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THE COST OF TERROR: HOW TERRORISM AND ANTI-TERROR LEGISLATION IN THE EUROPEAN UNION MAY HINDER BUSINESS.

I. INTRODUCTION

Democracy and the values it represents is a frequent target of extremist terrorist groups. (1) Terrorism occurs regularly throughout the world regardless of the underlying motivations, but the attacks on the World Trade Center in New York on September 11, 2001 (September 11th), brought greater attention to its looming presence. (2) Subsequently, European governments took preventative measures to limit attacks in their own countries. (3) The prevalence of terrorism on European soil in recent years has prompted countries to consider enacting laws that strengthen the government's authority and tighten immigration policies. (4) Businesses can be severely affected by terror attacks; however, they are also in danger of being stifled by these new laws. (5) The European Union functions as a unit and corporations and small businesses alike located within its Member States will need to adapt in order to sustain the economic interests of the European Union as well as those in their individual countries. (6)

This Note examines proposed legislation regarding stronger governmental control and immigration in France, Germany, and the United Kingdom aimed at preventing terrorism in their respective countries. (7) It further explores how these laws may affect businesses and the economy within each country. (8) Part II will discuss legislation enacted as a result of the attack on September 11th and previous legislation enacted in an attempt to strengthen government authority, streamline immigration, and the overall effects on multination corporations and small businesses. (9) Part III of this Note will examine recent terror attacks in the United Kingdom, Germany, and France and the resulting legislation proposed and enacted. (10) Part IV will analyze the potential effect regulations may have on various types of businesses within each respective country and the overall effects on the E.U. economy. (11) Finally, Part V will conclude by stressing that while stronger laws to prevent terrorism are justified, European countries should be wary of implementing harsh restrictions, as it may ultimately hurt the economies of each country. (12)

II. HISTORY

A. Government Intervention and Restrictions and Their Effects on the Economy

1. The Nuremberg Laws

Governments frequently attempt to pass laws strengthening their power; however, these laws have not always proven to be in the best interest of the citizens or the country. (13) For example, in September 1935, the Nazi party instituted the Nuremberg Laws in Germany, which precluded those of Jewish descent from retaining German citizenship. (14) The laws also restricted the Jewish from voting in German elections and holding certain positions of employment. (15) Jewish participation in the economy was severely limited as their businesses were seized and they were unwelcome in most stores. (16) As Adolph Hitler's regime persisted, the rights of the Jewish people within Germany continued to dwindle. (17)

Prior to the creation of the Nuremberg laws, the Nazis called for a boycott of Jewish businesses. (18) The boycott, combined with the newly enacted laws and the Nazis' increasing power in Germany, left the Jewish people personally and economically destroyed. (19) Hitler and the Nazis felt that those of Jewish heritage were hurting their country and took drastic steps to protect it from perceived, albeit nonexistent, harm. (20) The Nazis' rise to power eventually led to World War II, which left the German economy in shambles. (21)

2. Japanese Internment

The Jewish people in Germany were not the only group marginalized during World War II. (22) In the United States, the government became suspicious of the Japanese following the bombing of Pearl Harbor. (23) As a result, President Franklin D. Roosevelt signed an executive order that authorized certain areas to be deemed military zones and thus allowed Japanese and Japanese descendants to be removed. (24) The relocation was explained as a precaution for both the safety of the Japanese from those who may not trust them and for the safety of the United States. (25) While the removal and internment of the Japanese was not as harsh as what the Jewish experienced in Germany, the Japanese still had their lives uprooted and much of their property taken away. (26)

After the war, when the Japanese were allowed to return to their homes, many were not welcomed back to their jobs working on farms. (27) American farmers frequently purchased Japanese-Americans' land for mere cents on the dollar, leaving little for Japanese-Americans to return to, after internment. (28) While the farmers benefitted from acquiring the land, without the Japanese-Americans, they were often left with a shortage of workers to assist in managing their crops. (29) Additionally, the agricultural market in the United States was negatively affected because many crops were largely or exclusively produced by those now confined away from their farms. (30) The average earnings of those displaced were dramatically reduced and often unrecoverable. (31)

President Roosevelt issued an executive order he felt necessary at the time to protect the country. (32) While the United States Supreme Court held the order was constitutional, many felt the Japanese and Japanese-Americans were unfairly targeted. (33) It cannot be disputed however, that a large portion of the Japanese-American population had their lives forever altered as a result of the United States' rash decisions following Pearl Harbor. (34)

B. Legislation Enacted as a Result of the September 11, 2001 World Trade Center Attack

1. Counter-Terrorism in Europe

The world expressed solidarity with the United States after the September 11th attacks and began a process to strengthen anti-terrorism laws. (35) Unlike many of its Member States that have had terror laws in place for years, the European Union itself did not have any substantial counter-terrorism legislation. (36) To begin to rectify that, in 2002, the European Union adopted the Framework Decision Combating Terrorism (Framework Decision), which gave a more concrete definition to terrorism and outlined steps Member States may take prosecuting terrorists. (37) The Framework Decision also directed E.U. Member States to implement "necessary measures" to comply with the provisions outlined within six months of its publication. (38) In addition to the European Union's actions, the United Nations sought to impose sanctions on those who were associated with Osama Bin Laden or the Taliban under Chapter VII of the United Nations Charter. (39)

In 2005, the European Union adopted a comprehensive counterterrorism strategy, which covered four main areas: prevention, protection, pursuance, and response. (40) Its strategic commitment was "to combat terrorism globally while respecting human rights, and make Europe safer, allowing its citizens to live in an area of freedom, security and justice." (41) With the action plan in place, the European Union was able to pass legislation and initiatives in furtherance of their strategic commitment. (42)

Those countries that already had anti-terrorism laws in place sought to bolster their policies and legislation, many specifically regarding criminal prosecution and security. (43) Germany amended their Penal Code to include provisions regarding the formation of terrorist organizations. (44) The United Kingdom enacted the Anti-Terrorism, Crime and Security Act in late 2001, which provided additional provisions to the Terrorism Act of 2000. (45) The provisions included topics such as terrorism and security, immigration and asylum, and freezing assets, among others. (46) While criticized by some as potentially harmful to human rights, the main goal was to substantially increase security in light of the World Trade Center attack. (47)

2. Terrorism Risk Insurance

Terrorism is impossible to predict and, as such, businesses had trouble determining the cost and obtaining insurance to protect themselves following the September 11th attacks. (48) In late 2002, the United States Congress enacted the Terrorism Risk Insurance Act (TRIA). (49) TRIA allowed businesses to obtain terrorism insurance by requiring insurance companies to offer policies that included terrorism coverage. (50) As there appears to be no end to terrorism in sight, TRIA was extended in 2005 and the program was reauthorized in 2015. (51)

TRIA benefits only apply when a terror attack takes place within a U.S. territory. (52) Accordingly, European countries enacted their own programs. (53) France established the "Gestion de l'Assurance et de la Reassurance des risques Attentats et actes de Terrorisme" (GAREAT) in January 2002, while Germany enacted Extremus Versicherungs-AG in September 2002. (54) Generally, most terrorism insurance focuses on property damage rather than internal issues businesses may face resulting from terror attack. (55) As the world experiences increased terror risks, the nature of terror insurance has begun to adapt. (56) A terror event's categorization is critical in determining coverage because those events not classified as terrorisms will not be eligible for benefits. (57)

C. Effects and Challenges of Terrorism on Business

1. Corporate Industries

a. Financial Sector

Financial markets and institutions are often a target of terrorism because many regard them as "extensions of Western economic power and dominance." (58) The financial sector felt an immediate impact following September 11th. (59) In addition to market closure, financial companies had to adjust to dwindling foreign direct investments due to low investor confidence. (60) Despite these challenges, financial institutions have demonstrated the ability to bounce back from the effects of terror attacks. (61) Continued attacks, however, may have a detrimental effect on the global economy if confidence does not return and markets are unable to recover. (62)

b. Tourism Industry

Many countries rely on the tourism industry as a main contributor to their economies and terror attacks can have a damaging effect on tourism, as consumers are hesitant to travel to an area deemed unsafe. (63) Hotel bookings, airlines and major shopping areas tend to see a decline immediately following an attack. (64) Much like the financial industry, however, tourism will usually increase again, although the severity and frequency of attacks plays a role in how quickly tourism will increase again. (65)

c. Large Corporations

Multinational corporations can be impacted in a more internal manner than the external nature affecting financial markets and the tourism industry. (66) While a consumer's decision to buy products is a factor, companies must also deal with the indirect effects of terrorism. (67) Large companies with global offices must be cognizant of security for their various locations and the employees within. (68) They also must consider insuring their businesses in case of a terror attack. (69)

Additionally, companies are forced to monitor the political climate where their products are manufactured and consider how their global supply chain may be affected by terrorism. (70) If the supply chain is disrupted, not only will the company itself be affected, so will consumers and global trade. (71) Lastly, global corporations face the possibility of being victimized by cyberattacks. (72) The rapid growth of technology and global business dealings makes these attacks an inviting option for terrorists. (73)

2. Small European Based Corporations

Small and medium sized enterprises (SMEs) are a major part of many European economies. (74) As such, it may be even more important for Europe to protect their operations than those of multinational corporations. (75) Many SMEs do not yet have terrorism insurance and cannot properly protect themselves. (76) It is much harder for SMEs to deal with the negative effects of terrorism because they lack the resources and money of larger corporations. (77) Smaller, localized businesses are more likely to operate in rural areas than corporations and these areas are increasingly vulnerable to terrorist attacks. (78) Europe has enacted legislation and provided ample information to help ensure their wellbeing. (79)

Even with legislation in place to help them grow, SMEs can be affected by existing restrictions that subject them to greater regulations. (80) SMEs often facilitate trade both domestically and internationally and potential restrictions could limit these opportunities. (81) While many countries can be nationalistic, numerous local businesses are run by migrants or rely on foreign workers, making relationships with other countries key. (82)

III. FACTS

A. Recent Terror Attacks in Europe

1. United Kingdom

Since September 11th, there have been numerous and frequent terror attacks in Europe. (83) One of the first major incidents after September 11th took place in London in 2005. (84) Four men detonated explosive devices, three of which were in underground tube stations. (85) In total, there were fifty-two people killed and over 700 injured. (86) Several men were arrested in connection with the bombing in 2007, and were charged with "unlawfully and maliciously conspiring with the four suicide bombers and of conspiring to cause explosions at tourist attractions in London." (87)

More recently, there was an attack in London at the Leytonstone Tube Station in December 2015. (88) Several people were stabbed while a man shouted, "[t]his is for Syria." (89) During the attack, the suspect attempted to behead a train passenger. (90) The incident was isolated, but officials warned citizens to be vigilant. (91) In 2017, England experienced an increase in terror incidents, including an attack on the London Bridge and a suicide bombing outside of a Manchester concert arena that killed twenty-two. (92)

2. Germany

Germany also experienced a surge of terror attacks in recent years. (93) In July 2016, an assailant used an axe to attack several passengers aboard a train in Wurzburg, Germany. (94) The attacker had arrived in Germany through asylum. (95) That same week, a suicide bomber attacked a popular music festival in Ansbach. (96) The bombing injured fifteen on the final day of the festival. (97)

In December 2016, a truck was driven intentionally through a Christmas market in Berlin, killing twelve and injuring several dozen. (98) The suspect had connections with ISIS and subsequently escaped to Italy, where he was later killed. (99) Each of these incidents has raised fears of additional attacks in Germany. (100)

3. France

For several years, terror attacks have appeared to be the most frequent in France. (101) Since late 2015, there have been three major attacks in Paris and its surrounding cities, with various smaller attacks also taking place. (102) One of the more notable attacks took place in January 2015, against satirical newspaper, Charlie Hebdo. (103) Gunmen attacked the paper's offices, killing nearly all the staff, because of its depiction of the Prophet Muhammad. (104)

In November 2015, several coordinated attacks took place throughout Paris, killing a total of 130 people. (105) A concert venue known as Bataclan saw the brunt of the attack, with gunmen taking hostages and killing ninety people inside. (106) On July 14, 2016, Bastille Day, a truck drove through a celebrating crowd, killing eighty-four. (107) It has been theorized that France has experienced this high volume of attacks, in part, because immigrants feel marginalized and the rise of the political power of the right wing. (108)

B. Proposed Regulations Regarding Immigrants and Stronger Government Authority

1. United Kingdom

As a result of the increased terror attacks throughout Europe, many countries have sought to enact even tougher laws. (109) The United Kingdom passed the Counter-Terrorism and Security Act in 2015, which enabled the seizure of passports from suspected terrorists. (110) These laws were put in place to further protect the borders and keep terrorists out. (111) In response to the London Bridge attack, British Prime Minister Theresa May indicated she plans to implement additional measures, including altering human rights laws, if she deems it necessary. (112)

While perhaps not directly related to terrorism, in June 2016, the United Kingdom voted to leave the European Union, a process known as Brexit. (113) One of the central aspects of the Brexit leave campaign was to curb immigration in an attempt to protect the United Kingdom. (114) Supporters of leaving the European Union were concerned about protecting cultural identity and regulating the flow of immigrants. (115) The beginning stages of Brexit were officially triggered on March 29, 2017, but as of this Note's writing, it is still too early to determine how leaving the European Union will affect both the United Kingdom's economy and its safety from terror attacks. (116) Some speculate leaving the European Union may be detrimental to both areas of concerns. (117) Additionally, in response to Brexit, other E.U. Member States have discussed proposing similar referendums, which have the potential to create even more concerns for the European Union. (118)

2. Germany

In reaction to attacks on its own soil and the rest of Europe, Germany also began to strengthen its anti-terror laws; although, German courts have struck down some laws. (119) Updates were again made to the Penal Code that place restrictions on financing terrorism. (120) In August 2016, Germany's Interior Minister, Thomas de Maiziere, indicated that Germany planned to implement additional laws, including removing migrants from Germany who endangered safety, increasing surveillance, and revoking German citizenship from those who fight with militant groups and are dual nationals. (121)

In addition to tighter anti-terrorism laws, Germany has seen the rise of anti-immigration groups such as the Patriotic European Against Islamisation of the West (PEGIDA). (122) PEGIDA holds weekly rallies to protest the influx of immigrants in Germany, insisting that they "do not want to become strangers in their own country." (123) The Alternative for Germany party (AfD), often confused with PEGIDA because of their similar views, gained momentum when they won seats in the 2017 German election. (124) Additionally, in response to Germany's open border policy, there have been calls to limit the Schengen Agreement, which enables free movement of E.U. citizens between Member States. (125)

3. France

France has experienced some the worst of recent terror attacks and as such, many have called for stronger anti-terrorism laws. (126) Following the uncertainty of France's safety after the attacks, the French Parliament allowed an extension to the country's state of emergency. (127) French authorities were also given broader surveillance powers. (128) These laws were implemented to strengthen security and to try to keep out any suspected terrorists. (129) Some feel, however, that civil liberties may be in jeopardy if France pushes any further. (130) With the potential for more terror attacks on the horizon, it does not appear that France will soon curtail any of these measures. (131)

IV. ANALYSIS

A. Looking to the Past to Predict the Future

1. Balancing Safety Versus Power

With no end to terror attacks in sight, countries must continue to take necessary steps to protect their citizens, however, they must be careful to avoid restricting too many civil liberties. (132) Human rights groups are keeping a close eye on any new legislation passed. (133) Although stronger criminal penalties for terrorists seem reasonable, greater involvement of the government in civilian's lives may prove to be an issue. (134)

The Nuremberg Laws established by the Nazis and Japanese internment camps in the United States are extreme examples, but the lessons they provided should not be overlooked. (135) In each instance, although not to the same level of extremity, each group was placed in horrific situations as nationalism rose and the government attempted to protect its country. (136) The results not only devastated each group's population, but also damaged their economic futures. (137) Governments must protect their countries; however, they should be wary of targeting particular groups while doing so, as it has the potential to have the same lasting effect that the Jewish people and the Japanese Americans experienced. (138)

2. Implementing New Procedures in Business

The extent business and economies will be affected by terror attacks and related legislation is uncertain. (139) Businesses, both large and small, will need to closely examine anti-terror legislation and proactively plan for any changes it may require. (140) Large corporations should look to ways in which they can offset costs associated with greater security and a potentially limited work force, such as relocating offices to areas with less potential for terror attacks. (141) SMEs should continue to push for innovation and use existing laws to their benefit by utilizing groups such as the European Association of Craft, Small and Medium Sized Enterprises. (142) If possible, they should attempt to persuade the governments to keep legal migration policies in place. (143)

3. The Future of the European Union and Its Single Market

The United Kingdom's exit from the European Union may be used as a template for other countries to follow. (144) If successful, the possibility of more countries leaving the European Union grows. (145) Losing large economic powers such as France and Germany, in addition to the United Kingdom, would severely alter the European Union's organization. (146) The single market structure relies on each country's contribution. (147) Trade deals would need to be negotiated separately and terms could potentially be more favorable to one country over another. (148)

B. New Challenges from the Same Threats

1. Tourism and Financial Sector

Terrorism and related legislation have the potential to have a lasting effect on a wide variety of industries in Europe as confidence and stability are keys to both the financial and tourism industries. (149) Consistent terror attacks coupled with stronger laws may limit travelers' desire to visit these countries. (150) While tourism has traditionally only been moderately affected following a terror attack, sustained attacks in the same country, such as those in France, may do greater damage. (151) It is doubtful tourists will want to take the risk of intentionally putting themselves in harm's way, especially in those countries that give police and the government an abundance of power limiting tourists' rights while within their countries. (152)

The financial markets could see a decline resulting from stricter anti-terror laws as well. (153) Investors tend to be hesitant to invest in areas of instability, whether it is due to attack or the political climate of the country. (154) Markets in other countries can be affected by an attack that takes place outside their own borders, as was seen with Norway's slow stock market recovery after the September 11th attack. (155) The uncertainty of frequent terror attacks and stricter laws could prove to be too large a gamble for investors and thus hurt economies. (156)

2. Large Corporations

The full extent multinational corporations will be affected by continued terror attacks and related legislations remains to be seen, as businesses are still learning to adapt in the changing terrorism landscape. (157) They will likely experience additional costs related to security measures as attacks become more varied and unpredictable. (158) Terrorism insurance will be vital to those companies with locations throughout the world. (159) If insurance companies do not categorize an attack as terrorism, corporations will need to offset the direct and indirect costs themselves. (160) Their ability to focus operations in alternate locations allows for more leeway than smaller companies have to continue production and sustain profit. (161)

Limits to immigration could impair multinational corporations. (162) Many citizens of the European Union live and work outside their native country. (163) Brexit's limits to worker mobility will hurt both companies based in the United Kingdom, as well as those who employ citizens of the United Kingdom. (164)

3. SMEs

SMEs will likely suffer a harsher fate than their larger counterparts with proposed new anti-terror laws, because their ability to offset costs and handle challenges is much smaller. (165) Limited immigration, either through an altered Schengen Agreement or as a result of Brexit, will affect SMEs to a greater degree. (166) The free flow of people not only helps to create and sustain businesses, but also provides a market for products to be sold. (167) By no means should there be unmonitored travel between countries, but placing too great a burden on movement may affect SMEs' sustainability and stifle development, and as a result, the European economy. (168)

The structure of the United Kingdom's new trade agreements following its exit from the European Union also has the capacity to affect SMEs. (169) Labor forces could potentially be limited and importing or exporting goods could become more difficult. (170) The new laws may counter-act those existing laws aimed at growing SMEs throughout Europe. (171)

V. CONCLUSION

The world has undoubtedly changed since September 11th. (172) Terror attacks have become more frequent and countries are doing all they can to prevent further attacks. (173) Governments must walk a fine line when enacting anti-terror laws in order to prevent restricting human rights and potentially damaging their economies and the businesses within. (174) Some disruption to business and the economy is inevitable, but governments should examine legislation closely and attempt to both ensure the safety of their country and protect their economies. (175)

(1.) See Celestine Bohlen, Why Do Terrorists Target Democracies, N.Y. Times (Sept. 15, 2015), http://www.nytimes.com/2015/09/15/world/why-do-terrorists-targetdemocracies .html (discussing reasoning behind terrorist attacks on democratic societies). There are varying theories as to why terrorists attack western counties, among them, religion and politics. Id. Democracy itself may not be the target of terrorism; rather, countries that have democratic societies make it easier for the free flow of ideas, making the spread of terrorism easier. Id. See also Steven Charles Nemeth, A Rational Explanation of Terrorist Targeting 30 (July 2010) (unpublished Ph.D. dissertation, The University of Iowa) (indicating terrorists often choose targets for symbolic reasons); James M. Lutz & Brenda J. Lutz, Democracy and Terrorism, 4 Terrorism Research Initiative 1 (researching link between democracy and terrorism). While there is no concrete link that can be found indicating that a higher amount of democratic societies are affected by terrorism, but there is no doubt a strong connection. See supra Lutz. See generally Declaration of Independence (U.S. 1776) (indicating rights of American citizens). The Declaration of Independence states "[w]e hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness." Id. at para. 2. 1958 Const. Art. 2 (Fr.) (setting out motto of French nation). France's motto is "Liberte, Egalite, Fraternite," which translates to liberty, equality, fraternity. Id.

(2.) See 18 U.S.C. [section] 2331 (1992) (defining international and domestic terrorism in United States); Walter Laquer, History of Terrorism (2001) (chronicling acts of terror throughout history). Terrorism is found in many parts of the world and recently urban terrorism has become very frequent. Id. at 175. Urban terrorism can be broken down into three main categories, separatist, nationalist terrorism, Latin American terrorism and urban terrorism that grew out of the New Left. Id. See Kent Roach, The 9/11 Effect: Comparative Counter-Terrorism (2011) (discussing various countries' responses to September 11, 2001 (September 11th)); Nemeth, supra note 1 at 5 (stating terrorism has been around in some form for centuries); John Moore, The Evolution of Islamic Terrorism, Frontline, http:// www.pbs.org/wgbh/pages/frontline/ shows/target/etc/modern.html (listing Islamic terror attacks leading to September 11th). The roots of "modern terrorism" date back to the 1960s. Moore, supra.

(3.) See Strafgesetzbuches (StGB) (Penal Code) 8 129a translation at https:// www.gesetze-im-internet.de/englisch_stgb/englisch_stgb.html (Ger.) (codifying revisions to terrorism definitions after World Trade Center attack); Frank Foley, Countering Terrorism in Britain and France? Institutions, Norms and the Shadow of the Past 208 (2013) (describing France's and Britain's reaction to terror attacks in United States). The British passed Part IV powers, which allowed "detention without trial of foreign nationals whom intelligence indicated were a threat to national security." Foley, supra, at 265. See Frederic Simon, From 9/11 to Charlie Hebdo: The EU's response to Terrorism, EurActiv (Jan. 14, 2015) https://www.eurac tiv.com/section/justice-home-affairs/linksdossier/from-9-ll-to-charlie-hebdo-the-eu-sresponse-to-terrorism/ (providing details about European Union anti-terror initiatives after September 11th). Beginning in 2001, the European Union began to implement counter-terrorism measures. Id. After subsequent attacks in London and Madrid, additional steps were taken in an attempt to prevent future attacks. Id.

(4.) See Aurelien Breeden, French Authorities Given Broader Powers to Fight Terrorism, N.Y. Times (May 26, 2016), http://www.nytimes.com/2016/05/26/world/europe/ france-terrorism-laws.html (explaining new powers French Parliament passed to combat terror). One of the newly passed police powers allows the government to detain someone who was involved in a "terrorist theater of operation" to be put under house arrest for a month. Id. See also Stephanie Kirchner, Germany Calls for New Security Measures After String of Terrorist Attacks, The Wash. Post (Aug. 11, 2016), https:// www. Washington post.com/world/germany-calls-for-new-security-measures-afterstring-of-attacks/2016/08/1 l/f5982b49-45e3-4978-92al-dd6f6al3b04a_story.html (discussing new German proposals to halt terrorism). The German Interior Minister planned to improve "cybersecurity, increase security personnel and provide police with better equipment." Id.

(5.) See Michael D. Larobina & Richard L. Pate, The Impact of Terrorism on Business, 3 J. of Global Bus. Iss. 1 (2009) (explaining how various industries are impacted by terror). See also Joe Myers, What is the Economic Impact of Terrorism, World Econ. Forum (Nov. 19, 2015), https://www.weforum.org/agenda/2015/11/ what-is-the-economic-impact-of-terrorism/ (detailing economic costs of terror attacks). In 2014, the global cost of terrorism totaled USD 52.9 billion. Id. See Elvis Picardo, Don't Hide From The Reality Of How Terrorism Affects The Economy, Investopedia (Mar. 24, 2016), http://www.investopedia.com/articles/investing/030215/ how-terrorism-affects-markets-and-economy.asp (indicating terror attacks can have lasting effect on economy); Sean Ross, Top 5 Ways Terrorism Impacts the Economy, Investopedia (Aug. 21, 2016), http://www.investopedia.com/articles/markets/080216/ top-5-ways-terrorism-impacts-economy.asp (listing ways terrorism can affect economy); Global Terrorism Index 2015, Measuring and Understanding the Impact of Terrorism, Institute for Economics and Peace 61 (2015) (linking economic growth to terrorism). See generally Sari Pekkala Kerr & William R. Kerr, Economic Impacts of Immigration: A Survey (Harvard Business School) (examining how immigration can aid in economic growth).

(6.) See The Economy, Europa, https://europa.eu/european-union/about-eu/fi gures/economy_en (last visited Sept. 23, 2016) (explaining how European Union members act as single market). The European Union is made up of twenty-eight countries that work together as a single market economy. Id. It plays a large part in international trade as one of the top three global markets. Id. See generally The EU and Small Businesses, EuroNet, http://www.erionet.org (last visited Sept. 23, 2016) (detailing European Union's role in supporting small businesses). See generally Council Directive 2004/38/EC of the Eur. Pari, and of the Council 29 April, 2004 on the right of citizens of the Union and their family members to move and reside freely within the territory of the Member States amending Regulation (EEC) No 1612/68 and repealing Directives 64/221/EEC, 68/360/EEC, 72/194/EEC, 73/148/EEC, 75/34/ EEC, 75/35/EEC, 90/364/EEC, 90/365/EEC and 93/96/EEC (conditioning movement of European Union citizens in Member States).

(7.) See infra Parts II-V (supporting information regarding anti-terrorism legislation in European Union).

(8.) See infra Parts II-V (analyzing effect of legislation on business community in Europe).

(9.) See infra Part II (detailing history of anti-terror laws and their effects).

(10.) See infra Part III (examining effects of recent terrorism and how countries have reacted).

(11.) See infra Part IV (discussing legislative effects on corporations and small businesses).

(12.) See infra Part V (concluding economic affects if laws imposed).

(13.) See Tanya Lokshina, Draconian Law Rammed Through Russian Parliament: Outrageous Provisions to Curb Speech, Privacy, Freedom of Conscience, Human Rights Watch (Jul. 7, 2016), https://www.hrw.org/news/2016/06/23/draconian-lawrammed-through-russian-parliament (examining Russian law implemented curbing privacy and speech rights to protect country from terrorists). The bill that was initially proposed stripped Russians of their citizenship if it was found that they served for a foreign national army, although this was subsequently removed from the bill by lawmakers. Id. Additional provisions included "[Requiring cellular and Internet providers to store all communications data in full for six months ... [m]aking cryptographic backdoors mandatory in all messaging applications...." Id. See Emre Peker, Turkey Passes Touch New Security Law, Wall St. J. (Mar. 27, 2015), http:// www.wsj.com/articles/turkey-passes-tough-new-security-law-1427448854?mg=ID-wsj (enacting law giving police stronger powers to detain without authorization). The law gives the Turkish police a broad range of powers, including, "authority to fire live rounds on protesters if attached by Molotov cocktails or other weapons" and "let[ting] police search and detain people without judicial authorization." Id. See generally Antonios Loizides, Draco's Law Code, Ancient History Encyclopedia (June 12, 2015), http://www.ancient.eu/Dracos_Law_Code/ (explaining Draco's severe law code in Ancient Greece). Draconian laws were seen as "intolerably harsh" and usually benefitted the aristocracy. Id. Small crimes were often given disproportional punishments, including death. Id.

(14.) See Greg Bradsher, The Nuremberg Laws, Prologue Magazine (Winter 2010, Vol. 42, No. 4), https://www.archives.gov/publications/prologue/2010/winter/nu remberg.html (detailing original laws found in archives). The Nuremberg Laws were seen as a "cornerstone of the legalized persecution of Jews in Germany." Id. The Nazis stripped the Jewish people of many of their rights, including the ability to hold public office, employment in a wide range of industries and the ability to partake in the stock exchange. Id. See also The Reich Citizenship Law, German History in Documents and Images (Sept. 15, 1935) http://germanhistorydocs.ghi-dc.org/sub_docu ment.cfm?document_id=1523 (last visited Jan. 5, 2018) [hereinafter Reich Citizenship Law] (dictating discriminatory laws against those of Jewish decent). The law described the various degrees of Jewish ancestry and how each would affect rights as a German citizen. Id. Jewish businesses were targets and the subject of intense harassment. Id. See also The Holocaust Encyclopedia, Nuremberg Race Laws: Translation, USHMM, https://www.ushmm.org/wlc/en/article.php?ModuleId=10007903 (last visited Jan. 5, 2018) (translating German laws).

(15.) See Reich Citizenship Law, supra note 14 (restricting political and economic rights of Jewish people). The laws indicated "[a] Jew cannot be a citizen of the Reich. He has no right to vote in political affairs, he cannot occupy a public office." Id. See also This Day in History, Nuremberg Race Laws Imposed, History Channel, http:// www.history.com/this-day-in-history/nuremberg-race-laws-imposed (last visited Oct. 17, 2016) (describing occupations Jewish citizens were banned from holding). Jobs restricted from Jewish participation included everything "from public office to journalism, radio, theater, film, and teaching-even farming." Id.

(16.) See Sheila Solhtalab, The Representation of the Economic Persecution of German Jews in The New York Times, 1933-1938 (May 2011) (unpublished Masters dissertation, University of Toledo) at 21 http://utdr.utoledo.edu/cgi/viewcontent.cgi ?article=1746&context=theses-dissertations (explaining effect of boycott on Jewish business). The Nazis began planting seeds of doubt years prior to the boycott, leading to attacks on shop owners. Id. at 24. See also Karel Janicek, Jewish Groups Struggle to Regain Nazi-seized Property, The Times of Israel (Nov. 29, 2012), http://www. timesofisrael.com/jewish-groups-struggle-to-regain-nazi-seized-property/ (detailing difficultly of regaining Holocaust victim's stolen property). Even today, those of Jewish heritage are attempting to take back factories and other real estate that was seized by the Nazis. Id. The relatives of Holocaust victims face many obstacles in reclaiming what their relatives lost as a result of the Nuremburg Laws and the Holocaust. Id.

(17.) See Timeline of Events, The United States Holocaust Memorial Museum, https://www.ushmm.org/learn/timeline-of-events/1933-1938 (last visited Dec. 29, 2017) (chronicling Nazis' rise to power and effects on Germany). Beginning in 1933, the Nazi party took over Germany, which culminated in the Holocaust and World War II. Id. In the beginning of Hitler's reign, "German Jews felt the effects of more than 400 decrees and regulations that restricted all aspects of their public and private lives." Id.

(18.) See Marion A. Kaplan, Between Dignity and Despair: Jewish Life in Nazi Germany (Oxford Univ. Press 1999) (describing Nazis decision to boycott German business). Many Jewish people attempted to the resist the boycott by keeping their stores open. Id. at 22. See Solhtalab, supra note 16, at 20 (explaining goals of Nazis' boycott).

(19.) See Kaplan, supra note 18, at 37 (detailing reaction of neighborhoods to Jewish). Hitler's Youth often marched through the Jewish neighborhood. Id. They would throw stones and attack men, women and children. Id. Solhtalab, supra note 16, at 40 (stating economic future of Jewish people was "serious concern"); George Arnett, Auschwitz: A short history of the Largest Mass Murder Site in Human History, The Guardian (Jan. 27, 2015), https://www.theguardian.com/world/2015/jan/27/au schwitz-short-history-liberation-concentration-camp-holocaust (chronicling horror of Auschwitz concentration camp).

(20.) See Nazi Party, History Channel http://www.history.com/topics/world-warii/nazi-party (last visited Oct. 19, 2016) (examining origins of Hitler and Nazis). The Nazi party was created out of nationalism "and the concept of an Aryan 'master race.'" Id.

(21.) See Richard Reichel, Germany's Postwar Growth: Economic Miracle or Reconstruction Boom?, Cato Journal, Vol. 21, No. 3 (Winter 2002) available at http:// object.cato.org/sites/cato.org/files/serials/files/cato-journal/2002/1/cj21n3-5.pdf (analyzing growth of German economy post-war). See Bruce Bartlett, How the Revival of Postwar Germany Began, N.Y. Times (Jun. 18, 2013), available at http://economix. blogs.nytimes.com/2013/06/18/the-revival-of-postwar-germany-began-65-years-ago/?_ r=0 (discussing steps taken to revive German economy). At the end of the war, the German economy was a "basket-case." Id. See also The Holocaust Encyclopedia, supra note 14 (detailing timeline of events leading to World War II); Nazi Party, supra note 20 (documenting Hitler and Nazis' rise to power).

(22.) See Julie Des Jardin, From Citizen to Enemy: The Tragedy of Japanese Internment, The Gilder Lerham Institute of American History, https://www.gilder lehrman.org/history-by-era/world-war-ii/essays/from-citizen-enemy-tragedy-japaneseinternment, (last visited Oct. 19, 2016) (explaining process by which U.S. citizens forced to relocate out of fear). The relocation caused great strife within Japanese American families. Id.

(23.) See Des Jardin, supra note 22 (detailing steps taken by government following Pearl Harbor attack); Taunya Lovell Banks, Symposium--Legal Outsiders in America File: Outsider Citizens: Film Narratives About Internment of Japanese Americans, 42 Suffolk U.L. Rev 769 (describing film depicting distrust of Japanese following bombing). The loyalty of the Japanese living in America was questioned following the attack. Banks, supra. See supra Banks at 769. See generally Pearl Harbor, The History Channel http://www.history.com/topics/ world-war-ii/pearl-harbor, (last visited Jan. 3, 2018) (chronicling events of Pearl harbor bombing in 1941). The Japanese bombed the naval base Pearl Harbor, located in Hawaii, destroying American ships and planes. Id. The American casualties totaled over 2,400 and approximately 1,000 people were wounded in the attack. Id.

(24.) See Office of the President, Executive Order No. 9066: Resulting in the Relocation of Japanese (1942), Ourdocuments.gov (last visited Oct. 19, 2016) https://ourdocuments.gov/doc.php?flash=true&doc=74 (showing copy of Executive Order 9066 President Roosevelt signed). The army assisted with the relocation because constitutional issues were raised. Id. See also This Day in History: Roosevelt signs Executive Order 9066, Thf. History Channel http://www.history.com/this-dayin-history/roosevelt-signs-executive- order-9066, (last visited Jan. 6, 2018) (explaining Executive Order 9066). The Executive Order allowed the military to declare the western coast of the United States a military zone. Id. Approximately six months after Pearl Harbor, over 110,000 Japanese Americans were moved to internment camps. Id.

(25.) See National Archives, Japanese Relocation During World War II, https:// www.archives.gov/education/lessons/japanese-relocation (last visited Oct. 17, 2016) (indicating reasons for relocation). There was a national security fear on the Western coast of the United Stated after the bombing of Pearl Harbor. Id. "The objectives of the order were to prevent espionage and to protect persons of Japanese descent from harm at the hands of Americans who had strong anti-Japanese attitudes." Id. See also Des Jardin, supra note 22 (noting government said relocation was for safety); Sandhya Ramadas, How Earl Warren Previewed Today's Civil Liberties Debate--And Got it Right in the End, 16 Asian Am. L.J. 73, 77 (2009) (detailing high suspicion level in California). The public was generally suspicious of the Japanese Americans living in California and feared what may happen following the Pearl Harbor attack. Ramadas, supra, at 78.

(26.) See Greg Robinson, A Tragedy of Democracy: Japanese Confinement in North America, 2 J. of Transnat'l Am. Stud. (2010) (listing differences between internment and concentration camps). In contrast to concentration camps, which included torture and pain, the internment camps were a slightly better environment. Id. See also Melissa Fares, 75 Years Later, Japanese Americans Recall Pain of Internment Camps, Reuters (Feb. 18, 2017), http://www.reuters.com/article/us-usa-japanese-anniversary-idUSKBN15W2E2 (detailing experiences at internment camps). Joyce Nakamura Okazaki was taken to a concentration camp at the age of seven and noted the similarities to Nazi Germany. Id. She did indicate however, that unlike in Nazi Germany, the "detainees were not killed or tortured." Id.

(27.) See Melody Hill, Special Interests and the Internment of Japanese-Americans During World War II, Foundation for Economic Education (Jul. 1,1995), https:/ /fee.org/articles/special-interests-and-the-internment-of-japanese-americans-duringworld-war-ii/ (indicating Japanese-Americans not welcomed back after end of internment). While the intention of relocating the Japanese Americans was not initially to take their land away permanently, "some viewed the situation in California immediately following the attack on Pearl Harbor as a unique opportunity to get rid of competitors." Id. But See William Yardley, Bob Fletcher Dies at 101; Helped Japanese Americans, N.Y. Times (Jun. 6, 2013), http://www.nytimes.com/2013/06/07/us/bob fletcher-dies-at-101-saved-farms-of-interned-japanese-americans.html (detailing life of farmer who assisted Japanese Americans). Bob Fletcher took over farms for the Japanese who were relocated in order to keep them running while they were gone. Id.

(28.) See Hill, supra note 27 (indicating farm land bought for cheap). See also David Mas Masumoto, A Bitter Harvest: Inside Japanese-American Internment Camps During World War II, Modern Farmer (Oct. 13, 2015), http://modernfarmer.com/ 2015/10/japanese-american-internment-camps/ (noting crops also purchased inexpensive directly prior to internment camps). David Mas Masumoto's family was forced to sell all their belongings after the executive order was signed. Id. Some returned to California to restart what was left of the farms since they had nowhere else to go after being released from the relocation camps. Id.

(29.) See John G. Brucato, The War Hits the Farm Lands: City Folks Urged to Harvest Crop During Vacations, Back to Land Movement Takes on New Importance, The Virtual Museum of the City of San Francisco, http://www.sfmuseum.org/ hist9/harvest.html (last visited Oct. 19, 2016) (indicating labor help gone after relocation). Farm bureau officials contemplated bringing in workers to assist with crops. Id.

(30.) See id. (stating Japanese farmers responsible for large portion of crops in California). In the 1940s, "Japanese farmers were responsible for 40 percent of all vegetables grown in the state, including nearly 100 percent of all tomatoes, celery, strawberries and peppers." Id.

(31.) See Masumoto, supra note 28 (indicating changed social and economic structures of Japanese-Americans). Losing their farms and property meant that when they returned, the Japanese-Americans had no opportunity to expand. Id.

(32.) See National Archives, supra note 25 (stating government feared more attacks after Pearl Harbor). The attacks on Pearl Harbor drew the United States into World War II and created a strong sense of fear throughout the country as to what may happen next. Id. See also Hill, supra note 27 (indicating restrictions also put on immigration of Japanese).

(33.) See Korematsu v. United States, 323 U.S. 214 (1944) (holding deference to Congress and military during wartime). See also Des Jardin, supra note 22 (stating American citizens turned into enemies after attack). Years after the end of the war and the internment camps, reparations were made to Japanese-Americans as an apology for their relocation and internment. Id.

(34.) See Hill, supra note 27 (stating only small portion of losses repaid to internees). See Des Jardin, supra note 22 (indicating anti-Japanese sentiment widespread even after internment ceased). See generally Fares, supra note 26 (indicating President Reagan signed bill providing reparations and apology). Those who survived the internment received $20,000. Id.

(35.) See Tony Blair, Full Text of Tony Blair's Speech to Parliament, The Guardian (Oct. 2, 2001) available at https://www.theguardian.com/world/2001/oct/04/september11.usa3 (expressing unity with United States). Blair indicated to Parliament that it was necessary to strengthen laws to better protect security and citizens of the United Kingdom. Id. See Press Release from Eur. Comra'n. on Events of September 11th, (Sept. 12, 2001) available at http://europa.eu/rapid/press-release_PRES-01-318_en. htm (encouraging Member States to assist United States in combating terrorism). The Council condemned the terror attack and indicated support for the United States in any way they could be of assistance. Id. The Council noted the steps they planned to take would "be aimed at increasing the capacity of the European Union to effectively fight, together with the United States and other partners, international terrorism." Id.

(36.) See Kim Lane Scheppele, Other People's PATRIOT Act: Europe's Response to September II, 50 Loy. L. Rev. 89 (2004) (detailing legislation enacted in Europe as response to September 11th). Prior to September 11th, the European Union saw terrorism legislation as "primarily regulated through each EU member state's criminal law framework." Id. at 94.

(37.) See Council Framework Decision 2002/475/JHA, art. 1 (creating framework to combat terrorism). The Council Framework Decision's definition of terrorism acts include:
   offences under national law, which, given their nature or context,
   may seriously damage a country or an international organisation
   where committed with the aim of:

   --seriously intimidating a population, or --unduly compelling a
   Government or international organisation to perform or abstain from
   performing any act, or

   --seriously destabilising or destroying the fundamental political,
   constitutional, economic or social structures of a country or an
   international organisation, shall be deemed to be terrorist
   offences: (a) attacks upon a person's life which may cause death;
   (b) attacks upon the physical integrity of a person; (c) kidnapping
   or hostage taking; (d) causing extensive destruction to a
   Government or public facility, a transport system, an
   infrastructure facility, including an information system, a fixed
   platform located on the continental shelf, a public place or
   private property likely to endanger human life or result in major
   economic loss; (e) seizure of aircraft, ships or other means of
   public or goods transport; (f) manufacture, possession,
   acquisition, transport, supply or use of weapons, explosives or of
   nuclear, biological or chemical weapons, as well as research into,
   and development of, biological and chemical weapons; (g) release of
   dangerous substances, or causing fires, floods or explosions the
   effect of which is to endanger human life; (h) interfering with or
   disrupting the supply of water, power or any other fundamental
   natural resource the effect of which is to endanger human life; (i)
   threatening to commit any of the acts listed in (a) to (h).


Id. See also Scheppele, supra note 36, at 91 (indicating steps European Union has taken against terrorism). The definition of terrorism was structured similar to that of the definition of a hate crime. Id. at 95. See also Elies Van Sliedregt, European Approaches to Fighting Terrorism, 20 Duke J. of Comp. & Int'l L. 413 (2010) (explaining effects of Council Framework Decision). The Framework Decision places a strong emphasis on security. Id. Many European nations took steps to criminalize terrorism at early stages. Id. at 424.

(38.) See Council Framework Decision, supra note 37, at art. 5 (indicating when implementation must take place).

(39.) See U.N. Charter arts. 39-51 (implementing provisions of Charter). Chapter VII (Articles 39-51) of the United Nations Charter concerns measures that can be taken against threats to peace. Id. The Articles within outlined steps that U.N. Member States can take to both prevent and handle breaches of peace. Id. See Van Sleidregt, supra note 37, at 416 (explaining Charter). The amendment places sanctions on the "freezing of financial funds and assets of persons or organizations." Id.

(40.) See The European Union Counter-Terrorism Strategy, Council of the European Union (2005) available at http://register.consilium.europa.eu/doc/ srv?1=EN&f=ST%2014469%202005 % 20 RE V %204 (providing plan to fight terrorism).The strategy details key priorities in each area. Id. The European Council indicated that the strategy would be reviewed every six months. Id. at 17.

(41.) See id. (detailing strategy components). The strategy explained each of the four main pillars and noted key priorities for Member States in each area. Id. One of the aims was to prevent the radicalization and recruitment into terror groups. Id. at 7. They planned to accomplish this by developing a media strategy to explain European Union policies and addressing recruitment in particular environments. Id. at 9. The strategy detailed priorities in protection, which included improving the security of European Union passport and establishing a Visa Information System. Id. at 11.

(42.) See Philippe Delivet, The European Union and the Fight to Counter Terrorism, Foundation Robert Schuman, The Research and Studies Centre on Europe, Issue no. 372 (Nov. 23, 2015), http://www.robert-schuman.eu/en/europeanissues/0372-the-european-union-and-the-fight-to- counter-terrorism (discussing progression of European Unions' terrorism laws). Since 2002, the European Union has been able to develop policy related to police and judicial cooperation. Id. It was able to move forward developing additional legislation because of a more unified definition of terrorism. Id.

(43.) See Bozenko Devoic, The Post 9/11 European Union Counterterrorism Response: Legal Institutional Framework (Dec. 2012) (unpublished thesis, Naval Postgraduate School) (detailing Europe's response to September 11th). Prior to September 11th, there were only six Member States of the European Union that had any counterterrorism laws in place. Id. at 19. See Foley, supra note 3, at 208 (detailing Britain and France's reactions to September 11th).

(44.) See Strafgesetzbuches, supra note 3 (amending code to include terror formation); Scheppele, supra note 36, at 99 (detailing Germany's actions to amend terror laws).

(45.) See Anti-Terrorism, Crime and Security Act 2001, c. 24. (enacting provisions to promote safety of United Kingdom); Q and A: Anti-Terrorism Legislation, BBC News (Oct. 17, 2003), http://news.bbc.co.Uk/2/hi/uk_news/3197394.stm (explaining anti-terror legislation in United Kingdom). A new act "was introduced because the government believed there were individuals in the UK who were a potential threat but it could not deport back to regimes known for human rights abuses." Id.

(46.) See Anti-Terrorism, Crime and Security Act, supra note 45 (indicating possible ways to prevent terrorism). The Anti-Terrorism, Crime and Security Act's aim was
   to make further provision about terrorism and security; to provide
   for the freezing of assets; to make provision about immigration and
   asylum; to amend or extend the criminal law and powers for
   preventing crime and enforcing that law; to make provision about
   the control of pathogens and toxins; to provide for the retention
   of communications data.


Id.

(47.) See Virginia Helen Henning, Anti-Terrorism, Crime and Security Act 2001: Has the United Kingdom Made a Valid Derogation From the European Convention on Human Rights?, 17 Am. U. Int'l L. Rev. 1263, 1270 (2002) (stating Anti-Terrorism, Crime and Security Act may clash with ideas of Human Rights Convention). Immediately after it was enacted, there were protests from the Human Rights Convention. Id. at 1266. See Colin Nicholls, The U.K. Anti-Terrorism Crime & Security Act 2001: Too Much ... Too Soon, Humans Rights Initiative, (Feb. 2002) (listing possible problems with Anti-Terrorism Crime and Security Act). It was noted that in times where community rights are threated, there are usually measures that force individuals to give up some of their rights. Id. See also Global: 140 Countries Pass Counterterror Laws since 9/11, Human Rights Watch (Jun. 29, 2012), https://www.hrw.org/ news/2012/06/29/global-140-countries-pass-counterterror-laws-9/11 (indicating many countries have passed anti-terror laws clashing with human rights).

(48.) See Frank Holmes, The Global Cost of Terrorism is at an All-Time High, Business Insider (Mar. 26, 2016), http://www.businessinsider.com/global-cost-of-ter rorism-at-all-time-high-2016-3 (stating cost of terrorism rising). Since 2010, the "economic impact of global terrorism" has steadily risen each year. Id. The total cost of the September 11th attacks cost approximately $3.3 trillion. Id. See also Andrew Ross Sorkin, The Hidden Costs of Terrorism, N.Y. Times (Nov. 16, 2015), http://www. nytimes.com/2015/ll/17/business/dealbook/the-fallou'-from-attacks-is-measured-inmore-than-stock-markets.html (indicating costs of terror are difficult to measure). The clear physical costs of terrorism can be measured, however the indirect costs are difficult to determine. Id. See 2016 Terrorism Risk Insurance Report, Marsh (July 2016), https://www.marsh.com/content/dam/marsh/Documents/PDF/US-en/ 2016%20Terrorism%20Risk%20Insurance%20Report.pdf (detailing current state of terror risk). It appears that there has been a change in the way attacks are carried out in recent years, with a greater amount of attacks focused on "soft targets," causing disruptions to businesses. Id. at 3.

(49.) See Terrorism Risk Insurance Act of 2002, 15 U.S.C. [section] 6701 (detailing initiatives regarding terror insurance).

(50.) See id. (explaining when terrorism insurance required). See also Baird Webel, Cong. Research Serv., RS21979, Terrorism Risk Insurance: An overview, (2005) (providing details on 'terrorism Risk Insurance Act (TRIA)). The report indicated that "TRIA's goals are to (1) create a temporary federal program of shared public and private compensation for insured losses to allow the private market to stabilize, (2) protect consumers by ensuring the availability and affordability of insurance for terrorism risks, and (3) preserve state regulation of insurance." Id.

(51.) See Terrorism Risk Insurance Program, U.S. Department of the Treasury, https://www.treasury.gov/resource-center/fin-mkts/Pages/program.aspx (last updated Mar. 4, 2016) (showing progression of TRIA since inception). See also Terrorism [degrees].isk Insurance Program Reauthorization Act of 2015, H.R 26,114th Cong. (2015) (extending coverage of TRIA). The Act was extended through 2020 and the reauthorization revised several provisions found within TRIA. Id.

(52.) See Marsh, supra note 48, at 5 (explaining when terrorism insurance is available in United States). In order for the insurance to apply, the event must be a:
   violent act or an act that is dangerous to human life, property, or
   infrastructure to have occurred on US territory and committed by an
   individual or individuals as part of an effort to coerce the US
   civilian population or to influence the policy or affect the
   conduct of the US government by coercion.


Id.

(53.) See Marsh, supra note 48, at 8 (listing European pool programs). See also Who We Are, Pool Re https://www.poolre.co.uk/who-we-are/ (last visited Jan. 1, 2016) (explaining Pool Re). Pool Re was created in 1993. Id. It now provides protections "for the UK economy and currently underwrites over 2 trillion [pounds sterling] of exposure in commercial property to terrorism risk across the UK mainland." Id.

(54.) See Who Are We, GAREAT, http://www.gareat.com/en (last visited Dec. 31, 2016) (detailing Gestion de l'Assurance et de la Reassurance des risques Attentats et actes de Terrorisme (GAREAT)). GAREAT was created "to manage the reinsurance of the risks of 'attacks' and acts of terrorism in France ... to allow them to meet the Property Damage losses arising out of 'attacks' and acts of terrorism suffered on national territory, regardless of the country in which the act of terrorism is perpetrated." Id. There are two sections that make up GAREAT, "Large-Risk" and "Small and Medium Sized Risks." Id. See Christine de Brondy, GAREAT, Secretary General, GAREAT: The French Terrorism Insurance Scheme, OECD (Jun. 1, 2010) (presenting GAREAT overview); Erwann Michel-Kerjan & Burkhard Pedell, Terrorism Risk Coverage in lhe Post-9/11 Era: A Comparison of New Public-Private Partnerships in France, Germany and the U.S. Wharton Risk Management Decision and Process Center, Working Paper #2004-029, Oct. 2004, available at http:// citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.387.451 &rep=rep1&type=pdf (detailing development of terror insurance); Germany--Terrorism Risk Insurance Programme, OECD International Platform on Terrorism Risk Insurance (last visited Jan. 1, 2016) (summarizing German terror insurance). Terrorist acts are defined as "any acts committed by persons or groups of persons to achieve political, religious, ethnic or ideological purposes that are likely to spread anxiety or fear amongst the population or parts of the population and thereby influence any government or government institution." Germany--Terrorism Risk Insurance Programme, supra. See Maya Nikolaeva and Carolyn Cohn, Terrorism reinsurance fund to help Parisian businesses, Reuters (Nov. 24, 2015), http://www.reuters.com/article/france-shooting-insurance-id USL8N13I1MP20151124 (indicating how GAREAT currently works in France). After the November 2016 attacks in France, businesses will likely be able to use their terrorism insurance. Id. See also Richard Miller, Germany to Renew Terrorism Coverage Backstop-, Business Insurance (Aug. 20, 2009) http://www.businessinsurance. com/article/20090820/NEWS/908209992 (indicating Germany terror insurance extended).

(55.) See Marsh, supra note 48, at 3 (explaining scope of coverage); Does My Business Need Insurance?, Insurance Information Institute, http://www.iii.org/article/ does-my-business-need-terrorism-insurance (last visited Mar. 8, 2017) (answering questions in relation to terrorism coverage). Terrorism insurance covers "damaged or destroyed property--including buildings, equipment, furnishings and inventory. It may also cover losses associated with the interruption of your business." Id.

(56.) See Marsh, supra note 48, at 7 (adding risk of political violence and cyber risk). With the increased threat of political violence and cyber risks, new insurance policies for each should be considered. Id.

(57.) See Aloke Chakravarty, Time for a Global Legal Scheme for Terrorism Risk Insurance, B.U. Int'l L. J. (Jan. 7, 2015) (indicating challenges to various terror definitions). There is no one definition of terror and as such, an event may not necessarily qualify for terrorism coverage. Id. There typically needs to be a qualifying "triggering event" to be covered. Id. See also GAREAT, supra note 54 (defining terror). French terrorism insurance uses the terrorism definition found in the French penal code. Id.

(58.) See Joshua Sinai, New Trends in Terrorism's Targeting of the Business Sector, The Mackenzie Institute (May 9, 2016), http://mackenzieinstitute.com/new-trendsin-terrorisms-targeting-of-the-business- sector/ (stating financial institutions vulnerable to terror attacks).

(59.) See Adam Shell, 13 years after 9/11, markets face new threat, USA Today (last updated Sept. 11, 2014), http://www.usatoday.com/story/money/markets/2014/09/ 10/9-ll-markets-face-new-threat/15424957/ (examining previous threats to stock market and new challenges faced today). The stock market dropped twelve percent due to the unexpected nature of the attacks. Id. See generally Richard J. Herring & Anthony M Santomero, The Rote of the Financial Sector in Economic Performance 1 (The Wharton School, Working Paper 95-08, 1995), available at http://citeseerx.ist. psu.edu/viewdoc/download?doi= 10.1.1.41,3455&rep=rep1&type=pdf (defining financial sector and importance to economy). "The financial sector mobilizes savings and allocates credit across space and time." Id. at 1.

(60.) See R. Barry Johnston and Oana M. Nedelescu, The Impact of Terrorism on Financial Markets, 6 IMF Working Paper (March 2005), https://www.imf.org/exter nal/pubs/ft/wp/2005/wp0560.pdf (indicating global markets affected by lack of investor confidence); Terrorism and International Business, Japan Today (Sept. 8, 2011), https://www.japantoday.com/category/opinions/view/terrorism-and-international-busi ness (emphasizing investors' preference to local and direct investment over foreign after terror attacks); Todd Sandler & Walter Enders, Economic Consequences of Terrorism in Developed and Developing Countries: An Overview, University of Texas, available at http://www.utdallas.edu/~tms063000/website/Econ_Consequences_ms.pdf (stating lack of foreign direct investment can reduce economic growth); Daniel Wagner, The Impact of Terrorism on Foreign Direct Investment, FDI Magazine (Feb. 2006), available at https://www.irmi.com/articles/expert-commentary/the-impact-ofterrorism-on-foreign-direct-investment (detailing behavior of investors after terrorism). See also Ian Bremmer, Managing Risk in an Unstable World, Harvard Bus. Rev. (June 2005) (examining investors' confidence as result of political risk). Investors are also looking to the political risks in a country in order to determine whether to invest. Id.

(61.) See Sandler et al., supra note 60, at 24 (showing markets typically bounce back from attacks). Studies have shown that markets tend to be affected for one to several days unless the terror attack is a major one, such as September 11th. Id. See also Johnston et al., supra note 60, at 1 (listing instances markets rebounded from terror attacks in short period of time). Markets typically recover to pre-attack levels within weeks. Id. at 6.

(62.) See Johnston et al., supra note 60, at 7 (comparing effects of regional incidents to global incidents); See also Matt Krantz, 9 U.S. Companies Most Reliant on Europe at Risk, USA Today (Nov. 16, 2015), http://www.usatoday.com/story/money/ markets/2015/1 l/16/companies-reliant-on-europe/75876600/ (indicating companies with European ties are at risk of terror attacks). When portfolios are diversified, as they increasingly are, there is a greater risk when there is an attack in Europe. Id. See also Investing During Uncertainty, Investopedia (last visited Mar. 1, 2017), http:/ /www.investopedia.com/articles/basics/03/021403.asp (providing investment advice regarding uncertain times). There can be large rewards when making investments in risky markets. Id. The best approach is to be as informed as possible regarding changing circumstances. Id. See also Oliver Gee, How the Terror Attacks Are Impacting France, The Local (Nov. 23, 2015), https://www.thelocal.fr/20151123/howhave-the-terror-attacks-impacted-france (discussing potential repercussions of recent French attacks on markets).

(63.) See Terrorism and the International Business Environment: The Security-Business Nexus (Gabriele G.S. Suder ed., 2004) (noting tourism an economic target of terrorism). It is difficult to assess the economic damages caused by a disruption to tourism, but a decrease in tourism would hurt the job market and thus the economy. Id. at 157-158. See also Abraham Pizam & Ginger Smith, Tourism and Terrorism: A Historical Analysis of Major Terrorism Acts and Their Impact on Tourism Destinations, Univ. of Central Florida (2000), available at http://stars.library.ucf.edu/cgi/viewcontent.cgi?article=1379&context=rosenscholar (explaining how various terror attacks through history have affected tourism industry). The importance of tourism to a particular country will determine the impact a terror attack may have on that country. Id. at 126. See also Alexa Liautaud & Sam Schechner, Terror Attacks Weigh on Europe's Travel Companies, Wall St. J. (Jul. 24, 2016), http://www.wsj.com/articles/terror-attacks-weigh-on-europes-travel-companies-14693 72313 (noting airline and hotel booking levels down after terror attacks). Travelers are becoming fearful and with each attack, the demand usually present in the tourism industry decreases. Id. See also Sinai, supra note 58 (explaining tourism's importance to economy). It was noted that "[t]ourism is vital to a nation's economy because it impacts a government's revenue, national income and employment." Id. See also Liz Alderman, Terrorism Sc ires Away Tourists Europe was Counting On, N.Y. Times (July 29, 2016), http://www.nytimes.com/2016/07/30/business/international/europeeconomy-gdp-terrorism.html?_r=0 (indicating multiple attacks have driven tourists away). As the number of attacks increase and occur more frequently in Europe, the tourists that the area counts on are second-guessing their trips. Id. See also Laurie Laird, The Paris Attacks and the Economic Impact of Terrorism, Forbes (Nov. 16, 2016), http://www.forbes.com/sites/laurielaird/ 2015/11/16/the-paris-attacks-and-the economic-impact-of-terrorism/#5fcffda1386d (stating stocks and booking related to travel industry down after attacks).

(64.) See Suder, supra note 63, at 162 (indicating airlines severely hurt by September 11th attack). See generally Sinai, supra note 58 (commenting hotels, restaurants and major tourist areas susceptible to terror attacks).

(65.) See Katherine LaGrave, How Terrorism Affects Tourism, Conde Nast Traveler (Mar. 31, 2016), http://www.cntraveler.com/stories/2016-03-31/how-terrorism-affects-tourism (indicating terrorism does not tend to have lasting long-term impact). Rochelle Turner stated that "tourism is a very resilient sector." Id. It was noted that factors keeping tourists away include, "the stability of the country; whether the attack was aimed at tourists; and the government response." Id. See Ben Popken, Global Tourism Takes Massive Hit After Spike in Terror Attacks, NBC NEWS (Jul. 21, 2016), http://www.nbcnews.com/business/travel/ global-tourism-takes-massive-hitafter-spike-terror-attacks-n614111 (indicating multiple attacks may alter travel plans). One tourist who planned to travel to an area affected by terrorism indicated that "[a]fter the first bombing ... we weren't going to let the terrorists win ... after the second bombing ... we decided to cancel our plans." Id.

(66.) See John J. Mazzarella, Terrorism and Multinational Corporations: International Business Deals with the Costs of Geopolitical Conflict, Major Themes in Economics, 60 (Spring 2005), available at http://business.uni.edu/economics/themes/ mazzarella.pdf (building costs of terrorism into business plans); See Frederick V. Perry, Article, Multinationals at Risk: Terror and the Rule of Law, 7 FIU L. Rev. 43 (2011) (examining issues businesses face as result of terror attacks). See also Debbie Johnston, Article, Lifting the Veil on Corporate Terrorism: The Use of The Criminal Code Terrorism Framework to Hold Multinational Corporations Accountable for Complicity in Human Rights Violations Abroad, 66 U.T. Fac. L. Rev. 137, 161-162 (2008) (suggesting corporations monitor possibility of inadvertently facilitating terrorism).

(67.) See Suder, supra note 63, at 49 (explaining indirect effects of terrorism are often longer lasting). Businesses need to comply with new regulations imposed by the government. Id. These new regulations have the potential to have a greater effect on business than the attacks themselves. Id. See also Sangwon Yoon & Andre Tartar, The Global Economic Cost of Terrorism Is Now at Its Highest Since 9/11, Bloomberg (Nov. 16, 2015), https://www.bloomberg.com/news/articles/2015-ll-17/theglobal-economic-cost-of-terrorism-is-now-at-its- highest-since-9-11 (comparing terror costs from different years).

(68.) See Mazzarella, supra note 66 (indicating businesses must take physical security of locations into account). Increasing security is not only costly to the company, but may increase worry for employees and cause negative psychological effects. Id. See also Perry, supra note 66, at 47 (listing security issues faced by businesses).

(69.) See supra notes 55-57 and accompanying text (indicating needs of terror insurance).

(70.) See Mazzarella, supra note 66, at 62 (stating multinational corporations must plan for possibility of global supply chain disruption). The cost to ensure the safety of products and compliance with implemented regulations is high. Id. at 63. Shipping regulations and costs force companies to use certain routes, leaving them more open to disruption if the supply chains are attacked or unable to be utilized. Id.

(71.) See id. at 62 (indicating disruption to supply chain could dispute trade). See also Janet Napolitano, The Urgent Need to Protect the Global Supply Chain, Reuters (Jan. 27, 2012), http://blogs.reuters.com/great-debate/2012/01/27/the-urgent-need-toprotect-the-global-supply-chain/ (emphasizing costs of supply chain disruption). Ms. Napolitano indicated that by working together globally, the movement of goods can be secured. Id. See Wolfgang Lehmacher, How Safe Are Our Supply Chains From Terrorist Attack?, World Economic Forum (Dec. 11, 2015), https://www.weforum. org/agenda/2015/12/how-safe-are-our-supply-chains-from-terrorist-attack/ (indicating potential supply chain issues). It is important to protect global supply chains and the first step to do so is realizing they are a likely target. Id.

(72.) See Jonathan Vanian, Here's How Much Businesses Worldwide Will Spend on Cybersecurity by 2020, Fortune (Oct. 12, 2016), http://fortune.com/2016/10/12/ cybersecurity-global-spending/ (analyzing total cost of cyber security). Cyber security is a hot topic within many industries. Id.

(73.) See Hampton Pearson, Protecting Against Cyber Terrorism, NBCNEWS (Dec. 16, 2015), http://www.nbcnews.eom/id/3072965/ns/business-check_point/t/pro tecting-against-cyber-terrorism/#.WAf6ZOtORXU (indicating terrorists increasingly use cyber attacks). Successful cyber-attacks could cost the companies attacked millions of dollars. Id. See Fernando M. Pinguelo & Bradford W. Muller, Article, Virtual Crimes, Real Damages: A Primer On Cybercrimes In The United States and Efforts to Combat Cybercriminals, 16 Va. J.L. & Tech. 116, 125 (2011) (detailing foreign threats of cyber attacks).

(74.) See Eur. Economic and Social Committee, Small and Medium Sized Enterprises, http://old.eesc.europa.eu/?i=portal.en.enterprises-and-industry-sme (last visited Jan. 5, 2018) (explaining importance of small businesses in European Union). There are "some 21 million small firms making up 98% of E.U. businesses, and employing 87 million people." Id. See Aarno Airaksinen, Henri Luomaranta, Pekka Alajaasko & Anton, Statistics on Small and Medium-sized Enterprises, Eurostat (last visited Jan 7, 2018), http://www.eesc.europa.eu/?i=portal.en.enterprises-and-industry-sme (indicating importance of SMEs to economy). See generally The EU and Small Businesses, Euronet http://www.erionet.org (last visited Jan. 5, 2018) (defining SMEs). SMEs have "less than 250 employees, which operate independently from larger companies." Id. Dr. Jennifer Abel-Koch et al., SME Investment and Innovation, Dr. Jennifer Abel-Koch et al. 6 (2015) (discussing valuable traits of SMEs). SMEs play a large role in European innovation and investment. Id. at 7. It was noted that "the future international competitiveness and thus long-term growth and welfare prospects of the four largest economies in Europe will therefore depend to a large extent on the viability of the micro, small and medium sized enterprises." Id. See Marco Lopriore, Supporting Enterprise Development and SME in Europe, European Institute of Public Administration (2009) (discussing importance of SMEs in Europe). SMEs make-up approximately two-thirds of the "total private sector employment, represent 80% of the total job creation and produce more than half of EU added value." Id.

(75.) See Bridgette Sullivan-Taylor & Layla Branicki, Creating Resilient SMEs: Why One Size Might Not Fit All, 49 Int'l J. of Prod. Res. (2011), available at http:// wrap, warwick. ac.uk/43513/l/WRAP_Sullivan-Taylor_Sullivan-Taylor_and_Branicki_ IJPR_29_12_10_final.pdf (indicating SMEs damaged more by extreme events). SMEs generally have fewer resources than larger companies and thus are unable to recover as quickly. Id. at 4. See also The EU and Small Business, supra note 74 (detailing polices created to help SMEs thrive). There are ten principals included in the Small Business Act that are aimed to assist in the development of SMEs, which include, "[c]reat[ing] an environment in which family business can prosper; [a]bid[ing] by the 'Think Small First' principle; [a]ssist[ing] SMEs to capitalize on the opportunities offered by the Single Market; and[s]upport[ing] SMEs to capitalize market growth." Id.

(76.) See Why SMEs Need To Rethink Their Terrorism Insurance, Jlt Group (Apr. 30, 2016), http://www.jlt.com/specialty/our-insights/publications/whiteboard/ whiteboard-spring-2016/why-smes-need-to-rethink-their-terrorism-insurance (suggesting SMEs obtain terrorism insurance). Companies with more than one location can mitigate costs easier than small businesses with only one. Id.

(77.) See Maya Nikolaeva & Carolyn Cohn, Terrorism Reinsurance Fund to Help Parisian Businesses, Reuters (Nov. 24, 2015), http://www.reuters.com/article/franceshooting-insurance-idUSL8N13Il MP20151124 (stating small businesses tend to suffer greater losses from terror). Many small businesses rely on customers and people in the area and terrorism hurts them more than larger businesses who can cover costs with insurance. Id.

(78.) See Cindy May, Nice attack: Why do terrorists keep attacking France?, Inter national Business Times (Jul. 15, 2016), http://www.ibtimes.co.uk/nice-attack-whydo-terrorists-keep-attacking-france- 1570866 (theorizing terrorist attack rural areas because areas are easier to recruit and train potential terrorists). The President of France, Francois Holland noted that "[m]any immigrants live in impoverished suburban banlieues that are insular, ghettoized communities, which further exacerbate their isolation from wider French society. This makes France a potentially ripe recruiting ground for terrorist groups, and provides a disaffected population that could serve as autonomous actors." Id. Additionally, there have been tensions among the French and the French-Muslim communities. Id.

(79.) See European Charter for Small Enterprises, Eur-Lex., available at http:// eur-lex.europa.eu/legal-content/EN/TXT/?uri=URISERV%3An26002 (last visited Jan. 4, 2018) (summarizing charter enacted to protect small European enterprises). The charter indicated ten ways in which to facilitate growth of small businesses, including:
   Education and training for entrepreneurship; Cheaper and faster
   startup; Better legislation and regulation; Availability of skills;
   Improving online access; Getting more out of the single market;
   Taxation and financial matters; Strengthening the technological
   capacity of small enterprises; Successful e-business models and
   top-class small business support; Develop stronger, more effective
   representation of SMEs' interests at Union and national level.


Id. See The Small Business Act for Europe, European Commission, https:// ec.europa.eu/growth/smes/business-friendly-environment/smal!-business-act_en (last visited Jan. 5, 2018). The Act has four main goals: "promoting entrepreneurship, less regulatory burden, access to finance, access to markets and internationalisation." Id. Utilizing the "think small first" principle is aimed at prompting policymakers consider small businesses while proposing legislation. Id. See also About us, European Association of Craft, Small and Medium-Sized Enterprises "UEAPME" http:// www.ueapme.com/spip.php? rubriquei (last visited Dec. 27, 2016) [hereinafter UEAPME] (describing role of UEAPME for SMEs). UEAPME is "the voice" of SMEs, keeping abreast of E.U. policy and working toward promoting SMEs' interests in Member States. Id. See also Entrepreneurship and Small and medium-sized enterprises (SMEs), European Commission (last visited Jan. 2, 2017), http://ec.europa.eu/ small-business/most-of-market/rules/index_en.htm (listing helpful information for small businesses in EU); Entrepreneurship 2020 Action Plan, Eur-Lex (2012) http:// eur-lex.europa.eu/legal-content/EN/TXT/?uriCELEX:52012DC0795 (attempting to "reignite entrepreneurship spirit of Europe"). The goal is to help make entrepreneurship more attractive in Member States, helping to assist the economy. Entrepreneurship 2020 Action Plan, supra.

(80.) See Gregory Viscusi & Mark Deen, Why France Has So Many 49-Employee Companies, Bloomberg (May 3, 2012), http://www.bloomberg.com/news/articles/ 2012-05-03/why-france-has-so-many-49-employee-companies (stating companies with more than forty-nine employees subject to French Code). There are nearly two and half times as many companies with forty-nine employees as they are fifty in France. Id. If a company has fifty or more employees they are subject to stricter regulations and codes that many find difficult to deal with. Id.

(81.) See Ben Lobel, UK SMEs prefer Europe as Trading Destination, Small Business.co.uk (Nov. 4, 2015), http://smallbusiness.co.uk/uk-smes-prefer-europe-as-trad ing-destination-2496391/ (indicating SMEs rely on trade especially within Europe). There is a large trade volume within Europe and SMEs, especially those within the United Kingdom, need to be cognizant of the effects Brexit may cause on their trade relationships within the rest of Europe. Id.

(82.) See OECD, Entrepreneurship and Migrants, (2010) available at https://www. oecd.org/cfe/smes/45068866.pdf (examining migrants as entrepreneurs). A large portion of migrant entrepreneurship "comes from a typically skilled migrant whose business grows rapidly into a large firm. Such ventures, known as high-growth firms, account for most of the job growth in many OECD countries." Id. at 6. See also David Prosser, Small Talk: Immigrants start businesses, create jobs and pay taxes: let's welcome them, The Independent (Apr. 19, 2015), http://www.independent.co.uk/ news/ business/sme/small-talk-immigrants-start-businesses-create-jobs-and-pay-taxeslet-s-welcome-them-10188526.html (discussing importance of immigrants on small business economy); Edinburgh Group, Growing the Global Economy Through SMEs, available at http://www.edinburgh- group.org/media/2776/edinburgh_group_research__growing_the_global_economy_through_smes.pdf (recommending ways to assist growth SMEs). When looking at the importance of SMEs, "[j]ob creation is particularly important for countries that are plagued by high unemployment rates and in general for developing and emerging economies." Edinburgh Group, supra, at 9. See also Emma Featherstone, Migrants are Creating Jobs, not taking them, The Guardian (Sept. 12, 2016), https://www.theguardian.com/small-business-network/2016/sep/ 12/migrants-creating-jobs-visas-economy-report (indicating migrant businesses help U.K. economy). There have been reports that show "migrants contribute much more than they take from the UK economy." Id. See also Jan Rath and Anna Swagerman, Promoting ethnic entrepreneurship in European cities, European Foundation for the Improvement of Living and Working Conditions (2011) available at https:// www.coe.int/t/democracy/migration/Source/migration/congress_public_3.pdf (listing importance of ethnic entrepreneurship). Creating jobs can help eliminate unemployment among immigrants and can provide alternate skills than those native to the country. Id. at 2. See also Barry Jaruzelski, Volker Staack & Robert Chwalik, Will Stronger Borders Weaken Innovation? Strategy & Business (Oct. 24. 2017), https:// www.strategy-business.com/feature/Will-Stronger-Borders-Weaken-Innovation?gko= 848b0 (theorizing negative effects of stronger borders on innovation). With the rise of economic nationalism, companies are forced "to question the sustainability of their integrated global networks." Id.

(83.) See Jane Onyanga-Omara, Timeline: Terror Attacks in Europe, USA Today (Jun. 28, 2016), http://www.usatoday.com/story/news/world/2016/03/22/timeline-terrorattacks-europe/82108892/ (listing major European terror attacks over last twenty years). Over this timespan, the article details fourteen terror attacks that have taken place throughout Europe. Id. Attacks range from suicide bombers killing dozens to lone wolf attacks killing children. Id.

(84.) See CNN Library, July 7 2005 London Bombings Fast Facts, CNN (Jun. 29, 2017), http://www.cnn.com/2013/ll/06/world/europe/july-7-2005-london-bombingsfast-facts/ (chronicling account of London tube bombing). Three suicide bombs were set off within fifty seconds on one another at various train stations in the London area. Id. Days after the attacks, an additional twelve bombs were found at other stations in London. Id. See also Onyanga-Omara, supra note 83 (describing briefly London attack); Michael Edison Hayden, Terror in the UK: A Timeline of Recent Attacks, ABC NEWS (Sept. 15, 2017), http://abcnews.go.com/International/terror-uktimeline-recent- attacks/story?id=47579860 (chronicling terror attacks in United Kingdom). I

(85.) See BBC News, 7 July London bombings: What happened that day? (Jul. 3, 2015), http://www.bbc.com/news/uk-33253598 (mapping out London tube attacks); CNN Library, supra note 84. (describing London attacks). The locations of each of the bombs were: "[a] train just outside the Liverpool Street station, killing seven people; [a] train just outside the Edgware Road station, killing six people; [a] train traveling between King's Cross and Russell Square stations, killing 26 people." Id.

(86.) See CNN Library, supra note 84 (describing results of attacks).

(87.) See id. (describing arrest and prosecution). A mistrial was declared and upon re-trial, two of the men were found not guilty, while two are convicted of conspiracy. Id.

(88.) See BBC News, Leytonstone Tube station stabbing a 'terrorist incident' (Dec. 6, 2015), http://www.bbc.com/news/uk-35018789 (treating attack as terrorist incident). It was unclear immediately following the incident if it was indeed terror related. Id. In an abundance of caution, the incident was being deemed to have ties to terrorism. Id.

(89.) See id. (describing knife attack). The attacker reportedly had a knife approximately three inches long. Id. The incident caused chaos in the underground station. Id.

(90.) See Simon Usborne, Leyonstone tube attack victim: "It's bizarre how untramatized I feel," The Guardian (July 12, 2016), https://www.theguardian.com/uknews/2016/jul/12/leytonstone-tube-attack-victim- lyle-zimmerman-jo-cox (recounting victim's recollection of attack events). The victim required nineteen stiches after nearly losing his head. Id. A fellow passenger, a doctor, was able to stop the bleeding until he could be transported to a hospital for care. Id.

(91.) See Melissa Gray, Three stabbed at London Tube station in terror attack, police say, CNN (Dec. 7, 2015), http://www.cnn.com/2015/12/05/europe/london-tubestabbings/ (urging citizens take caution). Commander Richard Walton stated, "I would urge the public to remain calm, but alert and vigilant. The threat from terrorism remains at severe, which means that a terrorist attack is highly likely." Id.

(92.) See Harriet Alexander, London Bridge attack, everything we know, The Telegraph (Jun. 9, 2017), http://www.telegraph.co.uk/news/2017/06/03/london-bridgeeverything-know-far/ (detailing events of London Bridge attack); Yonette Joseph, London Bridge Attack: The Implements of Terror, N.Y. Times (Jun. 11, 2017), https:// www.nytimes.com/ 2017/06/11/world/europe/london-bridge-attack-kni ves-fake-suicide-vests-van.html?_r=0 (explaining how attack was carried out). One of the aims of the attacks was to cause fear of by-standers, which was done using "ceramic knives and fake suicide bomb vests." Joseph, supra. The attackers used a van to hit people on the London Bridge, resulting in eight deaths and more than a dozen wounded. Id. The van contained additional weapons including blowtorches and wine bottles that appeared to be filled with flammable liquid. Id. See also Chiara Palazzo & Emily Allen, Manchester terror attack: Everything we know, The Telegraph (May 26, 2017), http^/www.telegraph.co.uk/news/O/manchester-terror-attack-everything-knowfar/ (explaining events of Manchester bombing); Isaac Stanley-Becker, Three second of silence, then a scream: How the Manchester suicide attack unfolded, Wash. Post (May 23, 2017), https://www.washingtonpost.com/world/it-was-all-so-good--and-thenmayhem-at-the-manchester- arena/2017/05/23/282257e6-3fb8-11e7-b29f-f40ffced2ddb _story.html?utm_term=.d9c94ade238f (detailing events leading to attack). Twenty-two people, including many children were killed when a suicide bomb was set off outside an Ariana Grande concert in Manchester, England. Stanley-Becker, supra. The bomb went off as people were exiting the concert. Id. See also Hayden, supra note 84 (including descriptions of recent attacks in United Kingdom).

(93.) See Jake Polden, Timeline of terror: The deadly attacks on the West in the last 12 months as gunman goes on a rampage through German shopping mall and kills nine people, Daily Mail (Jul. 22, 2016), http://www.dailymail.co.uk/news/artiele-3703884/ Timeline-terror-deadly-attacks-West-12-months.html (listing terror attacks in Europe over last twelve months). Europe in general has experienced an uptick in terror attacks, including those in Germany. Id.

(94.) See James Rothwell, Chris Graham & Barney Henderson, German axe attack on train: Isil claim Afghan refugee who injured four as one of its 'fighters,' THE Telegraph (Jul. 19, 2016), http://www.telegraph.co.uk/news/2016/07/18/german-train-axeattack-many-injured/ (detailing train attack). ISIS claimed responsibility for the attack. Id. German police reportedly indicated that "[tjhe attacker was said to have been carrying 'weapons for slashing and cutting.'" Id. He initially fled the train in Germany, but was subsequently shot and killed. Id.

(95.) See Stephanie Kirchner & Michael Birnbaum, Ax-wielding attacker on train roils Germany over migrants, Wash. Post (Jul. 19, 2016), https://www.washington post.com/world/teenage-afghan-refugee-attacking-german-train-passengers-possessed -islamic-state-flag/2016/07/19/90555e6c-4d4c-11e6-bf27-405106836f96_story.html (detailing history of train attacker and its relation to immigration). The attacker had "pledged allegiance to the Islamic State." Id. His identity opened up a debate regarding Germany's national security and its open door policy to migrants. Id.

(96.) See Anton Troianovski, Ansbach Bombing in Germany Believed to Be Islamist Terror Attack, Wall St. J. (Jul. 25, 2016), http://www.wsj.com/articles/syrianasylum-seeker-blows-himself-up-outside- concert-in-germany-1469447416 (theorizing suicide bombing related to terrorism). The attacker was observed pacing outside the festival before setting off the bomb near an outdoor bar. Id. The attacker initially tried to enter the festival with the bomb, but was turned away. Id.

(97.) See Frederik Pleitgen, Tim Hume & Euan McKirdy, Suicide bomber in Germany pledged allegiance to ISIS leader, CNN (Jul. 26, 2016), http://www.cnn.com/2016/ 07/ 24/world/ansbach-germany-blast/ (summarizing both attack and suicide bomber's past). The bomber indicated the attack was revenge against Germany "because [it] obstructs] Islam." Id.

(98.) See Jack Moore, Berlin Attack: German Police Investigating 'Terror Attack' at Christmas Market, Newsweek (Dec. 20, 2016), http://www.newsweek.com/berlin-po lice-truck-crash-christmas-market-probable-terror-attack-534013 (chronicling events surrounding German Christmas market attack). The market at the time was full of families and tourists. Id. It was assumed that the attack was intentional and a terrorist plot. Id.

(99.) See Melissa Eddy & Alison Smale, Germany Releases Berlin Attack Suspect as ISIS Claims Involvement, N.Y. Times (Dec. 20, 2016), http://www.nytimes.com/ 2016/12/ 20/world/europe/berlin-attack-christmas-market.html (indicating ISIS' involvement); Kim Sengupta, Berlin Christmas market attacker 'killed while trying to reach accomplices', The Independent (Dec. 23, 2016), http://www.independent.co.uk /news/world/europe/berlin-christmas-market-attack-anis-amri-killed-trying-reach-ac complices-a7493321.html (detailing suspect's escape to Italy).

(100.) See Erik Kirschbaum, Despite relatively few terrorist attacks, Germany is gripped by fear and false alarms, L.A. Times (Aug. 19, 2016), http://www.latimes.com/ world/europe/ la-fg-germany-terror-false-alarms-20160819-snap-story.html (indicating Germany fearful of increased terrorist attacks). There have been a number of false alarms in recent months. Id. See generally Why is Europe Seeing so Many Terror Attacks?, U.S. News (Sept. 19, 2017), https://www.usnews.com/news/best-countries/articles/2017-09-19/why-is-europe- seeing-so-many-terrorist-attacks (theorizing various reasons for increased European attacks).

(101.) See Timeline: Attacks in France, BBC News (Jul. 26, 2016), http:// www.bbc.com/news/world-europe-33288542 (listing attacks since 2012). Not only has the frequency of attacks increased, the type of attacks has varied as well. Id. See Faith Karimi, Attack in Nice: New terror in France months after mass shooting, CNN (Jul. 15, 2016), http://www.cnn.com/2016/07/15/europe/terror-attacks-nice-why-france/ (highlighting repeated attacks against France). Paul Cruickshank, a CNN analyst stated, "[t]hey [France] are absolutely exhausted after a year and a half of intense efforts to try and protect this country." Id.

(102.) See id. (noting attacks have gotten more frequent in recent years). There have been eleven terrorist attacks in France since the beginning of 2015. Id. In 2015 alone, there were six planned or attempted terrorist attacks in France. Id. See also Angelique Chrisafis, Louvre Knife Attack Sparks Fresh Warning of French Terror Threat, The Guardian (Feb. 3, 2017), https://www.theguardian.com/world/2017/feb/ 03/french-soldier-shoots-man-outside-louvre-paris (suggesting Louvre attack may ignite fears of additional attacks).

(103.) See Timeline: Attacks in France, supra note 101 (noting newspaper attack); Charlie Hebdo attack: Three days of terror, BBC News (Jan. 14, 2015), http:// www.bbc.com/news/world-europe-30708237 (detailing account of attack and days following). The attackers forced a staff member to open the key code to an editorial room and opened fire. Id.

(104.) See Charlie Hebdo attack: Three days of terror, supra note 103 (explaining gunmen's motivations for attack on paper). The gunmen allegedly shouted, '"[w]e have avenged the Prophet Muhammad' and 'God is Great' in Arabic while calling out the names of the journalists." Id.

(105.) See Timeline: Attacks in France, supra note 101 (indicating location of attacks and death toll). The attacks took place at "a concert hall, a major stadium, restaurants and bars, almost simultaneously." Id.

(106.) See What Happened at the Bataclan!, BBC News (Dec. 9, 2015), http:// www.bbc.com/news/world-europe-34827497 (detailing events during terror attack at concert hall). Some concertgoers were able to escape the gunmen, but other were held hostage until the police were able to break in. Id.

(107.) See Ralph Ellis & Steve Almasly, Terror attack kills scores in Nice, France, Hollande says, CNN (Jul. 15, 2016), https://www.cnn.com/2016/07/14/europe/nicefrance-truck/index.html (highlighting key events of Bastille Day attack). See also Jared Maslin, Why France Has Become the Number One Target for Terror, Time (Jul. 15, 2016), http://time.com/4407810/nice-attack-france-target-jihadists-terrorism/ (detailing recent terror attacks in France).

(108.) See Maslin, supra note 107 (discussing reasons for terror attacks). Social tensions are high and there is a long history of discrimination within the Muslim community of France. Id. See Karimi, supra note 101 (theorizing motives behind terror attacks). A CIA operative indicated that there are many disenfranchised communities, which breed terrorists. Id.

(109.) See Simon, supra note 3 (listing timeline of Europe's anti-terror laws); see Ruth Green, UK counter-terrorism watchdog says European laws are up to scratch, Int'l Bar Ass'n (Mar. 26, 2016), http://www.ibanet.org/Article/Detail.aspx7ArticleU id=7945fc3a-ca9c-4063-975c-dfb8ed761c2b (theorizing Europe keeping up with terrorism threats). See generally Onyanga-Omara, supra note 83 (listing frequency of terror attacks).

(110.) See Counter-Terrorism and Security Act 2015, pt. 1 (U.K.) (enacting laws to protect United Kingdom from terrorists). The law creates greater restrictions on those suspected of terrorism from moving in and out of the United Kingdom. Id. See Matthew Holhouse, Counter-terrorism Bill: What it Contains, The Telegraph (Nov. 26, 2014), http://www.telegraph.co.Uk/news/worldnews/islamic-state/11254950/Count er-terrorism-Bill-What-it-contains.html (stating laws some of toughest in world against terrorism).

(111.) See Holehouse, supra note 110 (attempting to restrict borders). See also Counter-Terrorism and Security Act 2015, pt. 5, ch. 1 Sec. 29 (encouraging U.K. members to prevent people from joining terrorist groups). The Prevent Guidance is part of the Counter-Terrorism and Security Act of 2015 and requires "authorities to have due regard to the need to prevent people from being drawn into terrorism. This is also know[n] as the Prevent duty." Id.

(112.) See Alan Travis, What's in Theresa May's New Anti-Terror Package?, The Guardian (Jun. 7, 2017), https://www.theguardian.com/uk-news/2017/jun/06/anti-ter ror-options-tpims-tagging-mass-surveillance (explaining measures May seeks to implement). May stated that "[i]f human rights gets in the way of doing these things, we will change those laws to make sure we can do them." Id. Her plans include restricting movements of terrorists as well as deportation and longer prison sentences. Id. See Paul Waugh, Theresa May Signals Tougher Anti-Terror Laws As She Says 'Enough Is Enough' After London Bridge Attack, Huffington Post (Jun. 4, 2017), http://www.huffingtonpost.co.uk/entry/theresa-may-enough-is-enough-signals-new-an ti-terror-laws-despite-election-campaign-suspension_uk_5933da41e4b0c242ca24d6bc (explaining four-point response to London Bridge attack).

(113.) See Alex Hunt & Brian Wheeler, Brexit: All You Need to Know About the UK Leaving the EU, BBC (Oct. 2, 2016), http://www.bbc.com/news/uk-politics-32810887 (detailing Brexit vote and its consequences). In order to leave the European Union, the United Kingdom has to invoke Article 50 of the Lisbon Treaty. Id. The European Union and the United Kingdom then have two years to negotiate terms regarding the exit. Id. See also Data Team, A Background Guide to "Brexit" from the European Union, The Economist (Feb. 24, 2016), https://www.economist. com/blogs/graphicdetail/2016/02/graphics-britain-s-referendum-eu-membership (detailing Brexit background); Stephen Castle, Article 50: Reviewing the Road Map for 'Brexit, N.Y. Times (Nov. 3, 2016), http://www.nytimes.com/2016/11/04/world/europe/ what-is-article-50-brexit-k.html?rref=collection%2Fnewseventcollection%2Fbritainbrexit-european- union&action=click&contentCollection=Europe&region=stream& module=stream_unit&version=latest&contentPlacement=37&pgtype=collection&_r =0 (explaining Article 50 process). See also Stephen Castle & Steven Erlangler, In 'Brexit' Speech, Theresa May Outlines Clean Break for U.K., N.Y. Times (Jan. 17, 2017), https://www.nytimes.com/2017/01/17/world/europe/brexit-theresa-may-uk-eu. html?_r=0 (detailing plans to implement Brexit). Theresa May, Britain's Prime Minister has indicated that the United Kingdom will no longer be part of the European Union's single market after it has left the European Union. Castle & Erlangler, supra.

(114.) See Kim Hjelmgaard & Gregg Zoroya, Exploding U.K. Immigration Helped Drive UK 'Brexit' Vote, USA Today (June 28, 2016), http://www.usatoday.com/story/ news/world/ 2016/06/28/exploding-uk-immigration-helped-drive-brexit-vote/86424670/ (detailing immigration's role in vote); Brexit and Immigration: Raising the Drawbridge, The Economist (Aug. 27, 2016), http://www.economist.com/ news/britain/ 21705870-hopes-cost-free-cut-european-union-migration-are-illusory-raising-drawbridge (detailing hopes of United Kingdom with curbed immigration). There are currently 3.5 million E.U. immigrants in the United Kingdom that need to be discussed. Brexit and Immigration, supra. Most "tend to be young, employed and taxpaying." Id. See Alan Travis, The Leave Campaign Made Three Key Promises--Are They Keeping Them?, The Guardian (Jun. 27, 2016), https://www.theguardian.com/politics/ 2016/jun/27/eu-referendum-reality-check-leave-campaign-promises (examining Leave campaign promises). The campaign promised money given to the European Union would instead be given to NHS, immigration will be cut and there would be an immigration "free-for-all," if the United Kingdom stayed in the European Union. Id. See Michael Hiltzik, In Britain, anxiety about immigration started long before the 'Brexit' vote, L.A. Times (Jun. 29, 2016), http://www.latimes.com/ world/europe/la-fg-britain-immigration-0629-snap- story.html (examining background of European Union immigration policies in United Kingdom).

(115.) See Hjelmgaard et al., supra note 114 (indicating United Kingdom's hesitancy over immigration). As part of the European Union, the United Kingdom has seen its immigration level rise in recent years because of European Union immigration laws. Id. United Kingdom citizens worried that their jobs would be taken away and that immigrants would not assimilate. Id. See generally EU Citizenship--Statistics on Cross Border Activities, Eurostat (last visited Apr. 15, 2017), http:// ec.europa.eu/eurostat/statistics-explained/index.php/Archive:EU_citizenship_-_statis tics_on_cross-border_activities (breaking down European Union workforce). The data indicated that "[i]n nine Member States the majority of employed foreign citizens were citizens of other EU Member States...." Id.

(116.) See Alanna Petroff & Ivana Kottasova, Brexit Triggered: 5 Huge Obstacles to an Amicable Divorce, CNN Money (Mar. 29, 2017), http://money.cnn.com/2017/03/ 29/news/ economy/brexit-article-50-uk-eu-deal-obstacles/ (listing issues United Kingdom could face during Brexit divorce). The cost of Brexit will be extremely high. Id. It is unclear if migrant workers from other E.U. Member States will be allowed to remain and work. Id. See also Nathan Kitto, 'Uncertainty' and Article 50--What do SMEs Need Out of Brexitl, Business News (Wales) (Mar. 28, 2017), http://businessnewswales.com/uncertainty-article-50- smes-need-brexit/ (explaining uncertainty caused by Brexit). The uncertainty regarding the structure of trade deals has left many European businesses waiting for the negotiations to begin. Id. See generally Jon Stone, Brexit: Britain Must Stay in European Court of Human Rights If It Wants a Trade Deal, Brussels to Insist, The Independent (Dec. 7, 2017), http://www.independent.co.uk/news/uk/pohtics/brexit- human-rights-european-court-echr-leave-after-the- resa-may-tories-european-parliament-eu-a8096546.html (indicating requirements of European Union parliament). A leaked motion indicates that in order for the European Union to move forward in trade negotiation with the United Kingdom, they must agree to remain a part of the European Court of Human Rights. Id.

(117.) See The Economist, supra note 114 (indicating curbing migration may cause economic damage); Jason Burke, Brexit and Terrorism: EU Immigration is Not the Main Danger, The Guardian (Mar. 24, 2016), https://www.theguardian.com/uknews/2016/mar/24/post-brexit-immigration- controls-stop-uk-isis-attcks (theorizing threat from terrorist may be from within United Kingdom); Clark Mindock, What The Brexit Means For ISIS: US, EU Terrorism Battle Against Islamic State After UK Vote Could Be Strained, Int'l Business Times (Jun. 24, 2016), http://www.ibtimes.com/ what-brexit-means-isis-us-eu-terrorism-battle-against-islamic-state-after-uk-vote-2386 430 (noting leaving European Union may leave United Kingdom open to terror attacks). Many in the United Kingdom are fearful immigrants may harm their country. Mindock, supra. See Adam Taylor, What Will Happen Now That Britain Has Voted to Leave the E.U., Wash. Post (Jun. 24, 2016) https://www.washingtonpost.com/news/ world views/wp/2016/06/23/what-actually-happens-if-britain-votes-to-leave-the-e-u/ ?utm_term=.F1871209f238 (theorizing effects of leaving European Union). Leaving the European Union is an unprecedented move and as such, much of the process and results are still uncertain. Id. Many issues will need to be ironed out before the process is completed. Id. See Andrew Grice, Brexit: What happens if the UK leaves the EU?, The Independent (Jun. 21, 2016), http://www.independent.co.uk/news/uk/ politics/brexit-what-will-happen-eu-referendum-vote-leave-how-will-it-affect-me-a709 4096.html (listing potential effects of leaving European Union). See also James Slack, EU Workers Will Get a Visa Only if they have a Skilled Job--Post-Brexit Regime Would Slash Immigration by 100,000, Daily Mail (Oct. 16, 2016), http:// www.dailymail.co.uk/news/article-3839154/EU-workers-visa-skilled-job.html (indicating potential change in workforce); Zoe Wood, UK Labour Shortages Reported as EU Workers Numbers Fall, The Guardian (Feb. 13, 2017), https://www.theguardian. com/politics/2017/feb/13/uk-labour-shortages-brexit-as-eu-worker-numbers-fall (indicating difficulty in filling jobs with less European Union workers post-Brexit). Various industries within the United Kingdom are facing challenges hiring new workers as a result of less migration from other European Union countries. Wood, supra.

(118.) See Paddy Dinham, French far-right leader Marine Le Pen promises an Islamic crackdown and a 'Frexit' referendum as she launches her bid to be President, Daily Mail (Sept. 4, 2016), http://www.dailymail.co.uk/news/article-3773018/MarineLe-Pen-promises-Frexit-referendum- Islamic-crackdown-launches-bid-President.html (detailing France's possible exit from European Union). The leading platform of Marine La Pen's candidacy for French presidency was that of national sovereignty and immigration. Id. She proposed following the United Kingdom out of the European Union to achieve these goals. Id. See Steven Erlanger & Kimiko De Freytas-Tamura, E.U. Faces Its Next Big Test as France's Election Looms, N.Y. Times (Dec. 16, 2016), http://www.nytimes.com/2016/12/17/world/ europe/european-union-france-frexitmarine-le-pen.html (discussion crucial European elections); Nick Squires, More countries could follow UK out of the EU, says German finance ministry, as European leaders warn radical reform is needed, The Telegraph (Jun. 25, 2016), http://www. telegraph.co.uk/news/2016/06/25/european-leaders-fear-brexit-vote-could-herald-eucollapse-unles/ (indicating other countries contemplating exiting European Union). See also Allan Hall, Now Far-Right demands 'Dexit' poll for Deutschland . . . but referendums are banned because HITLER abused polls and claimed Dachau Jews supported him, Daily Mail (Jun. 28, 2016), http://www.dailymail.co.uk/news/article-36 63863/Now-Far-Right-demands-Dexit-poll-Deutschland-referendums-banned-HIT LER-abused-polls-claimed-Jews-supported-Dachau.html (stating German's call for referendum). Many Germans are demanding a referendum to leave the European Union. Id. PEGIDA support a proposed exit from the European Union. Id. See also The Conversations, Britain is Leaving the EU--Will Other Countries Follow?, U.S. News (Jun. 24, 2016), http://www.usnews.com /news/articles/2016-06-24/britainis-leaving-the-eu-will-other- countries-follow (theorizing effect of other countries leaving European Union); Bob Pisani, What Happens If France Leaves the EU, CNBC (Feb. 6, 2017), http://www.cnbc.com/2017/02/06/what-happens-if-france-leaves-theeu.html (detailing effects France leaving European Union could have). Countries leaving the European Union would hurt the Euro as other countries reintroduce their own currencies. Pisani, supra.

(119.) See Alison Smale, German Court Rules Antiterrorism Laws Partly Unconstitutional, N.Y. Times (Apr. 20, 2016), http://www.nytimes.com/2016/04/21/world/europe/germany-court-antiterrorism-laws- surveillance.html?_r=0 (overruling surveillance law to protect citizens' privacy); Jenny Gesley, Germany: New Anti-Terrorism Legislation Entered Into Force, Law Library of Congress (Jul. 10, 2015), https://www.loc.gov/ law/foreign-news/article/germany-new-anti-terrorism-legislationentered-into-force/ (listing revisions to German anti-terror laws).

(120.) See Strafgesetzbuch [StGB] [Penal Code], [section] 129a translation at https:// www.gesetze-im-internet.de/englisch_stgb/englisch_stgb.html (Ger.) (expanding antiterrorist financing laws). An offense against the state would include "collecting, accepting or providing not unsubstantial assets for the purpose of its commission." Id. See Gesley, supra note 119 (detailing penal code revisions).

(121.) See Justin Huggler, Dual Nationals Who Fight For Terror Groups to Be Stripped of German Citizenship, The Telegraph (Berlin) (Aug. 11, 2016), http:// www.telegraph.co. uk/news/2016/08/ll/dual-nationaIs-who-fight-for-terror-groups-tobe-stripped-of-ger/ (explaining stripping of German citizenship); Nikolaj Nielsen, Germany Proposes New Anti-Terror Laws, EU Observer (Aug. 12, 2016), https:// euobserver.com/migration/134631 (explaining new proposal for stricter anti-terror laws). Many of these laws are being proposed in an attempt to make Germany safer immediately following two more terror attacks. Nielsen, supra.

(122.) See Atika Shubert, German anti-migrant protest: 'We don't want to be strangers in our own country,' CNN (Oct. 20, 2015), http://www.cnn.com/2015/10/19/world/ dresden-protests-against-immigrants/ (explaining history of (PEGIDA)).

(123.) See id. (arguing PEGIDA should not be compared to Nazis). The protests started out small and grew to the current weekly protest of thousands. Id.

(124.) See Jefferson Chase, AfD, What You Need to Know About Germany's FarRight Party, T3UTCHE WELLE (Sept. 24, 2017), http://www.dw.com/en/afd-whatyou-need-to-know-about-germanys-far-right-party/a- 37208199 (describing Alternative for Germany party). Alternative for Germany party (AfD) opposes current German Chancellor Angela Merkel's open door policy regarding refugees. Id. Their views partially overlap with PEGIDA, especially in regards to immigration, but unlike PEGIDA, they are their own political party. Id. Kate Connolly, German election: Merkel wins fourth term but far-right AfD surges to third. The Guardian (Sept. 24, 2017), https://www.the guardian.com/world/2017/sep/24/angela-merkel-fourth-termfar-right-afd-third-german-election (covering results of German 2017 election).

(125.) See The Schengen Area and Cooperation, Eur-Lex, available at: http://eurlex.europa.eu/legal- content/EN/TXT/?uri=CURISERV%3A133020 (last visited Jan. 1, 201) (chronicling changes in Schengen Agreement). "The Schengen area represents a territory where the free movement of persons is guaranteed." Id. The area includes most E.U. Member States, however the United Kingdom opted out of participating. Id. See also Schengen: Controversial EU free movement deal explained, BBC News (Apr. 24, 2016), http://www.bbc.com/news/world-europe-13194723 (explaining history of agreement); L.G., Why the Schengen agreement might be under threat, The Economist (Aug. 24, 2015) http://www.economist.com/blogs/economist-explains/ 2015/08/economist-explains-18 (detailing current issues with Schengen Agreement). See also Catharine Hamm, Schengen Agreement: Understand the 90/180 Rule Before European Travel, L.A. Times (March 30, 2015), http://www.latimes.com/travel/deals/ la-tr-spot-20150329-story.html (simplifying Schengen agreement for travelers); Eric Maurice, EU and Switzerland Agree on Free Movement, EU Observer (Dec. 22, 3016), https://euobserver.com/justice/136398 (indicating potential effect of restricted movement across countries).

(126.) See Stacy Meichtry & Noemie Bisserbe, France Proposes Constitution Change After Terror Attacks, Wall St. J. (Dec. 23, 2015), http://www.wsj.com/articles /france-moves-to-shield-emergency-measures-from-legal-challenge-1450873849 (suggesting France needs more protection from terrorists). Following the Charlie Hebdo and Bataclan attacks, President Francois Holland indicated he would be pushing for stronger anti-terror laws. Id. Claude Moniquet, Viewpoint: New anti-terror approach needed after France train attack, BBC (Aug. 23, 2015), http://www.bbc.com/news/ world-europe-34032781 (discussing issues with current French terror laws). Recent attacks have exposed the problems with the current counter-terrorism laws and strategies. Id. The issues include not being able to properly monitor communication among those who have the potential to be radicalized and the sheer amount of those already radicalized. Id.

(127.) See Breeden, supra note 4 (detailing expanded state of emergency powers in France). The state of emergency extension allows authorities to raid without warrants and place "suspects under house arrest without prior judicial authorization." Id.

(128.) See id. (explaining new surveillance powers). Some are worried that these broad powers "go well beyond fighting terrorism." Id.

(129.) See Alessandria Masi, France And Britain's Coordinated Counterterrorism Strategy Against ISIS In Iraq And Syria Leaves Unanswered Questions, Int'l Business Times (Nov. 23, 2015), http://www.ibtimes.com/france-britains-coordinatedcounterterrorism-strategy-against-isis-iraq- syria-leaves-2196371 (noting European countries worry about their security more). France and the United Kingdom have announced a joint response against terrorists. Id.

(130.) See Jeff Stein, Why French Counterterrorism Efforts Are Too Much, Too Late, Newsweek (Jul. 15, 2016), http://www.newsweek.com/france-isis-terrorism-attacks-nice-bastille-day-truck-mohamed- lahouaiej-480963 (opining French terror laws are too strong). The new laws may be hurting immigrants from former French colonies who were already unhappy with French laws. Id. Radicalization appears to be increasing in immigrants of North African descent after the implementation of these laws. Id. See also UN blasts France over 'excessive' anti-terrorism measures, France 24 (Jan. 20, 2016), http://www.france24.com/en/20160119-un-blasts-france-over-excessive-anti-terror-measures (reporting United Nation's response to France's surveillance laws); Steven Erlanger and Kimiko De Freytas-Tamura, As France and Belgium Strengthen Security, a Classic Debate Arises, N.Y. Times (Nov. 19, 2015), http://www. nytimes.com/2015/11/20/world/europe/as-france-and-belgium-strengthen-security-aclassic-debate-arises.html?_r=l (stating difficulties of balancing civil liberties and safety); Aurelien Breeder) & Jeffrey Marcus, France Weighs Limits of Liberty, Equality and Citizenship, N.Y. Times (Mar. 30, 2016), http://www.nytimes.com/interactive/ 2016/02/16/world/europe/france-constitution-new-laws.html?_r=l (comparing proposed civil liberties limitations to other countries).

(131.) See Mathieu Vaillancourt, Anti-terror laws are challenging the founding principles of the French Republic, The Independent (Jan. 26, 2016), http://www.independent.co.uk/voices/frances-anti-terror-laws- are-challenging-the-countrys-governing- principles-a6834776.html (theorizing France heading down authoritarian path); Lisa Louis, France takes anti-terror legislation to next level, Deutsche Welle (Oct. 18, 2017), http://www.dw.com/en/france-takes-anti-terror-legislation-to-next-level/a40884936 (detailing additional measures passed by French Parliament). Parliament passed new laws, allowing some of the pieces of the state of emergency legislation to become permanent law. Louis, supra. There have again been cries that France has taken "a further step toward a repressive state based on general suspicion." (quoting Laurence Blisson, secretary-general of the Magistrates Union). Id.

(132.) See Onyanga-Omara, supra note 83 (detailing frequency of terror attacks); Polden, supra note 93 (listing terror attacks in Germany); Breeden et al., supra note 130 (detailing potential restrictions). The French government has sought to amend their Constitution in order to fight terrorism in the country. Breeden et al., supra. Those against the amendments note that "these surveillance powers go well beyond fighting terrorism, and that extraordinary measures undertaken during the state of emergency are slipping into common practice." Id. See also Smale, supra note 119 (overruling unconstitutional laws). The court found that civil liberties outweighed safety concerns. Id. Citizens, however, are increasingly worried about their borders and terror threats. Id.

(133.) See Henning, supra note 47 (detailing human rights issues). While safety is important, the Court of Human Rights will still need to monitor civil liberties. Id. at 1296. See also Human Rights Watch, supra note 47 (discussing human rights report on anti-terror laws). In their report, the Human Rights Watch found the majority of laws passed in response to September 11th "opened the door to abuse." Id. See also Vaillancourt, supra note 131 (indicating loss of French values). "[W]e risk seeing elementary rights of the people--liberty of association, the right to a fair trial--being compromised.... Id. See also Louis, supra note (noting laws could be harmful to citizens). Laurence Blisson, secretary-general of the Magistrates Union, has indicated that people who are accused of crimes under these new laws may have difficulty defending themselves and can be stigmatized as a result. Id.

(134.) See Strafgesetzbuches, supra note 3 (increasing penalties for terrorists). See also Stein, supra note 130 (noting harsher laws may have led to radicalization); Vaillaincourt, supra note 131 (theorizing result of temporary anti-terror laws becoming permanent). If certain laws passed in the name of safety in France are made permanent, it will be going down a path toward an authoritarian state. Vaillaincourt, supra. See also supra note 13 and accompanying text (explaining harsh laws imposed by various governments).

(135.) See supra notes 14-15 and accompanying text (detailing Nuremberg laws); supra notes 25-26 and accompanying text (detailing Japanese internment).

(136.) See E.O. 9066, supra note 24(authorizing evacuation zones); Des Jardin, supra note 22 (reasoning real decision for relocation). The government indicated that the Japanese were moved for their own good; however, it appeared to be to protect the United States and was a move mostly based out of prejudice and fear. Des Jardin, supra. See also The Holocaust Encyclopedia, supra note 14 (enacting law protecting Germans' purity); Nazi Party, supra note 20 (promoting "German nationalism and anti-Semitism"). Hitler indicated that the German economic problems would be resolved "if the communists and Jews were driven from the nation." Nazi Party, supra.

(137.) See Solhtalab, supra note 16 (detailing Jewish exclusion from economy). The author noted that "many German Jews were removed from their jobs, banned from business associations, had their shops boycotted to discourage sales, and ultimately excluded from their professions." Id. at iii. The Jewish people were faced with "financial destitution." Id. at iv. See also Masumoto, supra note 28 (stating many Japanese-Americans forced to abandon farming). See also Kaplan, supra note 18, at 229-231 (discussing repercussion of Nazi Germany). "After the November Pogrom almost all German Jews tried desperately to flee, realizing that there was no future for any Jew in Germany." Id. at 231. In 1943, Berlin was declared "free of Jews." Id. at 232.

(138.) See Simon, supra note 3 (listing steps Europe has taken to increase security); supra Part II.B and accompanying text (detailing effects of strong laws against certain groups). See also supra note 13 (examining harsh laws).

(139.) See Picardo, supra note 5 (indicating difficulty predicting economic reaction to terror). There will likely be both short-term and long-term effects that businesses and the economy will need to manage. Id. See also Global Terrorism Index, supra note 5, at 64 (indicating costs governments have spent on anti-terror legislation).

(140.) See supra Part III.B (detailing anti-terror legislation proposed and enacted).

(141.) See Larobina et al., supra note 5, at 152 (indicating security has not yet been top priority). Based on current data, the cost of security at businesses as a result of terror has easily been absorbed. Id. Data however, on the actual costs is sparse because it is generally private. Id. See also Perry, supra note 66 at 47 (discussing vulnerability of businesses). Corporations with a "worldwide footprint" need to be prepared for disruption to their businesses at any of their locations. Id.

(142.) See European Ch. for Small Enterprises, supra note 79 (promoting growth for SMEs). SMEs are seen as "the driving force for innovation and job creation in Europe." Id. The government indicated "ten pathways" for SMEs to continue to grow. Id. See also Small Bus. Act for Eur., supra note 79 (attempting to remove barriers promoting development); UEAPME, supra note 79 (describing objectives of UEAPME). Main objectives of UEAPME include:
   Monitoring the EU policy and legislative process and keeping its
   members informed on all matters of European Union policy of
   relevance to crafts, trades and SMEs; Representing and promoting
   the interests, needs and opinions of its member organisations to
   the EU institutions and other international organisations;
   Supporting its members academically, technically and legally on all
   areas of EU policy; Supporting its members academically,
   technically and legally on all areas of EU policy


UEAPME, supra. The UEAPME is working hard to promote SMEs and ensure that they have a voice in policy and are not forgotten. Id. See generally Abel-Koch et al., supra note 74, at 13 (discussing decline in SME innovation).

(143.) See Prosser, supra note 82 (demonstrating importance of immigrant to small business). A study was done indicating that "one in seven companies trading in the UK was originally set up by an immigrant." Id. Additionally, "[i]n the small and medium-size enterprise community, immigrant-founded companies created 14 per cent of all jobs." Id.

(144.) See Hunt et al., supra note 113 (detailing Brexit). The United Kingdom is the first sovereign to leave the European Union and will have to go through the steps of Article 50, which could potentially prove difficult. Id. See also Castle, supra note 113 (briefing steps to Brexit). No country has yet employed Article 50 and in fact, it was not expected to be used by any country. Id. All negotiations to exit the European Union must be completed within two years after its been invoked. Id.

(145.) See Dinham, supra note 118 (noting France has contemplated leaving European Union). Marine Le Pen, who ran for the French presidency used leaving the European Union as one of her biggest campaign platforms. Id. She stated "I will do it in France," in regards to a potential 'Frexit.'" Id. See also Squires, supra note 118 (listing other countries contemplating leaving European Union). "France, the Netherlands, Austria, Finland and Hungary could all follow Britain out of the European Union...." Id.

(146.) See European Union, supra note 6 (explaining structure of European Union). Twenty-eight countries make up the European Union and they share certain aspects of government, each while having their own separately run governments. Id. See also CNBC, supra note 116 (losing France would hurt European Union). As more countries continue to exit the European Union, the structure would be weakened, particularly the Euro. Id.

(147.) See EU Market Rules, supra note 79 (detailing structure of European Union single market). The countries that make up the European Union, its Member States, all function using one central market made of all the countries. Id. Trade deals are structured with the European Union as a whole and not with the individual Member States that it is made up of. Id. See also Castle et al., supra note 113 (detailing United Kingdom's "clean break" from European Union). In leaving the European Union, the United Kingdom will also be leaving its single market and thus will be faced with a lengthy process of renegotiating terms of deals with both the European Union and other countries through the world. Id.

(148.) See Taylor, supra note 117 (indicating new trade deals necessary). It is still not clear how Britain will structure any of their deals with the European Union. See also Grice, supra note 117 (indicating time frame for United Kingdom trade deals). If the European Union requests a new trade deal with the United Kingdom, it might not be completed until 2021. Id. See generally Stone, supra note 116 (indicated roadblocks to trade deals). If the European Parliament follows through with its motion to disallow any new trade deals with the United Kingdom, if the United Kingdom does not guarantee it will stay within the jurisdiction of the European Court of Human Rights, Theresa May could have trouble achieving her goals, as promised. Id. The European Parliament itself is not involved in Brexit negotiation; however, it does hold veto power on any future deals. Id.

(149.) See supra Part.II.C (illustrating effects of terrorism and anti-terror laws on various business industries). See also Johnson et al., supra note 60, at 4 (noting effects of global terrorism). Falling confidence, which "can reduce the incentive to spend as opposed to save" can also trickle into the economy. See also Pizam et al., supra note 63, at 125 (explaining tourists' demand affected by terror). Even if tourists aren't likely to be affected directly by terrorism and the risk is small; tourists still take note. Id. A study noted that tourism levels are usually affected after terror attacks, but there may be as long as a six to nine month period after the occurrences. Id. See also Gee, supra note 62 (fearing lasting effects of attacks). Joe Kaeser, chief executive at Siemens stated that "[t]he biggest economic damage from these attacks is on confidence, and confidence is a crucial element in this phase." Id.

(150.) See Alderman, supra note 63 (stating tourists considering cancelling trips after frequent attacks). With more frequent attacks, "visitors are rethinking Europe as a central travel destination." Id. It is uncertain if the travel levels will rise again. Id. See also Suder, supra note 63, at 160 (dissecting tourist behavior after attacks). After September 11th, consumers changed the destination they were going to, choosing to visit places that they deemed safer. Id.

(151.) See LaGrave, supra note 65 (detailing traditional effects of terror attacks). The average time period for an area to recover after a terrorist attack is roughly thirteen months. Id. The number of occurrences factors into the recovery time. Id. See also Alderman, supra note 63 (indicating questions about safety of Europe). Tourists have questioned whether traveling to Europe is still a safe option following sustained attacks. Id. See also Liautaud et al., supra note 63 (discussing effects of repatriated attacks in France). Demand appears to decrease slightly after each attack. Id. See also Gee, supra note 62 (reporting on tourists' response to French attacks). See also Suder, supra note 63, at 168 (discussing perception of safety). It was noted that "[a] destination that is perceived to be unsafe or lacking in security measures will ultimately decline." Id.

(152.) See Alderman, supra note 63 (noting uncertainty of safety). Michael Sapin, France's finance minister stated. "[b]ut today, the frequency of attacks is creating a new situation of uncertainty, with economic consequences." Id. See also Chrisafis, supra note 102 (theorizing effect of terror incident). The fact that there was a terror attack outside the Louvre, a popular tourism destination, could hurt the already reeling French tourism sector. Id. See also Breeden et al., supra note 4 (explaining French police and surveillance authority). Those suspected of terrorism can be detained "up to 144 hours without charges." Id. See also Stein, supra note 130 (stating increased security and stronger laws). The extension of state of emergency in France allowed the government to put "10,000 soldiers on the streets...." Id.

(153.) See Sandler et al., supra note 60, at 24 (explaining types of attacks causing significant drop). "[G]iven the low intensity of most terrorist campaigns, the economic consequences are generally very modest and short-lived." Id. at 29-30. See also Suder, supra note 63, at 121 (discussing factors that influence markets). Some argue that a downturn in the market is to be expected as a natural part of a business cycle; however, terrorism is a factor that needs to be considered. Id. at 121-122.

(154.) See Johnson et al., supra note 60, at 8 (noting impact of extreme events on financial markets). Demand falls when there is a lack of investor confidence. Id. at 4. The markets can be directly affected as victims of the attack, as they were on September 11th, when there were direct attacks to the trading infrastructure and communication systems of several large banks. Id. at 5. See also Bremmer, supra note 60 (detailing effects of politics on investments). The political climate of a country can be a good indication as to potential market instability. Id. See also Larobina et al., supra note 5, at 147 (discussing investor trends). Studies have shown that "[w]hen information becomes available about a cataclysmic event like a terrorist or a military attack investors often flee the market in search safer financial instrument and panic selling ensues." Id.

(155.) See Wagner, supra note 60 (stating Norway's slow stock market recovery). It was noted that "[o]ther financial markets were not as resilient. For example, over the 11-day period following 9/11, Norway's stock market dropped 25 percent and took 107 days to recover." Id. See also Johnson et al., supra note 60, at 6 (indicating contagion effects of attacks). It was shown "that in the aftermath of both terrorist attacks investor confidence deteriorated beyond the national boundaries because of contagion effects." Id.

(156.) See Ross, supra note 5 (noting effects of unstable markets). "The real threat of global terrorism from an investor's perspective is about the broader picture, not individual incidents." Id. See also Investopedia, supra note 62 (indicating how investors may react to unstable markets). "[Institutional investors will reduce their holdings in stocks considered unsafe...." Id.

(157.) See Mazzarella, supra note 66, at 71 (concluding multinational corporations must continue to deal with negative effects of terror attacks). See also Larobina, et al., supra note 5 (detailing past costs of terror attacks). Factors that influence costs include "the diverse nature of terrorism, the economic resilience of an economy and security levels." Id.

(158.) See Mazzarella, supra note 66, at 60 (identifying costs of security to prevent attacks). There are both fixed costs and variable costs to consider in regards to terror attacks. Id. See also Yoon, supra note 67 (indicating costs not included in study). The Institute for Economics and Peace determined that the cost of terrorism in 2015 was the highest since 2001, but did not include costs for things such as "number of security guards, higher insurance premiums, or city gridlock...." Id. See also Sandler et al., supra note 60, at 2 (discussing higher cost of doing business because of terrorism); Gee, supra note 62 (detailing issues for corporations). The President of the Franco-British Chamber of Commerce in Paris, Bob Lewis, theorized that "[t]he biggest problem for large corporations will be security. There will be reductions in travel and more investment in digital. What we have is a security crisis that will change how everyone works." Gee, supra.

(159.) See Marsh, supra note 48, at 15 (indicating how companies deal with global terror attacks); Michel-Kerjan et al., supra note 54 (detailing terror insurance in various countries). The requirements of insurance to cover terrorism vary in different countries. Kerjan et al., supra note 54. See GAREAT, supra note 54 (providing terror insurance to French territories); Pool Re, supra note 53 (describing terror insurance offered in United Kingdom); Perry, supra note 66, at 55 (indicating companies need for terrorism insurance). The insurance necessary to protect their business is often either not available or comes at a high price. Perry, supra, at 55.

(160.) See Marsh, supra note 48, at 5 (defining terror attack); Mazzarella supra note 66, at 68 (indicating insurance may not cover all types of terror acts). "Generally, underwriters claim that terrorism is an 'uncertainty' rather than an actual quantifiable risk." Mazzarella, supra, at 68. Due to the uncertainty of terrorism and other geopolitical disruption factors, international businesses bear the costs of political risk insurance. Id. See also GAREAT, supra note 54 (defining "act of terror"). "When they are performed intentionally in relation with an individual or collective enterprise for the purpose of seriously disturbing public order by intimidation or terror, by 'acts of terrorism' is meant the infringements...." Id.

(161.) See Mazzarella, supra note 66, at 65 (noting companies may choose non "high-risk" areas for production); JLT Group, supra note 76 (allowing use of multiple work sites). Julia Graham indicated, "[i]f a company with multiple sites in the UK loses one, it is terrible but it's not going to put it out of business. But if a company with one site gets knocked out, then it might." JLT Group, supra.

(162.) See Mazzarella, supra note 66, at 66 (indicating limiting expatriates could impede corporations' growth). When a company shies away from either employing expatriates or sending them to certain areas could create an "isolationist orientation" and hinder growth. Id. See also Slack, supra note 117 (explaining revised visa scheme). In the revised visa system in the United Kingdom, only skilled workers will be allotted visas. Id. A study noted that "[s]eventy per cent of EU migrants to the UK come here to work or to seek work. Eighty per cent of EU workers who have arrived in the past ten years are in low-skilled employment." Id.

(163.) See Economist, supra note 114 (indicating millions of migrants outside home country); Free Movement of EU Citizens, supra note 6 (indicating European Union citizens have free movement between countries). Additional conditions apply for those working in other countries. Free Movement of EU Citizens, supra. See also Schengen area, supra note 125 (explaining movement between countries); Eurostat Stat., supra note 115 (noting travel and work between Member States). "13.6 million E.U. citizens live in an E.U. Member-State other than their country of citizenship." Eurostat Stat., supra. "A majority of foreign workers are citizens of another E.U. country in nine Member States." Id.

(164.) See Slack, supra note 117 (detailing possible shift in workforce). Only skilled workers will be granted visas to the United Kingdom. Id. See Hiltzik, supra note 114 (theorizing new rule would alter European Union immigration). There will be new processes to apply for visas and it is estimated that "as much as 90% of the existing EU immigrant workforce" would not meet the proposed standard. Id. See Wood, supra note 117 (indicating workers leaving United Kingdom for home countries).

(165.) See JLT Group, supra note 76 (indicating resources not available as frequently as for SMEs); Sullivan-Taylor et al., supra note 75, at 4 (stating fundamental differences between large and small firms). SMEs do not have the same resources and often do not have plans in place to deal with extreme events. Sullivan-Taylor et al., supra note 75, at 4. See Nikolaeva et al., supra note 77 (differentiating small businesses' ability to cope with terror attacks). Pool Re executive, Julian Enozi stated, "Often it is small business which suffers most post a terrorism event as the reliance on access of customers to their business places them under huge pressure." Id. See Perry, supra note 66, at 58 (noting small businesses do not have same resources as larger companies). Large corporations have a greater ability to spend money on additional security measures. Id.

(166.) See Economist, supra note 114 (stating certain areas of labor may be hurt with immigration limitations). Certain industries, such as farming, hospitality, and food processing rely on immigrant labor. Id. Companies would be "forced to adapt their business models." Id. See also Free Movement of EU Citizens, supra note 6 (allowing free movement of European Union citizens); Schengen area, supra note 125 (listing Schengen Agreement framework); L.G., supra note 125 (allowing for border restrictions due to national security); Kitto, supra note 116 (examining Brexit's effect on SMEs).

(167.) See also L.G., supra note 125 (noting effects of limiting Schengen Agreement). There have been studies indicating the Schengen agreement has promoted trade partnerships between countries, increased imports and exports, and attracted tourists. Id.

(168.) See Edinburgh Group, supra note 82, at 8 (discussing employment at SMEs). A large portion of employment growth can be attributed to SMEs. Id. See European Economics and Social Committee, supra note 74 (stressing importance of SMEs to economies). SMEs are the "backbone" of the economy. Id. See Ross, supra note 5 (indicating effects of closing down borders). Limiting immigration "reduces the size and diversity of economic transactions and limits productive resources." Id. See Jaruzelski et al., supra note 82 (theorizing potential effects of limited immigration for innovation).

(169.) See Lobel, supra note 81 (emphasizing importance of trade to SMEs). Europe is an important trading location for SMEs. Id. See E.U. Market Rules, supra note 79 (indicating single market act assists movement of goods for SMEs); Taylor, supra note 117 (explaining necessity of new trade deals for United Kingdom). The process of negotiating new agreements will be lengthy and potentially complicated. Taylor, supra. See also Kitto, supra note 116 (indicating disruption Brexit may cause for SMEs). Many trade agreements with the United Kingdom are currently in flux. Id. Some of these agreements have the potential to make or break SMEs. Id.

(170.) See Wood, supra note 117 (explaining challenges faced with limited labor force). Immediately following the Brexit vote, the United Kingdom found itself with a shortage of workers. Id. A study found that one in four E.U. workers considered leaving either their job or the United Kingdom. Id. See also Maurice, supra note 125 (discussing negative impact of limiting free movement); Ross, supra note 5 (listing effects of closing borders). It is important for the economy to not exclusively rely on internal workers. Ross, supra.

(171.) See generally European Charter for Small Enterprise, supra note 79 (promoting stimulation of SMEs); UEAPME, supra note 79 (establishing organization aimed at assisting SMEs); The EU and Small Business, supra note 74 (detailing ways to assist SMEs). The European Union has tried to assist SMEs with the implementation of the Small Business Act; however, they need additional help to sustain their growth. The EU and Small Business, supra.

(172.) See Roach, supra note 1 (examining responses to September 11th); Simon, supra note 3 (providing details of Europe's anti-terror responses); supra Part II.B (enacting legislation as reaction to September 11th).

(173.) See supra Part III.A (detailing recent terror attacks); supra Part III.B (enacting legislation in response to frequent terror attacks).

(174.) See The European Union Counter-Terrorism Strategy, supra note 40 (detailing European Union's commitment to upholding human rights amid new legislation); supra note 47 and accompanying text (indicating potential clash with human rights); Breeden, supra note 130 (examining effects of France's anti-terror laws). See also supra Part IV.A (listing potential effects of terrorism and related legislation on businesses).

(175.) See Larobina, et al., supra note 5 (explaining terror attacks' impacts on various industries). See also supra Part IV.B.l (indicating governments should be wary of too much restriction). See also supra note 13 (citing various countries' harsh laws).
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