) The European Union must learn from Italy's Antimafia policies to enable itself to defend against large-scale terror threats. (155) These widespread efforts against the Mafia, in large part, requires a share of resources and information that is often limited. (156) As ISIS is strengthened through its globalization, Europe must do the same to better protect itself in the fight against ISIS. (157) ISIS is becoming globally intertwined and involved, but by unifying government forces, it will become easier to monitor and prosecute against these radical individuals. (158) Many of these events already take place across multiple borders in different states, and it is important that local and regional governments are not stalled once a terrorist or terrorist group leaves their country. (159)

The European Union must be willing to put aside certain issues and unify to expand on Italy's policies in the fight against ISIS. (160) Broadening the extradition of certain individuals across borders is key to prosecuting individuals. (161) There must be a shared system for intelligence so that all governments can be equally prepared for threats. (162) Governments must be prepared for joint funding for international law enforcement. (163) There must also be new anti-money laundering legislation to trace money that crosses borders. (164) These kinds of policies can help protect Europe and strengthen the international community. (165)

2. Cooperation and State building is Necessary to Combat the Mafia and ISIS

There must be cooperation between the countries of Europe to work against this common threat. (166) Often times, countries are unwilling to change their ways or even make concessions to one another. (167) During this crisis, it is imperative that the international community strengthen its relations in order to prevent further catastrophe. (168) ISIS grew beyond just a threat and is a real enemy that the world must work together to defeat. (169)

It is imperative that European law enforcement agencies unify, coupled with a need for the European Union to help developing countries promote state-building. (170) This will be an essential part in the fight against ISIS and the Mafia. (171) The European Union needs to strengthen its own governments and aid Syria and Iraq in the development of their governments as a deterrent to stop the spread of radicalized thinking. (172) Stronger governments may hold each other accountable to universally fight corruption in order to mitigate the radicalized mindsets that lead to the promotion of organizations, such as the Mafia and ISIS. (173)

V. CONCLUSION

The European Union must build off of Italy's Antimafia laws to create proper defense strategies to protect these countries from terrorism. (174) The Mafia's relationship with ISIS has invited members of the Caliphate into the rest of the European Union, resulting in a need for heightened security. (175) Though the adoption of new laws may be controversial, there must be a change in policy between the countries in the European Union to help combat terrorist threats. (176) These laws require cooperation from many countries and may come at a loss of certain civil liberties, but they are necessary for the protection of Europe. (177) Though these goals may be lofty, they are necessary to ensure national security in Europe. (178)

(1.) See Organised Crime in Europe: Concepts, Patterns and Control Policies in the European Union and Beyond 48 (Cyrille Fijnaut & Letizia Paoli eds., 2006) [hereinafter Organised Crime in Europe] (detailing Mafia's history and ramifications in Europe). In Italy, the Mafia has a longer and more stable history than Italy's government. Id. While the various families have faced their struggle through the years, they remain rooted in Italy's way of life. Id.

(2.) See Michael Day, Fears for Southern Italy as Unemployment, Organised Crime and Economic Recession Sees Young People Leave the Country, INDEPENDENT, (Sept. 13, 2015, 2:15 PM), http://www.independent.co.uk/news/world/europe/fears-for-southern-italy-as-unemployment-organised-crime-and-economic-recession-sees-young-people-10498516.html (discussing effect of Mafia on southern Italy today). See also Organised Crime in Europe, supra note 1, at 49-50 (stating Mafia's deep-rooted history in southern Italy). Since its inception, the Mafia flourished through the "organization-extortion-violence triad." Id. at 49. These groups are able to become so successful because they are extremely organized embedding themselves in local culture and manipulating their environments through extortion and violence. Id. These groups are so successful because they are families built off loyalty, duty, and ritual. Id. at 50.

(3.) See Jason Hanna, Here's How ISIS was Really Founded, CNN (Aug. 13, 2016, 2:05 PM), http://www.cnn.com/2016/08/12/middleeast/here-is-how-isis-began/index.html (discussing founding of Islamic State of Iraq and Syria (ISIS)); Tara John, Timeline: The Rise of ISIS, Time (Oct. 9, 2015), http://time.com/4030714/isis-timeline-islamic-state/ (highlighting events leading to rise of ISIS). See also Ali Khedery, How ISIS Came to Be, Guardian (Aug. 22, 2014, 12:44 PM), https://www.theguardian.com/world/2014/aug/22/syria-iraq-incubators-isis-jihad (outlining events in Syria leading to ISIS). ISIS docs not have a long history, but as Iraq and Syria faced substantial conflict, this organization developed as a response. Id. War destroyed this part of the country and left its people displaced causing fear and anger, which allowed ISIS to grow. Id.

(4.) See Jack Moore, Unlikely Friends: ISIS and The Italian Mafia Working Together to Bring Oil into Europe, Report Says, NEWSWEEK (Aug. 1, 2017, 8:29 AM), http://www.newsweek.com/unlikely-friends-isis-and-italian-mafia-working-together-bring-oil-europe-644660 (explaining ISIS and Mafia's oil trade); Philip Willan, Mafia and ISIS join forces to traffic oil, TIMES (Aug. 1, 2017, 12:01 AM), https://www.the-times.co.uk/article/mafia-and-isis-join-forccs-to-traffic-oil-cqrzz3wlp; Loulla-Mae Eleftheriou-Smith, Isis and Italy's Mafia "Working Together" to Smuggle Cannabis Through North Africa into Europe, INDEPENDENT (Apr. 19, 2016), http://www.inde-pendent.co.uk/news/world/europe/isis-and-italy-s-mafia-working-together-to-smuggle-cannabis-through-north-africa-into-europe-a6991451.html (detailing two group's drug trade); Abdelsattar Heitita & Guiseppe Pipitone, The Mafia and ISIS: An Unlikely Alliance, MAJALLA MAG., Dec. 17, 2017, at 8 (emphasizing relationship between ISIS and Mafia). See also Dave Burke, Mafia Mobsters in Naples Are Now Modelling Themselves on ISIS to Create 'Death Cults'--and Are Even Growing Long Beards, Says Judge, DAILY MAIL (Sept. 13, 2016), http://www.dailymail.co.uk/news/article-3787219/Mafia-mobsters-Naples-modelling-ISIS-create-death-cults-growing-long-beards-says-judge.html (displaying certain Mafia group's admiration for ISIS). Members of the Mafia in Naples have shown a growing admiration for ISIS. Id. They have studied their tactics, copied certain styles, and developed a respect for the terrorist organization. Id.

(5.) See Francesco Marone, The Use of Deportation in Counter-Terrorism: Insights from the Italian Case, INT'L CTR. FOR COUNTER-TERRORISM (Mar. 13, 2017), https://icct.nl/publication/the-use-of-deportation-in-counter-terrorism-insights-from-the-italian-case/(explaining Italy's deportation strategies); Guilia Paravicini, From Mafia to Terror, the Italian Way, POLITICO (Nov. 03, 2016, 5:28 AM), http://www.politico.eu/article/operation-expulsion-italys-controversial-counterterrorism-strategy-tunisianimam-civil-liberties/(discussing counterterrorism strategies in Italy). See also Commissione Parlmentare Antimafia, VI Legislatura, Disegni di Legge e Relazioni, Documenti, vol. XXXVI, no. XXXIII-2 (Rome, 1976) [hereinafter called Antimafia Commission 1976] (detailing Italy's need to implement Antimafia policies into law). The Antimafia Commission was formed in 1963 and tasked with incorporating Antimafia policies into Italy Law. Id. The Antimafia Commission was to use all resources at its disposal to combat the Mafia crisis. Id.

(6.) See Dave Burke, How Combating the Mafia Helped Italy Fight Isis: Surveillance Techniques and the Help of Organised Crime are Keeping Extremists at Bay, Claim Experts, DAILY MAIL (Dec. 24, 2016, 11:09), http://www.dailymail.co.uk/news/article-4063764/How-combating-mafia-helped-Italy-fight-ISIS-Surveillance-tech-niques-help-organised-crime-keeping-extremists-bay-claim-experts.html (comparing tactics in handling both Mafia and ISIS).

(7.) See infra Part II-V (determining need for joint intervention of ISIS).

(8.) See infra Part II (providing context for Mafia and ISIS involvement in Italy).

(9.) See infra Part III (analyzing effect of group's partnership on Europe).

(10.) See infra Part IV (examining current policies and incorporating them on broad scale).

(11.) See infra Part V (concluding negative ramifications without mass intervention from European Union).

(12.) See Origins of the Mafia, HISTORY, http://www.history.com/topics/crime/origins-of-the-mafia (last updated Aug. 21, 2018) (depicting southern Italy's history of foreign invaders). For centuries, Sicily was fought over by many groups "including the Phoenicians, Romans, Arabs, French and Spanish." Id.

(13.) See Organised Crime in Europe, supra note 1, at 55 (detailing violent history in Sicily). From this Modernization period, Sicily began to incorporate violence and competition into its way of life. Id. See also Silvia Console Battilana, Why Did the Mafia Emerge in Italy? An Institutional Answer 14-18 (Nov. 2003) (unpublished paper, Stanford University), available at https://web.stanford.edu/~silviacb/PEPR/Why%20did%20the%20Mafia%20Emerge%20in%20Italy.pdf (showing how end of feudalism led people to violence). The end of feudalism completely destroyed the social structure and left all of its citizens to fight for their order. Id. Following the abolition of feudalism there was an "unequal distribution of wealth; lack of the concept of equal rights for everyone; predominance of personal power; and every social relation had only individualistic connotations." Id. at 14. All this was accompanied by harsh feelings of hate, passion for revenge, and the well-known popular concept of "who does not do justice by himself has no honor." Id. The elimination of a structured society opened the flood gates for power struggles, making violence and corruption an accessible answer to remedy past wrongs of the lower classes. Id.

(14.) See Origins of the Mafia, supra note 12 (describing start of local systems of justice). The violent history of southern Italy caused its people to create their own forms of justice, as there was no structure in place to protect themselves. Id. Southern Italy has a long line of foreign invaders who have vied for control over the area. Id. See also William O'Connor, A Dishy, Bloody History of Sicily, DAILY BEAST (Sept. 20, 2015, 12:01 AM), https://www.thedailybeast.com/a-dishy-bloody-history-of-sicily (emphasizing vast number of conquers in Sicilian history). Sicily is known as the "most conquered island in the world" passing through Carthaginian, Roman, Gaiseric, Theodoric, Greek, and Norman rule, to name a few. Id. In all of this time, the Sicilian people were treated poorly, often having their possessions and land looted. Id. This violent landscape instilled a general mistrust in its citizens, who banded together to create "clans" to protect themselves and their property. Id. These original clans would then evolve into the Mafia families known today. Id.

(15.) See Origins of the Mafia, supra note 12 (showing development of mafias from necessity). The people of Sicily and southern Italy were left with no other option but to band together and try to protect their land. Id. The constant threat from intruders and lack of stable government left the Sicilian people in need of a way to protect themselves, finding protection by forming small private armies known as "mafie." Id.

(16.) See Organised Crime in Europe, supra note 1, at 47-55 (outlining groups associated as mafia organizations). Though it is debated as to which groups are Mafia crime syndicates, government and legislators hold the perspective that the Cosa Nostra, Ndrangheta, Camorra and Sacra Corona Unita are categorized under this term. See also Umberto Bacchi, Italian Mafia: Who are Cosa Nostra, Camorra, 'Ndrangheta and Sacra Corona Unita? INT'L BUS. TIMES (May 8, 2015), http://www.ibtimes.co.uk/italian-mafia-who-are-cosa-nostra-camorra-ndrangheta-sacra-corona-unita-1500221 (debating Sacra Corona Unita's inclusion as Mafia). These groups are characterized as Mafia because of their size, activity, and structure. Id. These four organizations are the largest and most influential in Italy and transcend other criminal activity in the region. Id. See also Threat Assessment: Italian Organized Crime, Europol, EDOC 667574 v8 (June 2013) (including Cosa Nostra, Ndrengheta, Camorra, and Apulian OC as mafia). For legislative purposes, these four groups are to be considered "mafia." Id. See also Organized Crime: Culture, Markets and Policies 16-18 (Dina Siegel & Hans Nelen eds., 2008) [hereinafter Culture, Markets and Policies] (arguing difference in Mafia from other organized criminal groups). Despite the various criminal organizations, what differentiates the Mafia is the way it exercises its power over its members and its community. Id. The Mafia are not the only criminals in Italy, but they are the most influential and have the longest history there. Id. See also Nick Squires, Italy's Mafia: Breakdown of Four Main Groups, TELEGRAPH (Mar. 8, 2011, 11:46 AM), http://www.telegraph.co.uk/news/worldnews/europe/italy/8368184/Italys-mafia-breakdown-of-four-main-groups.html (distinguishing different Mafia groups in Italy). Though the Mafia tends to be viewed as one homogeneous group, it is important to distinguish the various groups all made up of separate families with distinct traits and beliefs. Id. It is easy to refer to all of these groups as being members of the Mafia, however, it is necessary to distinguish and show that there are many different factions that make up the overall Mafia in Italy. Id.

(17.) See Organised Crime in Europe, supra note 1, at 58-60 (showing lack of centralized government following unification of Italy). Even after the Unification, the government lacked the strong presence necessary to protect its constituents and provide them with necessities. Id. at 58. The growing Mafia families were able to provide a level of protection that the state government could not. Id. at 59. See also Italy Corruption Report, GAN Bus. ANTI-CORRUPTION PORTAL, https://www.business-anti-corruption.com/country-profiles/italy (last updated Dec. 2017) (describing corruption in Italy).

(18.) See Battilana, supra note 13, at 18-22 (observing Mafia's integration within society). These groups did not clash with formal constructs but coexisted with them. Id. See also Origins of the Mafia, supra note 12 (acknowledging government officials and Vatican's coexistence with Mafia). In the late nineteenth century, government officials and even the Vatican relied on the Mafia to provide stability in the southern part of the country. Id. In the late nineteenth century, the Catholic Church would use the Mafia to remove independent criminals from the area and to protect the Church's property holdings in Sicily. Id. See also DIEGO GAMBETTA, THE SICILIAN MAFIA: THE BUSINESS OF PRIVATE PROTECTION 49-50 (1993) (explaining start of Vatican and Mafia relationship). The relationship between the Mafia and Vatican traces back to Italy's unification. Id. at 49. Following Italy's unification, the state and the Vatican tended to clash over major federal issues and the Catholic Church strengthened relations with local political groups over national political groups. Id. at 50.

(19.) See Kenneth St. John, Historical, Mussolini's War on the Mafia, 5 KALEIDOSCOPE INT'L J. 24, 24-29 (2014), available at http://www.bckaleidoscope.Org/uploads/9/2/6/6/92665638/5_2_s14_mussolinis_war_on_the_mafia.pdf (analyzing Mussolini's failed attempt to eradicate Mafia). Though Mussolini's efforts did result in the reduction of the Mafia's presence in Italy at the time, the Mafia was able to outlast fascism in Italy. Id. See also MONTE S. FINKELSTEIN, SEPARATISM, THE ALLIES AND THE MAFIA: THE STRUGGLE FOR SICILIAN INDEPENDENCE 1943-1948 19-21 (1998) (outlining Mussolini's opposition to Mafia). Mussolini had seen the Mafia as fascism's biggest opposition and knew the importance of eliminating them. Id. Initially, the various mafia groups supported Mussolini, but as Mussolini sensed their strength, he worked to strip them of their control. Id. In 1925, Cesare Mori was appointed as the Prefect of Palermo, and this marked the start of Mussolini's Antimafia campaign leading to "torture, arbitrary arrests, and secret trials" in an effort to disrupt the Mafia's chain of command. Id. Mori was appointed as Prefect, because he was known as a man of action who was not against taking a stance against a strong opponent. Id. Though his fight against the Mafia was notable, it was not overly successful as his campaign did not have long-term effects; most of the Mafia's structures were left in place and only minor figures were imprisoned. Id.

(20.) See James J. Martin, The Death and Life of the Mafia in Italy: From Suppression by Mussolini to Revival by 'Liberation,' 1926-1946, 15 J. HIST. REV. 2-22 (May-June 1995), available at http://www.ihr.org/jhr/v15/v15n3p2_martin.html (last visited Sept. 25, 2018) (comparing fascism's relationship with Mafia). Following the Allied forces victory in Europe, the Mafia was able to reestablish itself in Italy, becoming stronger than it had been prior to the war. Id. "In Italy, what looked like extinction was turned around by the fortunes of the war, which became the salvation of the Mafia as a force in Italian affairs." Id.

(21.) See Organised Crime in Europe, supra note 1, at 66-70 (analyzing Mafia's post war success in Italy). Following Italy's loss in World War II, the Mafia exposed the lack of organization to entrench itself in the country and firmly established itself in the drug trade. Id. at 66-68. While most of Europe was preoccupied with rebuilding following the war, the Mafia was able to take advantage of the fractured governments to gain further local support and strengthen its presence throughout Europe. Id. at 68. Italy's loss in World War II and its failed experiment with fascism left the country with an identity crisis. Id. at 67-68. With Italy lacking a strong government and Allied troops still occupying portions of the country, the Mafia was able to gain strength again in the absence of the fascist regime. Id. at 67.

(22.) See Tewfik Cassis, A Brief History of ISIS, WEEK, (Nov. 21, 2015), http://theweek.com/articles/589924/brief-history-isis (summarizing ISIS rise in Middle East). ISIS evolved out of the chaos in the Middle East following the United States invasion of Iraq. Id. Radical jihadists were able to use local hatred towards the United States and other religious groups in Iraq to divide the country and cause further turmoil. Id. In Iraq, there was a lot of animosity towards the Shiites by the Sunnis, who had originally supported Saddam Hussein and were now out of work and angered because of the American occupation. Id. See also What is 'Islamic State'?, BBC (Dec. 2, 2015), http://www.bbc.com/news/world-middle-east-29052144 (explaining significance of Islamic state). The idea of an Islamic state goes beyond the Middle East and is an old religious belief rooted in establishing "a state governed in accordance with Islamic law, or Sharia, by God's deputy on Earth, or caliph." Id. ISIS demanded that all other Muslims throughout the world swear their allegiance to the Caliph and "migrate to territory under its control." Id. This led other jihadist groups to pledge themselves to ISIS and inspired new groups to start. Id. See also Terrorism in Africa: the Imminent Threat to the United States Before the Subcomm. on Counterterrorism and Intelligence of the H. Comm. on Homeland Security, 114th Cong. (Apr. 29, 2015) (statement of Daniel L. Byman, Director of Res., Ctr. for Middle East Pol'y at Brookings Inst.), available at https://docs.house.gov/meetings/HM/HM05/20150429/103382/HHRG-114-HM05-Wstate-BymanD-20150429.pdf (differentiating ISIS from Al-Qaeda). Much like the various families in the Mafia, there are also various factions that make up ISIS. Id. It is important to understand that the Islamic State is made up of many different groups and though these factions have worked with Al-Qaeda at different points in time, ISIS and Al-Qaeda are distinct and stand for different principles. Id.

(23.) See Cassis, supra note 22 (elaborating on ISIS's creation in Iraq). See also Tara John, Timeline: The Rise of ISIS, TIMES (Oct. 9, 2015), http://time.com/4030714/isis-timeline-islamic-state/(tracing rise of ISIS). Al-Zarqawi had been the leader of the jihadist insurgency in Iraq against the American forces, and had tied his group with Osama Bin Laden starting their partnership with Al-Qaeda. Id. Though Al-Zarqawi was popular amongst radical jihadists, he lost considerable support in Iraq because of its attacks on other Muslim groups within the nation. Id.

(24.) See Cassis, supra note 22 (detailing reasoning and development of Al-Qaeda in Iraq (AQI)). Following the invasion of Iraq, the United States removed thousands of Sunnis from Iraqi civilian and military jobs. Id. This action outraged many Sunnis, who had been loyal to Saddam Hussein and were now angered and jobless. Id. The AQI leaders strategically used this anger to not only ramp up animosity towards the United States, but also as propaganda against the Shia population who were working with the United States. Id. See also Jason Hanna, Here's How ISIS was Realty Founded, CNN (Aug. 13, 2016, 2:05 PM), http://www.cnn.com/2016/08/12/middleeast/here-is-how-isis-began/index.html (describing exploitation of Sunni resentment to establish control). Following the United States insurgency in Iraq, the Sunni government was mostly replaced by a "Shiite-dominated government." Id. Although Saddam's government had been considered secular, it was mainly run by members of Iraq's Sunni minority and they abused this power to repress other groups in the country. Id. The new Shiite government backed by the United States looked for revenge against the Sunni population. Id. The Sunnis in turn used this as propaganda to fight against the Shiites and United States forces. Id.

(25.) See Cassis, supra note 22 (noting AQI's involvement in Syria leading to ISIS). The United States continued to send troops over to Iraq causing the AQI to diminish and the group was largely defeated in Iraq. Id. As the war was dissipating in Iraq, the Arab Spring in Syria was beginning to turn to civil war. Id.

(26.) See ISIS Fast Facts, CNN, http://www.cnn.com/2014/08/08/world/isis-fast-facts/index.html (last updated Sept. 3, 2018) (outlining relevant dates for ISIS). In June 2006, Al-Zarqawi was killed in a United States airstrike and Abu Ayyub al-Masri replaced him as the new leader. Id. As its new leader, al-Masri rebranded the organization as the Islamic State of Iraq (ISI) and appointed Abu Omar al-Baghdadi as its leader. Id.

(27.) See id. (describing ascension of Abu Bakr al-Baghdadi among ISIS ranks). Abu Bakr al-Baghdadi was able to take control of ISI following the death of the group's top leaders, Al-Masri and Abu Omar al-Baghdadi. Id. See also Massimo Calabresi, Abu Bakr al-Baghdadi: The Head of ISIS Exports Extreme Violence and Twisted Religion Around the Globe, TIME, http://time.com/time-person-of-the-year-2015-runner-up-abu-bakr-al-baghdadi/(ranking Al-Baghdadi as number two person of year). Al-Baghdadi was able to take a failing organization and transform "the breakaway al-Qaeda group from a battlefield force operating in the chaos of Syria and Iraq into a transnational terrorist franchise killing civilians in more than a dozen countries around the world." Id. Al-Baghdadi recognized the importance of the internet and the ability to recruit across the globe to expand this group. Id.

(28.) See David Ignatius, How ISIS Spread in the Middle East, ATLANTIC (Oct. 29, 2015), https://www.theatlantic.com/international/arehive/2015/10/how-isis-started-syria-iraq/412042/(articulating ISIS's rise to power through alliance with other jihadist groups). Jubhat al-Nusra was one of the toughest and most successful groups fighting during the Syrian war. Id. It was able to catch ISI's attention and ISI began to funnel weapons and resources to this group. Id.

(29.) See Ian Bremmer, The Top 5 Countries Where ISIS Gets its Foreign Recruits, TIME (Apr. 13, 2017), http://time.com/4739488/isis-iraq-syria-tunisia-saudi-arabia-russia/(offering top countries contributing recruits to ISIS). Tunisia, Saudi Arabia, Russia, Turkey, and Jordan are the top five countries that supply ISIS with recruits. Id.

(30.) See ISIS Fast Facts, supra note 26 (describing internal difference between Al-Oaeda and ISIS). See also Daniel L. Byman & Jennifer R. Williams, ISIS vs. Al Qaeda: Jihadism's Global Civil War, BROOKINGS INST. (Feb. 24, 2015), https://www.brookings.edu/articles/isis-vs-al-qaeda-jihadisms-global-civil-war/(contrasting two groups' beliefs and motivations in Middle East).

(31.) See What is 'Islamic State'?, supra note 22 (exploring ISIS's goals in establishing caliphate). ISIS's declaration of the establishment of a caliphate is of significant importance, as it has expanded its goals beyond Iraq and Syria and are looking to the rest of the Muslim world. Id. See also Carlo Mufloz, Islamic State's 'Caliphate' Dissolves, but Ideology, Operations Spread Around World, WASHINGTON TIMES (Oct. 17, 2017), https://www.washingtontimes.com/news/2017/oct/17/isis-to-spread-ideology-operations-around-world-af/(describing tough battle in fighting ideological war with ISIS).

(32.) See What is left of ISIL's 'Caliphate?, AL JAZEERA (Aug. 31, 2017), http://www.aljazeera.com/news/2017/08/left-isil-caliphate-170831155337858.html (reviewing ISIS's rise and deterioration in Middle East). Three years following ISIS declaration of a caliphate, the organization has suffered some setbacks losing physical territory in Syria and Iraq. Id. In 2014, ISIS had almost one-third of Iraq's territory, and in August 2017, it only had about ten percent of the country under its control. Id. What ISIS lacks in physical territory, it has expanded in a worldwide presence, showcasing its support across the globe through sleeper cells and affiliated organizations. Id.

(33.) See Daniel Byman, Beyond Iraq and Syria: ISIS' ability to conduct attacks abroad, BROOKINGS INST. (Jun. 8, 2017), https://www.brookings.edu/testimonies/beyond-iraq-and-syria-isis-ability-to-conduct-attacks-abroad/(explaining ISIS's presence abroad). The main power of ISIS is that it lacks boarders and extends past Iraq and Syria. Id. The most powerful ideology of ISIS is that it can extend to any part of the globe through any number of means. Id. See also Justin Leopold-Cohen, The Islamic State is Losing at Home but Gaining Abroad, DIPLOMATIC COURIER (June 12, 2017), https://www.diplomaticourier.com/2017/06/12/islamic-state-losing-home-gaining-abroad/(arguing ISIS's growing presence abroad resulting in expansion of group). ISIS has been losing territory in Syria and Iraq, which has come at a great cost to the organization, but it has gained ground globally. Id. Though it has been losing physical territory, the group has been growing globally through social media, with as many as forty affiliate groups across the globe spurring on terrorist attacks around the world. Id. See also Hassan Hassan, Its Dreams of a Caliphate are Gone. Now Isis has a Deadly New Strategy, GUARDIAN (Dec. 30, 2017), https:/r/www.theguardian.com/commentisfree/2017/dec/31/isis-dreams-of-caliphate-gone-now-deadly-new-strategy (detailing expansion of ISIS); Michael Kranz & Skye Gould, These Maps Show How Drastically ISIS Territory has Shrunk Since its Peak, Bus. INSIDER (Oct. 24, 2017, 12:07 I'M), http://www.businessinsider.com/maps-of-isis-territory-2014-2017-10 (illustrating diminishing ISIS control). ISIS lost physical territory, but still represents a growing threat through its various groups across the globe. Hassan, supra.

(34.) See Organised Crime in Europe, supra note 1, 58-59, 70 (discussing development of Mafia in Italy). The Mafia established itself in Italy long before it became a unified country and is still a part of the country today. Id at 58-59. Italy's government has over 150 years of dealing with mafia groups and has taken great lengths in enacting policies to combat the dangerousness of these organizations. Id. at 70. See also Misure Di Prevenzione Nei Confronti Delle Persone Pericolose Per La Sicurezza E Per La Pubblica Moralita, Legge 27 dicembre 1956, n. 1423, G.U. Dec. 31, 1956, n. 327 (It.) (taking preventative measures against potentially dangerous persons). This act was the first measure in establishing policies against potentially dangerous persons and would end up being a base for much of the Antimafia legislation that would be developed over the next twenty years. Id.

(35.) See Antimafia Commission 1976, supra note 5 (creating commission to enact Antimafia policies in government). See also Alison Jamieson, The Antimafia 52-74 (2006) (analyzing Antimafia efforts in southern Italy). Shortly after the Antimafia Commission was created, it passed its first Antimafia legislation called "Dispositions Against the Mafia." Id. at 17. Of the policies put in place the legislation helped define who was a Mafia member and included special surveillance measures, suspension of licenses, and other restrictions. Id.

(36.) See Jamieson, supra note 35, at 16-23 (describing legislation giving extra powers for law enforcement to surveille Mafia members). See also Disposizionl Contro La Mafia, Legge 31 Maggio 1965, n. 575, G.U. June 5, 1965, n. 138 (It.) (developing original legislation against Mafia). This Act represented Italy's first Antimafia legislation created by the Antimafia Commission to give government officials the ability to surveille any persons believed to be associated with the Mafia, as well as trace any and all of its assets. Id. See also Culture, Markets and Policies, supra note 16, at 17 (depicting Mafia's level of secrecy). "Since the unification of Italy in 1861 Mafia groups have been at least formally criminalized by the state and, in order to protect themselves from arrest and criminal prosecution for its continuing recourse to violence, they have needed to resort to varying degrees of secrecy." Id. The hardest issue with combating the Mafia is not the organizations internal code of silence, but the effect they have on the community in not cooperating with government officials. Id. The government needed to expand its practices to protect civilians who cooperate by attempting to incentivize witnesses to talk to police officers. Id.

(37.) See Jamieson, supra note 35, at xxi (detailing development of Antimafia policies southern Italy). The root of the Mafia issue goes further than defeating the organization and lies with attempting to build a stronger state in Italy. Id. However:
The suggestion that bringing in more magistrates and police will solve
the problem of the Mafia is totally inadequate. If the Mafia pays you,
finds and keeps you in work, helps you win contracts, gets promotion or
runs your business, then you won't reject it. The solution to the
problem of the Mafia is to make the state work.


Id. The government realized that it needed to build from within the state, and not combat the Mafia head on. Id. See also Modifiche Urgenti al Nuovo Codice di Procedura Penale e Provvedimenti di Contrasto alia Criminalitd Mafiosa, D.L. 8 giugno 1992, n. 306, G.U. June 8, 1992, n. 133 (It.) (enacting urgent policies following Mafia activity). This decree, later converted into Law 356 on August 7, was formed to encourage witness participation, restrict mafia leaders in prison, confiscate assets, and restrict the sale of munitions, as well as other provisions. Id. See also Culture, Markets and Policies, supra note 16, at 21 (exemplifying Antimafia policies put in place). Following the enactment of the decree, the Direzione Investigativa Antimafia reported that between 1992 and 2006, 1,627 arrest warrants were issued against members of the Cosa Nostra and 2,317 against Ndrangheta members. Id. at 21. See also Center. For the Study of Democracy, Antimafia: The Italian Experience in Fighting Organised Crime 1-6 (Oct. 2011), available at http://www.csd.bg/artShow.php'?id=158 16 (encompassing Italy's Antimafia laws). Italy incorporated many policies to protect against criminal organizations by accelerating criminal proceedings, implementing harsher penalties, and adding protective measures in southern Italy. Id.

(38.) See Do Mafia Prosecutions Give Italy an Edge in Preventing Terror Attacks?, USA Today (Jun. 29, 2017, 9:20 AM), https://www.usatoday.com/story/news/world/2017/06/29/do-mafia-prosecutions-give-italy-edge-preventing-terror-attacks/438555001/(detailing relevance of Mafia policies to handling terrorism). Italy was forced to develop its legal system early on to handle terrorists' threats and this educated it about certain techniques in handling organized groups. Id. See also The Mafia Effect: Why Italy Has Not Yet Suffered Islamist Terrorism, ECONOMIST (Sept. 30, 2017), https://www.economist.com/news/europe/21729775-unlike-other-european-countriesitaly-has-avoided-jihadist-outrages-why-italy-has-not-yet (describing Mafia's influence on terrorist activity). Many of the legislative policies enacted in Italy give the government heightened power to monitor, surveille, and weaken terror organizations in the country. Id. Italy's history of dealing with the Mafia made it well equipped to deal with terrorism. Id.

(39.) See Stephanie Kirchgaessner, Why Has Italy Been Spared Mass Terror Attacks in Recent Years?, GUARDIAN (June 23, 2017), https://www.theguardian.com/world/2017/jun/23/why-has-italy-been-spared-mass-terror-attacks-in-recent-years (associating lack of terror attacks to Antimafia legislation). Italy saw its fair share of criminal acts, including the assassination of two Antimafia judges in the 1990s; however, a comparatively low number of foreign terrorist attacks have taken place within the country. Id. According to the Italian interior ministry:
[C]ounter-terrorism authorities stopped and questioned 160,593 people
between March 2016 to March 2017. They stopped and interrogated about
34,000 at airports and arrested about 550 suspected terrorists, and 38
have been sentenced on terrorism charges. More than 500 websites have
been shut down and nearly half a million have been monitored.


Id. See also Timeline-Terror Attacks in Europe, RAIDIO TEILIFIS EIREANN (Aug. 17, 2017), https://www.rte.ie/news/world/2017/0817/898178-europe-terror-attack-timeline/(illustrating major terror attacks in recent years). Recently, wide spread terrorist attacks occurred throughout Europe, but Italy managed to avoid these types of attacks. Id. See also Two Years of Terror: As Spain is Left Reeling by Barcelona Attacks Chilling Map Shows How More Than 300 Innocents have Lost Their Lives in 16 Separate Jihadist Atrocities, DAILY MAIL (Aug. 18, 2017), http://www.dailymail.co.uk/news/article-4802394/Map-shows-jihadi-attacks-Europe-two-years.html (showing increase in terror attacks in Europe). Despite an escalation in terrorist threats in Europe, Italy manages to be seemingly unscathed. Id.

(40.) See Philip Daniels, Italy in European Union, ECON. AND POL. WKLY (Sept. 4, 1998) (detailing Italy's presence in European Union). The Italian government supported the project to integrate the European countries since the 1950s. Id.

(41.) See id. (outlining reasoning for creation of European Union). Part of the function of the European Union is to have a collective responsibility between all of its members. Id. This means it is important for the European Union to share goals, resources, and work to build a legislative infrastructure that protects the Union as a whole. Id.

(42.) See John M. Mason, Italy's Future and the Future of the European Union: Is The U.S. Watching?, SEEKING ALPHA (Mar. 22, 2017, 11:31 AM), https://seekingalpha.com/article/4057104-italys-future-future-european-union-us-watching (detailing Italy's standing in European Union). Italy has one of the weakest economies in the European Union, which has allowed the Mafia to flourish. Id.

(43.) See also Europol, Mafia Structured Organised Crime Groups, Threat Assessments: Italian Organised Crime, EDOC No. 667574 v8, (June 2013) (depicting expansiveness of Mafia organizations). The Cosa Nostra has legitimate business and affiliates in many other countries including the United States, Canada, South Africa, Venezuela, and Spain. Id. at 3. The Ndrangheta has a presence in "Spain, France, Belgium, the Netherlands, Germany, Switzerland, Canada, the USA, Columbia and Australia." Id. The Camorra controls markets in "Spain, France, the Netherlands, Germany, Switzerland, Eastern Europe, the USA, and Latin America." Id. The Apulian organizations are only present in Italy and surrounding regions of Europe. Id. See also Wainaina Wambu, Time Popular Nairobi Casino Boss Was Linked to Italian Mafia, STANDARD DIGITAL (Feb. 27, 2018), https://www.standardmedia.co.ke/mobile/amp/article/2001271348/time-popular-nairobi-casino-boss-was-linked-to-italian-mafia (showing connection between Mafia and Africa). The Italian Mafia extended its presence farther into northern Africa and is even influencing many of the casinos in Kenya. Id.

(44.) See Organised Crime in Europe, supra note 1, at 67-68 (detailing Mafia's presence in Mediterranean). Italy's large and unguarded coastline, in conjunction with its proximity to western Europe and the Middle East, makes it a major trading point in the European black market. Id. at 67-68. See also What is 'Islamic State'?, supra note 22 (exploring ISIS's goals in establishing caliphate across globe). ISIS's physical territory diminished over the past few years, but its worldwide presence has expanded through social media and the black-market trade. Id. ISIS is heavily funded through the oil market, but also generated revenue through kidnapping, selling antiquities, and through the drug trade. Id.

(45.) See Organised Crime in Europe, supra note 1, at 64 (explaining Mafia's presence in region). See also ISIS Fast Facts, supra note 26 (detailing presence in black market). The various mafia groups have a large presence in Italy's black market, but they are not the only participants. Id. The Mafia's actual revenue is hard to track, as most families are also grounded in legal businesses making it easier to launder its money. Id.

(46.) See Bruce Cornibe, The Italian Mafia and ISIS: Friends, Enemies or Frenemies?, COUNTER JIHAD (Oct. 19, 2016), https://counterjihad.com/italian-mafia-isis-friends-enemies-frenemies (analyzing two groups' relationship). ISIS and the various Mafia families in Italy have a growing trade network, but appear to be bolstering its relationship by allowing Islamic extremists to travel into Europe through Italy. Id. Though the two groups appear to be profiting off one another, it is yet to be seen whether the relationship goes beyond just business. Id.

(47.) See id. (questioning Italy's role in ISIS future Caliphate). ISIS sees Italy and specifically Rome and the Vatican as having a symbolic significance in Europe. Id. The Mafia allowed ISIS to broaden its presence in Italy, but there is still a belief that the Mafia will only allow ISIS to have so much power, and that it would stop ISIS from operating within the country. Id. Regardless of the two groups' motives, Italy's government cannot rely on the Mafia to protect its country. Id. Italy must be proactive in suppressing this partnership before it is too late. Id.

(48.) See Gaia Pianigiani, Mafia in Italy Siphons Huge Sums from Migrant Centers, N.Y. TIMES, Jul. 17, 2017, https://www.nytimes.com/2017/07/17/world/europe/italy-migrants-mafia-edoardo-seordio.html?_r=0 (depicting Mafia's exploitation of immigrants). Many managers of the immigration centers in Italy have been siphoning off government funds and keeping them for personal use. Id. Officials are working with the Mafia to skim off government money, allowing the money and supplies to go directly into the black-market. Id. The migration crisis is highlighting Italy's governmental issues, with corruption putting a further strain on its economy and government relations. Id. The migrants find themselves leaving behind "poverty and violence in their home countries" and finding more of the same in Italy. Id.

(49.) See Italy Suspects the Mafia and ISIS Teamed Up to Smuggle Oil to Europe, ORGANIZED CRIME AND CORRUPTION REPORTING PROJECT (Aug. 2, 2017), https://www.occrp.org/en/daily/6798-italy-suspects-the-mafia-and-isis-teamed-up-to-smuggle-oil-to-europe (outlining oil trafficking from ISIS territories). See also Willan, supra note 4 (describing investigations into Italian oil refineries). Italian authorities are struggling to trace this oil as it is being smuggled into Europe through intermediaries, but it is clear that the oil is coming from Syria and Libya. Id. The oil is found in major refineries all over Italy. Id. Like much of the smuggling between the Mafia and ISIS, the government is struggling to prosecute the groups as it becomes hard to build a case against them when they are using intermediaries, middlemen, and conducting business across borders. Id.

(50.) See Irina Slav, Italian Police are Investigating Oil Smuggling Links Between the Mafia and ISIS, Bus. INSIDER (Aug. 1, 2017), http://www.businessinsider.com/mafia-isis-oil-smuggling-2017-8 (detailing difficulties in investigating oil smuggling). Both the Mafia and ISIS have set up numerous safeguards to protect their dealings by establishing intermediaries and shell companies abroad, making it nearly impossible to track the oil to its original source. Id. The oil is typically smuggled in the middle of the Mediterranean Sea, then brought in through southern Italy's unguarded coastline. Id. These groups are hiding the oil supplies on tanker ships and then transferring them over to smaller ships, which can reach the Italian coastline unnoticed. Id. Authorities appear to know where the oil is coming from and where it is ending up but are unable to stop the transactions as they cannot prove a link between the two groups in the smuggling. Id. Both the Mafia and ISIS have operated with intermediaries, using money laundering and other forms of secrecy, making it nearly impossible to trace the transactions. Id.

(51.) See Moore, supra note 4 (emphasizing ability of groups to exploit migration crisis). Italy is dealing with a massive migrant crisis, taking in hundreds of thousands of migrants from northern Africa. Id. The Mafia is using this crisis to not only steal aid money from local shelters, but also to use the crisis as a distraction to smuggle in goods from northern Africa. Id. Italy's government is occupied with the inundation of immigrants to notice the massive amounts of oil smuggled in through its boarders. Id.

(52.) See Moore, supra note 4 (depicting current crisis in governing growing relations between Mafia and Islamic State). The biggest issue thus far has been tying the two groups together. Id. The Italian government knows that the oil is coming from Syria and northern Africa and ending up in Italy, but it struggled to show a link connecting the two. Id. Both organizations are protective of their business dealings and have set up many intermediary companies to conduct business and make it harder to tie the groups together. Id. The continuing issue in Italy is the people's refusal to speak up against the Mafia. Id. The Mafia's biggest advantage over the government is its ability to instill loyalty in its members and fear into the people of Italy. Id. Government officials, police officers, business owners, and other citizens are all benefiting from the Mafia, so there is little incentive to speak out against it. Id.

(53.) See Colin P. Clarke, ISIS is So Desperate its Turning to the Drug Trade, RAND CORP. (July 25, 2017), https://www.rand.org/blog/2017/07/isis-is-so-desperate-its-turning-to-the-drug-trade.html (detailing ISIS's involvement in new black market ventures). As ISIS continued to lose physical territory it began outreach into other markets to try to keep its goals alive. Id.

(54.) See id. (outlining ISIS's growing involvement in drug trade). Despite ISIS following Sharia law, which condemns drug use, ISIS expanded into the drug market. Id. ISIS is struggling to keep making money and it is using its control over territory to profit off the drug market in the area. See also Josh Robbins, Italian Mafia and ISIS Collaborate to Traffic Drugs: Millions of Opioid Tablets Bound for Libya Seized, INT'L BUS. TIMES (Nov. 3, 2017), http://www.ibtimes.co.uk/italian-mafia-isis-collabo-rate-traffic-drugs-millions-opioid-tablets-bound-libya-seized-1645871 (describing trafficking of Tramadol to Libya). Officials believe that ISIS is not only using the Mafia to smuggle drugs, but that the Mafia is also selling drugs to ISIS. Id. Many ISIS fighters use and sell the drug Tramadol as it suppresses "fear and hunger" and is even referred to as the "fighter drug." Id. High amounts of Tramadol were confiscated in Ndrangheta controlled territory and it was believed that the shipment was headed to ISIS fighters in Libya. Id.

(55.) See Rukmini Callimachi & Lorenzo Tondo, Scaling Up a Drug Trade, Straight Through ISIS Turf, N.Y. TIMES, Sep. 13, 2016, https://www.nytimes.com/2016/09/14/world/europe/italy-morocco-isis-drug-trade.html (describing ISIS's smuggling routes). The Mediterranean Sea acts as a natural passage from Africa to Europe; ISIS capitalized off of this. Id. European authorities were so trained to look out for small smuggling ships, that they were not paying attention to larger freighters, which were carrying drugs, oil, and other contraband. Id. Law Enforcement Officers in Europe are just beginning to catch up to smugglers and become privy to their actions. Id. Italian authorities are using their experience with handling the Mafia to surveille the smugglers in order to gain more information on their techniques for smuggling goods into Italy. Id.

(56.) See Steve Scherer, Decriminalizing Cannabis Would Hurt Islamic State, Mafia - Italy Prosecutor, REUTERS (Apr. 18, 2016, 6:15 AM), http://www.reuters.com/article/us-italy-mafia-islamic-state-cannabis/decriminalizing-cannabis-would-hurt-islamic-state-mafia-italy-prosecutor-idUSKCNOXFUD (comparing both organizations and their involvement with trafficking). Both Mafia organizations and ISIS factions are finding common ground as they have similarities revolving around their general operations and forms of businesses. Id. Italian authorities are becoming more concerned as the two organizations are strengthening in their relations leading to concerns over national security. Id. See also Loulla-Mae Eleftheriou-Smith, Isis and Italy's Mafia 'Working Together' to Smuggle Cannabis Through North Africa Into Europe, INDEPENDENT, (Apr. 19, 2016, 6:15 AM), http://www.independent.co.uk/news/world/europe/isis-and-italy-s-mafia-working-together-to-smuggle-cannabis-through-north-africa-into-europe-a6991451.html (emphasizing growing relations between ISIS and Mafia).

(57.) See Francesca Astorri, The Mafia-ISIS Connection: Partners in Crime Or Perfect Strangers?, ALARABIYA (July 12, 2017), http://english.alarabiya.net/en/features/2017/07/12/The-Mafia-ISIS-connection-Partners-in-crime-or-perfect-strangers-.html (questioning relationship of ISIS and Mafia). See also Clarke, supra note 53 (highlighting partnership between groups). The drug market is a fairly new venture for ISIS and its introduction into this market is showing its willingness to branch out past its original means of revenue. Id. The drug trade is not something that is taken lightly in Islam as drug use and its sale is banned in Sharia law. Id. This endeavor into the drug trade is showing a further distinction between ISIS and the rest of Islam, as the group continues to follow its own laws. Id.

(58.) See Barbie Latza Nadeau, The Mafia Runs Guns for ISIS in Europe, DAILY BEAST (Mar. 24, 2016, 1:15 AM), http://www.thedailybeast.com/the-mafia-runs-guns-for-isis-in-europe (explaining Mafia's gun trade with ISIS). The Mafia is not only supplying ISIS with weapons, but it is also providing falsified documents and other resources, allowing ISIS connected agents to travel through Europe to conduct business. Id. See also Barbie Latza Nadeau, Italian Mob Trades Weapons for Looted Art from ISIS in Libya, DAILY BEAST (Oct. 18, 2016, 7:31 AM). http://www.thedailybeast.com/italian-mob-trades-weapons-for-looted-art-from-isis-in-libya (detailing black market exchange of guns for ancient artifacts). Italian officials uncovered an underground market for expensive Greek and Roman artifacts that are being traded from Libya and northern Africa to the Italian mob for weapons. Id. These historic pieces are sold everywhere from USD50,000 to more than USD1 million depending on their age and history. Id.

(59.) See Nadeau, The Mafia Runs Guns for ISIS in Europe, supra note 58 (showing Mafia's willingness to provide any resources to ISIS). The Mafia is no longer acting as only a financial partner to ISIS, but it is showing its willingness to aid these organizations in any way possible, which is of growing concern. Id. A growing number of Mafia affiliated members are running guns to the Islamic State. Id. Many of the weapons being traded are major weapons including Kalashnikov rifles, rocket propelled grenades, body armor, and other munitions. Id. What has been shown to be a larger threat to Europe than the arms trade between these two groups is the cooperation in moving Jihadist Soldiers through Europe. Id. Italian investigators have referred to this network as "[M]afia-sponsored terrorism travel agents." Id. The Mafia affiliates provide Jihadists everything from fake papers and identification, transport, logging, and other resources necessary to travel though Italy. Id. The same weapons being sold to ISIS are being brought back into Europe to help execute terrorist threats within the European Union. Id.

(60.) See Barbie Latza Nadeau, The Camorra-Connected Couple Running Guns--and Choppers--to ISIS, DAILY BEAST (Feb. 6, 2017, 1:13 AM) [hereinafter Nadeau, Camorra-Connected Couple], http://www.thedailybeast.com/the-camorra-connected-couple-running-gunsand-choppersto-isis (outlining connection between Camorra and radical jihadists). Police discovered that the party responsible for the truck attack in Berlin, Anis Amri, spent significant time in Camorra country prior to these events. Id. Though this may appear to be an isolated and coincidental occurrence, it also showing a growing trend of connections between terrorism, the Islamic State, and the Camorra. Id. See also Barbie Latza Nadeau, Did Paris Terrorist Move Freely Between Italy and Greece?, DAILY BEAST, (Nov. 23, 2015, 3:30 PM) [hereinafter Nadeau, Did Paris Terrorist Move Freely], https://www.thedailybeast.com/did-paris-terrorist-move-freely-between-italy-and-greece (questioning Italy's involvement with Paris terrorist).

(61.) See Nadia Francalacci, ISIS in Italy, The Safest Regions Where the Mafia There is the Mafia, PANORAMA (Jan. 31, 2017), https://www.panorama.it/news/cronaca/isis-itaIia-regioni-sicure-mafia/#gallery-0=slide-2 (arguing Mafia is protecting Italy from terrorism). Despite the Mafia's continued involvement with ISIS, many officials are still adamant that these groups are protecting the country. Id. ISIS operating in Italy and Europe is bad for the Mafia's business in the long run. Id. Though they are vastly different groups, the two organizations do compete in some similar markets, making it difficult for the Mafia to be a competitive seller. Id. Also, at the end of the day, the Mafia is loyal to the idea of Italy and it would not want attacks from outsiders to take place in its territory. Id. See also Black Flags from Rome (propagating ISIS expansion into Europe). ISIS sees Italy, and specifically Rome, as a strategically significant location, as it is both geographically in the center of Europe and a symbolic capital. Id. at 76-78. ISIS understands that the Mafia is a powerful force in Italy that has taken advantage of the weak government to control a large portion of the underground markets in Europe. Id. at 79. Despite ISIS working with the Mafia, it still has an adversarial relationship towards the group as it understands that the Mafia stand in the way of its conquest of Europe. Id. at 79.

(62.) See Steven D'Alfonso, Why Organized Crime and Terror Groups are Converging, SECURITY INTELLIGENCE (Sept. 4, 2014), https://securityintelligence.com/why-organized-crime-and-terror-groups-are-converging/(explaining partnerships between organized crime and terror groups). Transnational criminal organizations have been around for hundreds of years and have specific skill sets that are valuable to terrorist organizations. Id. As terrorism is on the rise, these groups see the need to increase revenue and are using these criminal organizations as partners and influencers in how to run their own terrorist organizations. Id. The Mafia is not the only criminal organization working with terrorists as there have been reports of the Mexican Cartels working with Hezbollah, as well as ties between the Columbian Cartels, and Russia with other terrorist organizations. Id.

(63.) See Hayden Ford, The Real Migrant Crime Wave: Mafia Exploitation of Migrants in Sicily, NEWS DEEPLY (Aug. 1, 2017), https://www.newsdeeply.com/refugees/community/2017/08/01/the-real-migrant-crime-wave-mafia-exploitation-of-migrants-in-sicily (exemplifying Cosa Nostra exploitation of turbulent migration crisis). The Mafia exploited the migrant crisis by not only skimming funds from NGOs, but by exploiting the refugees themselves, using them as prostitutes and drug dealers in return for protection. Id. See also Lorenzo Tondo, Mafia at Crossroads as Nigerian Gangsters Hit Sicily's Shores, GUARDIAN (June 11, 2017), https://www.theguardian.com/global-development/2016/jun/111/mafia-palermo-nigcrian-gangsters-hit-sicily-shores (revealing growing partnership between Mafia and Nigerian migrants). Over the past two years, the migrant crisis brought Nigerian street gangs into southern Italy. Id. The Mafia exploited these groups to sell drugs and run prostitution rings for it. Id. Though the Cosa Nostra in Sicily is bound by a code of honor, which normally prohibits prostitution and the direct sale of drugs, the Mafia are using the Nigerians as a "loop hole" to break its own rules and expand its criminal enterprises. Id. The Mafia is normally restricted by a rigid code, which disallows its members to talk with outsiders, especially law enforcement, and condemns certain immoral practices. Id.

(64.) See Raffaella R. Ferre, The New Generation of Young Mafia Members Terrorizing Naples, VICE (Sept. 30, 2015), https://www.vice.com/en_us/article/bnpywq/the-new-generation-of-mafia-camorrists-terrorising-naples-876 (showing evolution of mafia groups in Italy). The Cosa Nostra in Sicily typically is viewed as a highly organized and honor-bound brotherhood, but the growth of other organizations, such as Camorra and Ndranghetta, show a willingness to run its family through chaos and terror. Id. The Camorra is increasingly made up of younger and younger members, as its older associates become imprisoned. Id. The Camorra is less structured, and like other groups, members often fight amongst themselves and operate farther from the Mafia's normal code of honor. Id.

(65.) See Burke, supra note 4 (showing mobsters admiration for ISIS). The two groups have a mutual admiration and affinity for chaos and terror. Id. An Italian judge was cited saying:
[A]n existential thread links the young men who course through the
streets of Naples with guns, and jihadi militants. Both groups are
obsessed with death. Maybe they are in love with the idea, they are
seeking it out, almost as if it is the only way of giving meaning to
their lives.


Id.

(66.) See Burke, supra note 4 (linking both organizations to violence, terror, and death). Certain mafia groups grew admiration for ISIS; one group even calling themselves "Barbuti," meaning "the bearded ones." Id. Both of these organizations have capitalized off of fear and anti-government sentiments, often times reaching out to impressionable youths. Id. Both organizations are sharing recruiting methods and using similar social media platforms to organize groups. Id. The Mafia in Italy is becoming younger and less like the stereotypical mobsters depicted throughout Italy's history. Id.

(67.) See M. Piero Luigi Vigna, National Anti-Mafia Prosecutor, The activities of Italy's national anti-mafia directorate in the international context, Speech at Pan-European Conference (May 22-24, 2000), in WHAT PUBLIC PROSECUTION IN EUROPE IN THE 21ST CENTURY, Nov. 2000, at 143 (detailing prosecutorial efforts in Europe and Italy against organized crime). Europe's geography makes it easier for transnational organizations to coexist, as it is easier for many organizations to pool resources to accomplish their goals. Id. This led to a need for countries to work together against organizations that extend past their borders. Id. See also Antimafia Commission 1976. supra note 5 (allowing Italian government to use all resources to combat terror threats). Though this commission was created with the Mafia in mind, it can be used to combat any potential dealings of the Mafia and other terror organizations. Id.

(68.) See Burke, supra note 6 (describing Italy's tough stance on handling terrorism). Italian law enforcement is using the same methods for handling terrorism as it has with organized crime. Id. Italy implemented a police unit that combats both terrorism and the Mafia, using similar strategies. Id. Italy's history of handling the Mafia through heightened surveillance, intelligence, and enforcement led to less terrorism in its country. Id.

(69.) See Marone, supra note 5 (analyzing Italy's strict deportation policy). See also Paravicini, supra note 5 (emphasizing Italy's zero-tolerance policy strategy with terrorism). Italy puts an emphasis on enforcing and preventing crimes of terrorism, which came at a cost to its citizens' personal liberties. Id. Italy has taken drastic measures in deporting and detaining suspected terrorists, with officials declaring that they would rather cause a civil rights violation, than see a major act of terror within their country. Id. See also Ford, supra note 63 (explaining Italy's current migrant crisis). Though Italy has strong deportation laws in place, it is also facing unprecedented levels of migration into the country, which could lead to further complications of which it has never dealt. Id.

(70.) See U.S. Dep't of St., COUNTRY REP. ON TERRORISM 2016-ITALY (July 19, 2017), available at https://www.state.gov/j/ct/rls/crt/2016/272231.htm (outlining prosecutorial efforts on national scale). See also D.L. n. 306/ 1992 (It.) (enacting urgent policies to combat Mafia activity). See also Piano Straordinario Contro Le Mafie, Nonche Delega al Governo in Materia di Normativa Antimafia, Legge 13 Agosto 2010, n. 136, G.U. Aug. 23, 2010, n. 196 (It.) [hereinafter Antimafia Code] (outlining need for harmonized Antimafia policy in European Union). In this act, the Italian parliament describes the need to adapt Italian legislation to the European Union Law. See also Daniela Cardamone, Criminal Prevention in Italy: From the Pica Act to the Anti Mafia Code, Eur. Ct. H.R. (Apr. 26, 2006) (illustrating preventative policies in place to combat Mafia). The Antimafia laws and preventive measures work through a multi staged approach:
a) collection of the anti-mafia legislation contained in the various
bodies of laws, including the provisions already contained in the
criminal code and in the code of criminal procedure); b) harmonisation
of the legislation referred to in letter a); c) coordination of the
legislation referred to in letter a) with the provisions introduced by
law 136; d) finally, the adaptation of the Italian legislation to the
European Union law.


Id. at 13.

(71.) See Daniels, supra note 40 (showing Italy's place in the European Union). Italy's government has always been an advocate for globalizing and unifying the various countries of Europe. Id. Prior to the European Union, Italy's government has voted to bring the governments of Europe together. Id. Italy had an active role as a founding Member of the European Union. Id. The fallout from World War II laid the stones for the start of the European Union. Id. Many European countries saw a need to form treaties with their neighbors, which led to further cooperation and reliance on one another. Id.

(72.) See Ruper Myers, The Greatest Threat to the EU Lies in Italy, a Country on the Edge, New European (June 14, 2017), http://www.theneweuropean.co.uk/top-stories/the-greatest-threat-to-the-eu-lies-in-italy-a-country-on-the-edge-1-5061824 (illustrating Italy's current issues in European Union). Italy's government is undergoing issues based on a stagnant economy. Id. Italian banks are struggling to turn profits as their economy is failing to grow. Id. These issues are stressing an already strained government, which has had issues in the past with corruption, the migrant issue, and constantly changing political regimes. Id. With these issues occupying the government it is making it nearly impossible for the government to face issues with ISIS and the Mafia. Id. See also Jan Techau, The Four Threats to European Security, CARNEGIE EUROPE (Oct. 2, 2012), http://carnegieeurope.eu/strategiceurope/?fa=49541 (describing security issues in Europe). Europe's main security threats stem from "(1) [l]ack of confidence, (2) the de-linkage across the Atlantic, (3) lack of public resilience, and (4) the undermining of European solidarity." Id. Europe is struggling to work as a collective as the countries of the European Union are competing with one another instead of working together. Id. The public is losing trust in the European Union, which is leading to European Nations wanting to leave the Union. Id.

(73.) See Stefano Stefanini, The EU Can't Solve Italy's Migration Crisis, POLITICO (July 29, 2017), https://www.politico.eu/article/eu-cant-solve-italy-migration-crisis-refugees-mediterranean-sea/(emphasizing European Union's current issues with migration crisis). Italy's infrastructure cannot withstand the strain being caused by the number of migrants flowing to Italy. Id. Italy's economy has struggled through a recession and its issues are being compounded by the migrant issue. Id. Nearly 75% of the migrants who come to Europe start in Italy. Id. The infrastructure and programs needed to support this has been costly to Italy. Id. See also European Commission, Managing Migration: EU Financial Support to Italy (Nov. 2017), available at https://ec.europa.eu/home-affairs/sites/homeaffairs/files/what-we-do/policies/european-agenda-migration/20171124_managing_migration_eu_financial_support_to_italy_en.pdf (detailing amount of money sent to Italy to support migration crisis). See also European Commission, Migration: A Roadmap (Dec. 7, 2017), available at https://ec.europa.eu/home-affairs/sites/homeaffairs/files/what-we-do/policies/european-agenda-migration/20171207_migration_a_roadmap_en.pdf (illustrating number of migrants fleeing to Europe). In 2016 alone, nearly 720,000 refugees resettled in Europe. Id. Of these migrants coming to Europe, a majority start their journey in Italy. Id.

(74.) See Press Release, European Parliament, Mafias: Special Committee to Probe Organised Crime In EU (Mar. 14, 2012), available at http://www.europarl.europa.eu/news/en/press-room/20120314IPR40749/mafias-special-committee-to-probe-organised-crime-in-the-eu (showing creation of special committee to fight Mafia). This special committee was created to evaluate and recommend potential legislation to handle international threats. Id. The committee members will travel to various countries and meet with judges, victims, and other officials to help address the issues posed from organized crime. Id. See also Kathy Gilsinan, Interpol at 100: Does the World's Police Force Work?, ATLANTIC (May 12, 2014), https://www.theatlantie.com/international/archive/2014/05/interpol-the-global-police-force-that-isnt/362086/ (discussing limitations of Interpol). Interpol represents an example of an interconnected agency, but even it has its limitations and is spread too thinly to be effective against terrorism. Id.

(75.) See supra notes 31-32 and accompanying text (discussing increase in growing presence of Islamic State across globe). With every physical loss to ISIS in the Middle East, it appears the organization expands and showcases its notoriety across the globe. Id. Though the group's caliphate appears to be struggling, its global fight in western countries is intensifying. Id. See also Hassan, supra note 33 (analyzing ideological war). ISIS's battle goes beyond conquest, as its fighters believe in a divine right to make an all ruling empire. Id. Though ISIS is losing the physical war, it gained traction by fighting for something more than just physical territory. Id.

(76.) See Kranz & Gould, supra note 33 (discussing ISIS's loss of physical territory). ISIS is losing the physical battle, as Anti-ISIS forces focus their fighting on reclaiming physical land that the Islamic State captured. Id. See also Hassan, supra note 33 (detailing evolution of ISIS's plans). "Its much-vaunted caliphate has gone, crushed by the might of Russian, Syrian and US warplanes, Iran-backed militias, Kurdish forces and armies launched by Damascus and Baghdad." Id. These anti-ISIS forces have combined to suppress ISIS in the physical battlefield. Id. Despite its setbacks, ISIS remains resilient in its sectarian battle across the globe. Id.

(77.) See Kranz & Gould, supra note 33 (arguing importance of loss of Raqqa to ISIS). Raqqa became known as the capital of the Islamic State and contained many of its officers. Id. The loss of this capital was a major victory to the Anti-ISIS coalition marking a major victory in the fight. Id. Raqqa represented a symbolic capital for ISIS and was centrally located within its territory. Id. ISIS is geographically important as it represents a part of Syria close to Iraq, which contains many of the religious sects backing ISIS. Id.

(78.) See Kranz & Gould, supra note 33 (showing symbolic importance of loss of Raqqa). This showed a major turning point in the battle to suppress the Islamic State. Id. The loss of Raqqa is important because it represents the capital city of the Islamic State. Id. As the organization loses physical ground in Syria and Iraq, it is becoming pushed further underground, which raised concerns of attacks from associated groups looking for retaliation. Id.

(79.) See Kranz & Gould, supra note 33 (illustrating importance of ISIS territory). See also supra note 32-33 (showing growth in number of groups aligned with ISIS). Since ISIS faced major setbacks with respect to losing territory, its Caliphate became less of a priority and it focused more on a sectarian war. Hassan, supra note 33. The number of radical groups that have aligned with ISIS is startling. Id.

(80.) See supra notes 31-33 and accompanying text (arguing global presence of ISIS through subsidiary groups). Though ISIS lost a significant amount of its physical territory, it managed to expand its footprint through isolated organizations that have pledged their allegiance to the caliphate. Id. See also Leopold-Cohen, supra note 33 (showing importance of radical ideologies for Islamic State). ISIS managed to entrench itself in all western countries through its radical beliefs, promoting the creation of ideologically similar groups across the globe. Id. See also supra Part II.B and accompanying text (examining history and reason for fighting in Middle East). As a large group of ISIS fighters are in western countries, they have taken it upon themselves to plan attacks on those nations. Id. These insurgencies are incredibly alarming, as many of the attacks result in the loss of innocent citizens. Id. This is why ISIS became such a threat to the Western World; it has shown how far reaching its organization is and how willing it is to make sacrifices to its overall cause. Id.

(81.) See supra note 61 and accompanying text (illustrating precautions surrounding Europe). As the Mafia continues to build on its relationship with ISIS it further opens Europe up to potential attacks from the organization. Id. The relationship allowed ISIS to reach parts of European and gain access to goods and services that had not been attainable to them. Id.

(82.) See Black Flags From Rome, supra note 61, at 85 (discussing symbolism of Vatican and Rome). ISIS values Rome as the capital of Europe because of its central location and it being the home of the Vatican. Id. at 85. This kind of recognition puts Italy in a serious amount of harm, as ISIS has shown its willingness to attack landmarks and public venues. Id. at 84-86. There is a clear religious importance to the Vatican and ISIS knows its importance to not only Catholicism, but also to the Western World. Id. at 78. The European Union needs to give importance to ISIS's threats towards Rome as it has made it clear that the holy city sits within its cross hairs. Id. at 79.

(83.) See Black Flags From Rome, supra note 61, at 78-79 (arguing significance of areas of Rome). As the Vatican is the capital of the Roman Catholic Church, it is seen as a major landmark and is a target for ISIS's religious war. Id. at 86. The Islamic State looks to spread Islam across the globe and it sees other religions as a threat to that goal. Id. Though ISIS's goal of a Caliphate has diminished, it has still shown its willingness to execute strategic attacks across the globe. Id. at 71.

(84.) See Francalacci, supra note 61 (explaining ISIS's potential threat to Italy). ISIS has as a great amount of respect and fear for the Mafia and Italy, and because of this there is a natural competition. Id. ISIS knows that the Mafia could potentially present issues if there was ever any expansion into Europe; because of this, there is a fear that Italy could be susceptible to future terrorist attacks. Id. As of right now, the two organizations appear to be amicable, but if their relationship was to sour then this could put Italy in further danger. Id. The Italian government needs to prepare for this possibility as the Mafia has already allowed ISIS to extend itself far into its territory. Id.

(85.) See Black Flags From Rome, supra note 61, at 66-68 and accompanying text (arguing need for protection in Italy). ISIS's express threats to Rome should raise serious concerns and call for a greater need to protect the capital city. Id. at 68. Though Italy took many precautions against potential terrorist organizations, this relationship is showing a partnership between two powerful organizations that should not be taken lightly. Id. at 75.

(86.) See supra notes 59-61 and accompanying text (exploring evolution of ISIS and Mafia's relationship). ISIS and the Mafia's relationship has continued to expand with every new deal. Id. See Nadeau, Did Paris Terrorist Move Freely, supra note 60 (detailing relationship between ISIS and Mafia). At first the two organizations appeared to be business partners, but this has expanded to a more personal relationship with a mutual admiration. Id.

(87.) See Nadeau, Did Paris Terrorist Move Freely, supra note 60 (describing Mafia's willingness to allow ISIS in Italy). The Mafia has shown little hesitation to allow members of ISIS through Italy. Id. Though it has benefited from this relationship, it has shown more reluctance in the past with regards to allowing competitors within its territory. Id. See also supra note 13 (detailing Italy's history of foreign invaders). Despite their skepticism towards foreign intruders, the Mafia has allowed ISIS to travel through and conduct business. Id.

(88.) See O'Connor, supra note 14 (arguing Italy's history of protecting itself from foreign intruders). Since Italy's founding, it had to protect itself from foreign invaders. Id. This history makes many Italians protective of their country from foreign influences. Id. It is surprising that the citizens of Italy would not put up more resistance against allowing ISIS members through their country. Id. The Mafia is working with ISIS, yet the people of Italy put up with the Mafia within the country. Id. Organized crime has been institutionalized into the Italian way of life, however the people of Italy should be more resistant to terrorist groups within its borders. Id.

(89.) See supra notes 57-59 (expanding on growing relationship between ISIS and Mafia). The Mafia's relationship with ISIS has extended past running guns and developed into aiding them during certain terror attacks. Id. See Nadeau, Did Paris Terrorist Move Freely, supra note 60 (showcasing Mafia's willingness to aid ISIS). It is uncertain of how much information the Mafia is provided, however it has become complicit in certain terrorist plots. Id.

(90.) See Nadeau, Did Paris Terrorist Move Freely, supra note 60 (emphasizing importance of this relationship to national security in Italy). As the Mafia and ISIS's relationship grows, it continues to put Italy's security at greater risk by opening the country to this terrorist organization. Id. With every new business dealing, the Mafia is allowing ISIS to have more influence within its country. Id. This natural security threat is of concern not only to Italy, but to the rest of the European Union as well. Id.

(91.) See Francalacci, supra note 61 (arguing Mafia's control over region and willingness to protect it). Despite the concessions made to the Islamic State, there is still a strong belief that the Mafia is protecting Italy from this organization. Id. The Mafia has a natural tendency to protect its country from outsiders. Id. Southern Italians have a history of defending their territory from intruders. Id. Right now, the Mafia's motives are masked, but many Italian citizens believe that the Mafia is protecting the country from ISIS. Id.

(92.) See Kirchgaessner, supra note 39 (showing Mafia's ability to protect regions of Italy). The Mafia controls a large amount of southern Italy's resources and black market, and it is in the best position to control ISIS's presence in this part of Europe. Id. Though the Mafia does not have a monopoly on the black market, it does know of the business dealings within the country. Id. As Italy represents the southern gateway into Europe, the Mafia is strategically located to control all of the black market deals coming from across the Mediterranean. Id.

(93.) See Do Mafia Prosecutions Give Italy an Edge in Preventing Terror Attacks, supra note 38 (connecting lack of terrorist attacks in Italy to Mafia's presence). Many argue that there is a clear correlation between the Mafia's involvement with ISIS and the lack of ISIS attacks in southern Italy. Id. Despite the numerous major terror attacks in recent years, none have been located in Italy. Id. See Timeline-Terror Attacks in Europe, supra note 39 (illustrating lack of terror attacks in Italy). There has been an intensification of attacks in Europe; however, there have been no major attacks in Italy. Id. See Two Years of Terror, supra note 39 (outlining spread of terrorism throughout Europe). From 2015 to 2017, there have been 364 confirmed deaths because of major terror attacks in Europe in six different countries. Id. Of the six countries in Europe, there have been "six incidents in France, three in Germany, three in Britain, two in Spain, one in Belgium and one in Stockholm." Id.

(94.) See Kirchgaessner, supra note 39 (exploring theory of Mafia protecting Italy from ISIS). The Mafia has taken steps to monitor and surveille the Islamic State's involvement in Europe. Id. It is fair to say that the Mafia has taken certain measures to protect its country. Id. There is some debate whether it is the Mafia protecting Italy or whether it is Italy's government, which has developed strategies to protect the country from terrorist threats. Id.

(95.) See Black Flags from Rome, supra note 61, at 79 (detailing ISIS's knowledge of Mafia's strength). ISIS knows how powerful and influential the Mafia is in this area. Id. at 79-80. ISIS expressly believes that the Mafia is the one major impediment in its way of conquering Rome. Id. Since ISIS identified the Mafia as a major competitor and threat, there is concern that their relationship is unsustainable. Id. at 79. ISIS's motives in dealing with the Mafia remains unclear as the various Mafia families are a major threat to ISIS's Caliphate. Id.

(96.) See Heitita & Pipitone, supra note 4 (detailing current relationship between Mafia and ISIS). Up until this point, the two groups have had a mutually beneficial relationship. Id. The two took over the black markets in their regions and have kindled an amicable relationship through their trade. Id.

(97.) See supra notes 49-60 (outlining multiple ventures two groups benefit from). The two groups have engaged in everything from the sale of guns and antiquities, to the smuggling of drugs and oil, to the provision of safe passage to members of the Islamic State. Id. Their relationship flourished over the past few years, starting with trading oil and progressing to providing asylum and assistance to wanted members of ISIS. Id. The various Mafia families have shown a willingness to aid and abet ISIS in its endeavors. Id.

(98.) See Astorri, supra note 58 (showing growth in relationship between two groups). As ISIS struggled to form its Caliphate, it needed to develop new forms of revenue in order to keep funding its conquest. Id. This enabled it to venture into the drug trade and to even sell many antiquities on the black market. Id. It has been rumored that some of the items that ISIS traded to the Mafia have made their way back to wealthy Americans and celebrities. Id.

(99.) See Clarke, supra note 53 (describing ISIS's need to open new streams of revenue to finance war). The war ISIS waged is coming at a great cost to ISIS's forces. Id. As it continues to use the same resources, it must branch out and explore new opportunities to bring in revenue. Id.

(100.) See Cornibe, supra note 46 (juxtaposing two organizations' ideologies and motivations). Though the two organizations found a middle ground, they are still ideologically different. Id.

(101.) See supra Part III.A (expounding on ISIS and Mafia's tenuous relationship). These two groups are bound to eventually reach an impasse as they must decide how they will coexist in the future. Id. Both of these organizations have differing goals, which will have to come to light sooner rather than later. Id.

(102.) See Organised Crime in Europe, supra note 1, at 58-60 (2006) (depicting Mafia's history of control over Italy). The Mafia has never shown a willingness to share its control over southern Italy. Id. Since its inception Italy has protected itself from foreign intruders. Id. This helped shape the culture of southern Italy. Id. The Mafia greatly opposed fascism during the reign of Mussolini as they saw this as a threat to their control over the region. Id. The Mafia represented and aided a large part of the resistance fighters in Italy during World War II. Id.

(103.) See Origins of the Mafia, supra note 12 (illustrating rise of Mafia in Europe and Americas); Organized Crime in Europe, supra note 13, at 49-55 (detailing Mafia's history of control over Italy); Italy Corruption Report, supra note 17 (discussing Mafia's presence in Italy long before its unification). Since before Italy was established as a country, the Mafia has been in that territory. Organized Crime in Europe, supra, at 49-55. The Mafia is widespread throughout Italy. Italy Corruption Report, supra. There are four major mafia groups, made up of various families, which contain hundreds of members and associates. Id. In Italy, it is not unfair to say that everyone knows someone in the Mafia. Id.

(104.) See Callimachi & Tondo, supra note 55 (noting Italy's history of protecting against outside influences). Italy has always been a contested land. Id. Owing to its strategic location in Europe and its proximity to the Mediterranean Sea, it has always been seen as a valuable land. Id. Italy has defended itself from every kind of foreign invader throughout its history, leaving it with a diverse culture built through war. Id. This history in Italy made the country very skeptical and protective from outsiders. Id.

(105.) See Black Flags from Rome, supra note 61, at 62 (detailing ISIS's goals in Europe). ISIS's eventual goals of conquering Rome will go against the Mafia's longstanding control over the country. Id. The Mafia has its hand in all parts of Italy's way of life, from politics to the black market. Id. The Mafia managed to control politics in Italy and have controlled many of its major businesses, legitimate and illegal. Id.

(106.) See What is 'Islamic State'?, supra note 22 (outlining ISIS's global conquest). Since its inception, ISIS attempted to expand its organization and conquer the Middle East. Id. ISIS's conquest does not stop there as it wishes to expand globally. Id.

(107.) See supra Part III.A.2 (anticipating future problems between these two organizations). Despite their partnership, the two organizations have conflicting goals and are competitors in the same markets. Id. Eventually its relationship will reach an impasse and the groups will have to address their conflicting beliefs and goals. Id. This confrontation will come at a cost to Europe. Id.

(108.) See supra Part III.B-C (emphasizing potential issues if relationships were to devolve). Though the two groups worked together in their limited relationship, the more exposure they have with one another the more likely their relationship will sour. Id. At the end of the day, both groups have conflicting ideologies and are competitors for the same business. Id. After a certain point, the two organizations will meet an impasse and will need to deal with their contradicting goals. Id.

(109.) See Francalacci, supra note 61 (depicting Mafia's protection of Italy from ISIS). The Mafia allowed members associated with ISIS into southern Italy, but they made it clear that they can only cross through the territory and not stop. Id. Both sides know that this relationship is tenuous as they are both gaining from this relationship. Id. That being said, there is a sense of concern that an elevated presence of ISIS in Italy could potentially be damaging. Id.

(110.) See Origins of the Mafia, supra note 12 (discussing history of Mafia protecting southern Italy). The Mafia was formed to protect southern Italy from outside intruders and influences. Id. This is something that various organizations have done since their inception. Id. See Pianigiani, supra note 48 (outlining current struggles surrounding migration crisis). As it becomes harder for the Italian government to monitor foreigners within its borders because of the migration crisis, there is a strong hope that the Mafia has been protecting Italy's land. Id.

(111.) See Gambetta, supra note 18 (describing ISIS's and Mafia's importance in their regions). Both groups are greatly influential in their respective regions. Id. at 49-50. The Mafia and the Catholic Church have connections going back beyond the unification of Italy. Id. These two organizations have an understanding and, though the Catholic Church condemned the Mafia at times, the Mafia organizations are made up of men who are devout Catholics. Id.

(112.) See Organised Crime in Europe, supra note 1, at 49-50 (showing how institutionalized Mafia has become in Italy). The Mafia incorporated itself into every aspect of Italian life. Id. The Mafia became such a large part of Italy that it is connected to every facet of the government. Id. at 70. The Mafia owns numerous businesses, whether illegal or legitimate; often citizens look to the Mafia when they are in need. Id. at 66-70.

(113.) See Organised Crime in Europe, supra note 1, at 66-70 (detailing Mafia's global presence). For hundreds of years, the Mafia has not only grown roots in Italy, but also all across the globe. Id. With a large number of Italians immigrating to America in the early 1900s, the Italian people also brought their way of life to the New World. Id. Included in this lifestyle are connections with organized crime, for example the Sicilian Cosa Nostra started its own families in North America. Id. See also Wambu, supra note 43 (illustrating Mafia's presence in Kenya). The Mafia managed to extend its influence into Asia and northern Africa. Id. As of late, the Italian Mafia has an active influence in casinos in Nairobi. Id.

(114.) See Organised Crime in Europe, supra note 1, at 67 (noting Italy's weak centralized government leading to growth of Mafia). Over the course of its history, Italy struggled with a weak central government. Id. Each region of Italy contained different cultures and customs, and even after the unification, it became hard to unite all of Italy. Id at 58-60.

(115.) See supra Part II.B (reviewing history and motivations for Islamic State). ISIS started the Caliphate as a state and ruled through Islamic Law, based on God's wishes. Id. ISIS believes it is fulfilling the wishes of God by spreading its Islamic State across the globe. Id.

(116.) See What is 'Islamic State'?, supra note 22 (examining support for Islamic State's Caliphate). Numerous groups across the globe have pledged their support to the Caliphate, and whether it is attainable, it is something for which they will continue to fight. Id. Following the War on Terror, there was a great amount of distrust of the Western World. Id. There was a great amount of anger directed at the Western World for leaving countries war torn. Id. Extremists were able to exploit this anger in order to recruit and indoctrinate individuals. Id. History has shown that radical ideologies spread easier following times of war because of the anger and turmoil that is left in its place. Id.

(117.) See Munoz, supra note 31 (characterizing idea of ISIS being more than physical territory); What is Left of ISIL's 'Caliphate'?, supra note 32 (exploring difficulties in fighting ideological battle). Despite the physical victories in suppressing ISIS, local governments struggled to suppress the spread of ISIS's ideologies. Munoz, supra. The government tried to use "containment," the failed policy for stopping the spread of communism, which has only shown its inability to stop the spread of ISIS's beliefs. Id. This ideological battle is of greater concern in the age of the internet, where people from across the globe can correspond and share ideas within seconds. Id. New innovations in technology have made it easier to spread ideologies across the globe. Id. These innovations bring vast amounts of information to a wider audience and allow information to spread at a higher rate than possible. Id. Islamic extremists are nothing new, but they have been able to use technology to spread their platform and recruit across the globe. Id.

(118.) See What is Left of ISIL's 'Caliphate'?, supra note 32 (indicating appeal of Islamic State to extremists). See also Khedery, supra note 3 (arguing war torn countries as possible explanation for growth in extremism). Following the occupation of the Middle East during the War on Terror many Middle Eastern people became frustrated with their war torn country. Id. They blamed the Western World for the destruction that took place in their countries and were left with failing states. Id.

(119.) See Khedery, supra note 3 (detailing ISIS's growth from weak state in Iraq and Syria). The Islamic State grew from the turbulence that followed the wars in the Middle East. Id. During this time, many people embraced extremism as a way of taking out their anger from the wars that had taken place in their countries. Id. War causes a fear of power, which leaves individuals to be more open to radical ideologies. Id.

(120.) See Moore, supra note 4 (questioning motives for ISIS and Mafia's relationship). The more willing the Mafia becomes in allowing ISIS to cross into Europe, the more potential there is for possible attacks. Id. Italy is acting as the gateway into Europe, and by allowing ISIS through that gate, it is putting Europe in further danger. Id.

(121.) See Cornibe, supra note 46 (considering potential ramifications of relationship between two groups). This partnership can have far reaching consequences in Europe in the long run. Id. With every new transaction, these two groups appear to be furthering their relationship and exposing Europe to ISIS. Id. Europe is already struggling to handle the Migrant crisis and with the Mafia allowing members of ISIS into their territory, it is becoming hard for Italy to keep its country safe. Id.

(122.) See Cornibe, supra note 46 (reviewing ISIS's current activity in Italy). What started as simple business partnership progressed into something much more. Id. These two groups have moved past mere business dealings and have started to share an admiration for one another. Id.

(123.) See Burke, supra note 4 (comparing these two organizations). Though these two organizations are no strangers to violence and terror, they ultimately have conflicting goals. Id. Despite this, the organizations have managed to have a mutual admiration for one another. Id.

(124.) See Khedery, supra note 3, at 20 (emphasizing international presence and weak states as contributing to development of these groups). The far-reaching spread of these groups and their growth from weak states, are similarities that show a pattern. Id. War and economic issues have allowed for these two organizations to flourish. Id. The governments surrounding them have failed to contain them from spreading. Id. Corruption and failing economies allowed countries to become breading grounds for extremism. Id.

(125.) See Threat Assessment: Italian Organized, supra note 16 (detailing need for outside intervention to stop further violent acts). Italy became inundated with the migration crisis and its own economic concerns. Id. There is much need for outside intervention to help aid these crises. Id.

(126.) See John, supra note 3 (examining origins of these two organizations). Italy suffered from years of corruption and a stagnant economy, which allowed for the Mafia to flourish. Id. ISIS developed following the War on Terror, which left much of the Middle East in shambles. Id. ISIS was able to exploit the mistrust of western governments to recruit and incite individuals into following Islamic Extremism. Id.

(127.) See Organised Crime in Europe, supra note 1, at 66-67 (discussing importance of state building in limiting growth of extremists within its country). Often, radical organizations are able to entrench themselves in countries undergoing regime changes. Id. Italy's political control shifted among many different political parties and it struggled to keep its economy growing. Id. A stable government can help limit radical ideologies and foster trust in the government. Id.

(128.) See Burke, supra note 6 (detailing long history in countries leading to radicalized groups). By building a stronger state, Italy would not only continue its fight against the Mafia, but would limit extremist thinking in the country. Id.

(129.) See Burke, supra note 6 (depicting struggles within countries). Italian politics is plagued by corruption leading to the people of Italy having little faith in the system. Id. With the Mafia and other criminal organizations having ties to the government, Italy has seen its share of rigged elections and corrupt officials. Id. There is a general belief that the people's vote and opinion do not matter, because the government will act on its own accord, regardless of how the people feel. Id.

(130.) See supra notes 13-14 (outlining local allegiance over national pride). Most Italians feel greater sentiments for their own local towns, than they do to their relatively young nation. Battilana, supra note 13, at 14-18. Italy is a relatively young nation and for a long time was made up of smaller providences. Id. Italians have often identified themselves by their regions, which all contain vastly different cultures. Id. This combined with the Italian government's instability caused many citizens to feel a greater pride in their providences over their national government. Id. This allowed the Mafia to flourish as these organizations developed a great amount of pull over regional governments and the people of Italy developed a great deal of mistrust towards their National government. Id.

(131.) See Organised Crime in Europe, supra note 1, at 66-70 (reviewing difficulties Italy faced combating Mafia). Though there has been some success, Italy has never been able to eradicate the Mafia. Id. Italy has undergone many different regime changes that have made it hard for the government to take a united front against the Mafia. Id. Over the past few decades, Italy has managed to have some successes in its fight against the Mafia; however, as of late, economic issues which have been exacerbated by the migration crisis have distracted the government. Id.

(132.) See Organised Crime in Europe, supra note 1, at 47-70 (examining history of Mafia in Italy). Corruption is a major issue that Italy faced as the Mafia has become so prevalent; every form of government developed ties to the Mafia. Id. at 78. Italy has a corrupt government, which in part is because of the lack of transparency and accountability. Id. at 78-79. The European Union has expressed the problems surrounding corruption but has yet to take positive steps towards addressing these issues. Id.

(133.) See Jamieson, supra note 35, at 40-74 (discussing history of development of Antimafia legislation in Italy). Italy has had to incorporate a lot of trial and error to find how to best handle the Mafia. Id. at 2-5. Years of policy changes and new methods have led the government to develop a system with some success. Id.

(134.) See Jamieson, supra note 35, at 2-5 (outlining many tactics used to help suppress Mafia activities in Italy through legislation). These policies and tactics have involved everything from expedited trials to wiretapping laws. Id.

(135.) See Jamieson, supra note 35, at 16-23 (juxtaposing policies to other governments' legislation). These laws give Italy a higher amount of discretion to prosecute individuals involved with organized crime. Id. In other countries, such as the United States, these policies may be seen as unconstitutional. Id. Italy often prioritized public safety over civil liberties, which came at a cost to personal freedoms. Id

(136.) See Jamieson, supra note 35, at 40-65 (expressing policies put in place to fight Mafia). These kinds of policies are only a few of the laws that Italy successfully implemented in its fight against the Mafia. Id. Italy also took precautions by closely monitoring prisons, which can be recruiting grounds for the Mafia, and through the use of protective custody and wiretapping to obtain information on these organizations. Id.

(137.) See Organised Crime in Europe, supra note 1, at 47-50 (examining history of Mafia in Italy). Corruption is a major issue that Italy faced as the Mafia became so prevalent that every form of government has ties to the Mafia. Id. at 47. The Mafia uses extortion, bribery, money laundering, and other tactics to control government officials. Id. at 49.

(138.) See supra note 5 (discussing development of Antimafia and Antiterror policies over time in Italy). Though it has been a constant work in progress, Italy has had decades to develop and incorporate its Antimafia policies. Id.

(139.) See Paravicini, supra note 5 (comparing Italy's development to European Union). Italy has a greater history of handling acts of terror and has used this time to prevent and try to develop a response to these types of events. Id. Italy spent the past decades cultivating a response system for handling the Mafia. Id. This very system is instrumental in fighting terrorism, while many countries in Europe do not have the same framework in place for handling these types of conflicts. Id.

(140.) See Paravicini, supra note 5 (addressing struggles that have eventually led to breakthroughs involving Antimafia tactics in Italy). See also Antimafia Commission 1976, supra note 5 (outlining issues and action needed to combat Mafia). Most of Italy's success came following the Antimafia legislation of the 1960s. Id. Where in years prior, the Mafia was growing and operating at an alarming rate, the government managed to control and limit its influence. Id.

(141.) See supra note 13 (emphasizing Italy's governments fight against radical groups throughout its history). The Mafia is an institution in southern Italy and the government had to build itself around this group. Id. Battilana, supra, at 14-18. While the government faced many regime changes and transformations, the Mafia remains a constant part of Italy's way of life. Id. Italy is not new to the fight against extremists as this is something that they have had to handle since the country's beginnings. Id. Though the Mafia still exists, the country grew, adapted, and implemented policies to fight terrorist organizations within its borders. Id.

(142.) See Francalacci, supra note 61 (showing small number of terror attacks in Italy). There has been a significantly smaller amount of terror attacks in Italy in the past few years, despite its long history of violence. Id. Italy evaded massive terror attacks in recent decades due in large part to Italy's law enforcement efforts. Id. Unlike many other European countries, Italy became better situated to fight terrorism based on its years of policing the Mafia. Id.

(143.) See Francalacci, supra note 61 (arguing Mafia is protecting southern Italy from ISIS). Some Italian citizens believe that the Mafia is protecting the region from outside influences. Id. Though the Mafia has an active role in tracking outsiders within its territory, the country of Italy cannot rely on the Mafia for its protection. Id. At the end of the day, the Mafia is a self-interested organization, which is bringing the very threat of terrorism to Italy and Europe's door. Id.

(144.) See Francalacci, supra note 61 (detailing Mafias precautions of allowing ISIS in Italy). See also Nadeau, The Mafia Runs Guns for ISIS in Europe, supra note 58 (illustrating example of Mafia allowing ISIS into Italy despite security concerns within country). The Mafia seized the opportunity to not only trade with Jihadist fighters, but to also provide them with fake identification, transportation, and other resources necessary to travel through Europe. Id.

(145.) See Kirchgaessner, supra note 39 (expressing importance of legislation to stopping Mafia). The Antimafia agenda needs to continue to be adapted and used in the fight against these organizations. Id. Italy's government took measures to surveille, expedite prosecution, and keep criminals separated in prison. Id. By instituting policies that remove potential threats from the country and stop the spread of extremism, Italy managed to successfully combat terrorism. Id. Though it has come at a loss of civil liberties, many of Italy's policies have been successful. Id. Nothing is foolproof, but these are the types of policies that need to be enacted on a larger scale in order to protect the rest of Europe from threats of terrorism. Id.

(146.) See Do Mafia Prosecutions Give Italy an Edge in Preventing Terror Attacks?, supra note 38 (suggesting Italy's history of fighting Mafia created safer country today). Italy has a history of fighting organizations based around terror. Id. Italy created legislation that allows for heightened monitoring of potentially dangerous individuals and allows for zero tolerance policies. Id. These types of policies are valuable against terrorist organizations. Id. By implementing them on a larger scale it would become easier to protect Europe. Id.

(147.) See Paravicini, supra note 5 (arguing importance of utilizing Antimafia policies against Islamic State in Europe). These policies are something that Italy has been developing for many years, which has positioned its government to be better suited to fighting terrorism. Id. Though its implementation of Antimafia laws is not perfect, Italy is still well situated to adapt its policies on a larger scale. Id.

(148.) See The Mafia Effect: Why Italy Has Not Yet Suffered Islamist Terrorism, supra note 38 (describing Italy's vast experience in combating radicalized and violent groups). Italy has a long history with well-organized and well-funded radical organizations. Id. Italy has spent the past decades revolutionizing its law enforcement to combat the Mafia and these policies could be instrumental in continuing the fight against ISIS in Europe. Id.

(149.) See Marone, supra note 5 (illustrating Italy's deportation methods as way of preventing terrorism within country). Italy has enacted a strict policy of deporting potentially dangerous persons prior to any potential threats. Id. Though this comes at a loss of personal liberties, Italy is successful at preventing attacks within its borders. Id.

(150.) See Marone, supra note 5 (showing Italy's use of Antimafia policies against ISIS). Italy learned to use certain surveillance and monitoring techniques against ISIS. Id.

(151.) See Kirchgaessner, supra note 39 (describing importance Italy places on surveillance and intelligence in securing its country). Italy's law enforcement has policies in place that include wiretapping, monitoring internet activity, and strict surveillance of train stations and airports. Id. This gives law enforcement a larger base of knowledge of what is happening in Italy. Id. Law enforcement agents can intercept phone calls, which can then be used in court as evidence. Id. This differs from European countries such as the United Kingdom, where this is not allowed. Id. In Italy, calls related to the Mafia or terrorist activity can be monitored based on suspicious activity, without the need for solid evidence. Id. These kinds of progressive policies are having a direct effect on how terror threats are prosecuted in Italy. Id.

(152.) See Burke, supra note 6 (depicting dangers of prisons for spreading extremists). Often, prisons act as breeding grounds for extremists. Id. In prison, likeminded individuals, who share an animosity towards law enforcement, come together and are recruited into radical groups such as the Mafia and ISIS. Id.

(153.) See Burke, supra note 6 (addressing hopes of further community involvement). There is a strong need for the Italian citizens to voice their opposition to ISIS, however the Italian people have long feared speaking out against the Mafia. Id. The Italian people notoriously follow a code of silence against talking to law enforcement. Id. Much of this comes back to a lack of trust that the Italian people have in their economy. Id. It becomes exceedingly hard to prosecute individuals when the prosecutors are unable to secure witnesses against the criminal organizations. Id. If citizens played a more active role in speaking out and standing as witnesses to the crimes that the Mafia caused, then prosecutors would see more success in bringing down the Mafia. Id.

(154.) See Myers, supra note 72 (expressing need for more unified policies). The European Union allowed for an easier exchange of information, but many countries in the European Union still have different policies and tend to disagree on how to run the European Union. Id. If the European Union wishes to combat organized crime and terrorism, they will have to put egos aside and start to implement joint policies that allow for more shared information and prosecution. Id.

(155.) See Myers, supra note 72 (exploring need to cooperate in order to ensure safety from terrorist threats). The European Union, despite being a joint force, lacks cohesion. Id. This caused issues in dealing with their common enemies, because they cannot even agree on how to handle their problems. Id. See also Techau, supra note 72 (debating Europe's security issues). The European Union lacks confidence. Id. While the European Union spends heavily on domestic security, member countries have withdrawn their spending on unified defense measures. Id. The European Union needs to take some accountability for what is taking place across the globe. Id. The European Union also struggled to keep up its connection with the United States. Id. There is much less information shared between the United States and Europe, which is hurting both parties. Id. Europeans are also struggling with keeping faith in their politicians and support for national security. Id. Finally, European countries are struggling with cohesion between each other. Id. There is almost no trust between the European countries and more times than not it appears that they are competing with one another rather than working together. Id.

(156.) See Techau, supra note 71 (discussing difficulties in cooperating between multiple countries and agencies). Often, it becomes hard for various organizations spanning across multiple boarders to cooperate on a large scale. Id. These organizations get bogged down by varying laws, bureaucracies, and differing opinions on how to handle the situations. Id.

(157.) See Byman, supra note 33 (describing need for expansion to keep up with ISIS's growth). As ISIS continues to expand, so should law enforcement organizations cross borders to follow the Islamic States actions in multiple countries. Id. There is a lack of unity between law enforcement agencies, which makes it harder to follow, apprehend, and prosecute transnational criminal organizations. Id. The more connected these forces become, the easier it will be to detain and prosecute individuals. Id.

(158.) See Byman, supra note 33 (arguing importance of cooperating global law enforcement agencies). There is information sharing between the law enforcement agencies in Europe; however, many times these organizations are still holding back pertinent information from one another. Id. There is a competitive relationship between these groups and despite the costs to society, they still refuse to completely work together. Id. There is a general lack of trust between one another. Id.

(159.) See Byman, supra note 33 (expressing importance of unified front in combating Islamic State). It is essential that governments fight ISIS on not only a micro level, but on a macro level, through cooperation and resource sharing. Id. The more resources that are made available, make this enemy easier to combat. Id.

(160.) See Vigna, supra note 67, at 29-30 (outlining issues in prosecuting individuals in Europe). Italy's interconnected nature makes it easier for criminal organizations to pool resources and hide money across country lines. Id. This web of organizations made it harder to prosecute criminals as they can often cross borders or hide their crimes. Id. There is a general lack of cohesion between European law enforcement causing a lack of trust between one another. Id. They become divided on how to handle these pressing issues and often fail to gain any real traction. Id.

(161.) See Vigna, supra note 67, at 29-30 (expanding on extradition's value to international safety). Extradition is a major resource in cooperating between multiple countries to ensure the proper prosecution of criminals. Id. It is easy to travel from one country to another within the European Union. Id. When a criminal commits a crime and then fleas to another country it often becomes difficult to track them from one country to another. Id. Often, law enforcement is bogged down by jurisdictional issues making it nearly impossible to collect evidence and apprehend suspects. Id. Extradition allows law enforcement to bring criminals back to the country where the crime was originally committed, making it easier for them to be tried in the country that contains many of the witnesses and evidence of the crime. Id.

(162.) See Antimafia Commission 1976, supra note 5 (imputing need for shared policies across multiple countries, especially within European Union). Up until this point, the European Union struggled to follow through with its pooling of information. Id. There are so many different governments and agencies distrusting one another that it is nearly impossible for them all to work together. Id. See also Gilsinan, supra note 73 (arguing limitations and struggles of Interpol). Organizations such as Interpol have had success in collaborating between multiple agencies, however it is only as strong as the organizations from which it is pooling resources. Id. Despite many misconceptions, there are no Interpol officers who are investigating crimes. Id. Interpol is made up of many different local agencies and thus limited by those agencies. Id. This makes it hard for Interpol to be effective against terrorism when it is severely limited by the jurisdictional issues of these crimes. Id. Interpol is not adept at handling these types of crimes which require investigations from multiple local authorities. Id.

(163.) See Threat Assessment: Italian Organized Crime, supra note 16, at 18 (explaining importance of joint financing). With every country facing its own issues, it becomes hard to convince multiple countries to pool their resources and finances with other countries within the European Union. Id. Every country feels that its problems are the most pressing and for there to be any real change, the European Union will need to start seriously trusting one another and working together. Id.

(164.) See Threat Assessment: Italian Organized Crime, supra note 16, at 18 (emphasizing importance of anti-money laundering legislation). Money often travels across borders as it is laundered, making it nearly impossible to trace. Id. With global money laundering policies in place, it becomes easier to follow and prosecute money that travelled across borders. Id. Outside sources usually fund terrorism, but if law enforcement is able to freeze assets or cut off funding, it becomes difficult for these attacks to come to fruition. Id.

(165.) See Threat Assessment: Italian Organized Crime, supra note 16, at 18 (arguing importance of these policies on larger scale). These ideas represent just a few of the policies that could have a positive influence on the fight against organized crime and terrorism. Id. Although it is not an absolute solution, these initiatives represent a step in the right direction. Id.

(166.) See Threat Assessment: Italian Organized Crime, supra note 16, at 18 (finding global cooperation necessary to ensure safety). At the heart of much of Europe's struggles are a lack of trust and confidence. Id. The European Union investigates and discusses interconnectivity between its countries, but it fails to follow through. Id. These countries need to put their egos aside and work together to face a common enemy. Id. There is entirely too much at stake to be hindered by bureaucratic red tape. Id.

(167.) See Vigna, supra note 67, at 29-30 (outlining issues in multiple governments cooperating together). Lack of trust and connectivity in Europe is not a new issue, but is one that needs to be addressed. Id. at 27. With the numerous terror attacks throughout Europe, it has become of utmost importance to work together for a common good. Id. at 29.

(168.) See Vigna, supra note 67, at 29-30 (arguing need for joint operations against criminal organizations). The lack of cohesion and collaboration between European Law Enforcement made it easier for both criminal organizations and terrorist organizations to operate within Europe's borders. Id.

(169.) See Threat Assessment: Italian Organized Crime, supra note 16 (depicting threats to European Union). ISIS grew and transformed from the turmoil left by the War on Terror. Id, Now it has transformed itself into a borderless global organization executing terrorist plots across the world. Id.

(170.) See Organised Crime in Europe, supra note 1, at 226-29 (describing importance of state-building in limiting growth of radicalism within its country). Radicalism feeds off broken states and failing governments. Id. at 229-230. When citizens are not being provided the necessary services from their government, they often gain anti-government sentiments that may lead them to be more likely to adhere to radicalized thinking. Id.

(171.) See Organised Crime in Europe, supra note 1, at 229-30 (arguing necessity of state-building in preventing future issues). Future safety relies heavily on the ability to prevent these types of uprisings from happening again. Id.

(172.) See Organised Crime in Europe, supra note 1, at 229-30 (cautioning need for strengthened states). State building is an essential step in preventing further radicalized thinking and organizations. Id. By providing support to youth and creating jobs the government can effectively help deter the spread of radicalized thinking. Id.

(173.) See Organised Crime in Europe, supra note 1, at 229-30 (expressing need for larger government accountability in suppressing radical behaviors in Italy and Middle East). Through widespread cooperation and resource sharing governments can take a united front against ISIS and the Mafia. Id.

(174.) See supra Part IV.C (describing need for unification of Antimafia laws in Europe). By enacting unified legislation the European Union will help eliminate much of the red tape that currently allows terrorist organizations to slip through boarders. Id.

(175.) See supra notes 46-47 and accompanying text (cautioning Mafia's relationship with ISIS). The Mafia's partnership with ISIS opened the door to allow ISIS to extend its reach further into Europe. Id. Further measures are needed to protect and prevent this crisis from escalating. Id.

(176.) See supra Part IV.C.l (warning of potential controversy around unified Antimafia laws). There may be some resistance to the implementation of these policies, but they are a necessary step to ensure national security. Id.

(177.) See Paravicini, supra note 5 (weighing balance of laws for national security). The implementation of this form of legislation would require much collaboration and time, but remains a necessary step in combating ISIS and the Mafia. Id.

(178.) See Burke, supra note 6 (detailing need for tactics to fight ISIS). Unification, collaboration, and state building are the only means of addressing this crisis head-on. Id.
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Author:Ball, Alexander
Publication:Suffolk Transnational Law Review
Date:Jan 1, 2019
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