JUSTICE - No. 68

17 Summer 2022 Intolerance (ECRI), among others. Its decision-making body is the Committee of Ministers of its 47 Member states or their permanent diplomatic representatives in Strasbourg. ECRI, which advises Member states on human rights matters, published a revised “General Policy Recommendation (GPR) No. 9” on preventing and combating antisemitism in 2021. This three-part document outlines ECRI’s mandate and obligations in Part I. The rationale and context for updating the original 2004 recommendation appears in Part II, and this includes a description of contemporary antisemitism. This part also notes the increasing harassment of Jewish women, the surge in Holocaust distortion and the move to online antisemitism. Part III presents 52 recommendations (“Recommendation”) to guide Member states’ responses. A stand-alone opinion supporting the use of the IHRA Working Definition had been published in December 2020, and now forms an appendix to the Recommendation. Primarily intended for governments, but also of relevance to civil society, the GPR will be among the tools used to evaluate government efforts to tackle antisemitism and other forms of racism and intolerance, during the five-yearly country inspections undertaken by ECRI.13 PACE convenes quarterly to advise governments on Council of Europe initiatives and provide guidelines for Member state governments and parliaments on human rights issues. Like the European Parliament, PACE also indirectly affects the lives of European citizens. In 2007 and 2016, it agreed on resolutions condemning antisemitism and it is engaged in formulating a third set, scheduled for publication in June 2022. This will move beyond analysis and condemnation, and it is expected to request Member states to take concrete action against antisemitism.14 The European Court of Human Rights rules on individual or state applications on human rights, as set out in the European Convention on Human Rights. Its decisions are binding on Member states. Its case law makes the Convention a living instrument for meeting new challenges and consolidating the rule of law and democracy in Europe. Over the years, it has ruled on several important cases involving antisemitism, e.g., Holocaust denial, and religious and racial incitement. Recent cases include Kilin v. Russia (May 11, 2021), where the Court held that the applicant, who had been convicted of posting racist and neo-Nazi video and audio files to an online social network, had not had his freedom of expression rights violated under Article 10 of the Convention.15 UNESCO The United Nations Educational, Scientific and Cultural Organization (UNESCO) notes that Antisemitism is a security issue for Jewish communities and individuals across the world and the driving force of a range of extremist ideologies… In recent years, the changing geopolitical climate and media environment have led to a situation where open antisemitism is no longer confined to extremist circles and has become increasingly mainstreamed.16 Together with the OSCE, UNESCO published a policy guide, “Addressing Anti-Semitism through Education - Guidelines for Policymakers,” in May 2018. During 2019 and 2021, together with the World Jewish Congress, it organized capacity-building workshops and regional and training conferences for policymakers and educators.17 To support teachers and school directors in addressing antisemitism in schools, UNESCO and OSCE/ODIHR published in November 2020 a set of four framework curricula for teacher trainers entitled “Addressing Anti13. “ECRI revised General Policy Recommendation No.9 on preventing and combating Antisemitism,” Council of Europe (July 1, 2021), available at https://www.coe.int/ en/web/european-commission-against-racism-andintolerance/recommendation-no.9 14. Combating anti-Semitism in Europe, Resolution 1563, Parliamentary Assembly of the Council of Europe, June 27, 2007, available at http://www.assembly.coe.int/nw/ xml/XRef/Xref-XML2HTML-en.asp?fileid=17561&lang=en; Renewed commitment in the fight against antisemitism in Europe, Resolution 2106, Parliamentary Assembly of the Council of Europe, April 20, 2016, available at http:// assembly.coe.int/nw/xml/XRef/Xref-XML2HTML-en. asp?fileid=22716 15. “Factsheet - Hate speech,” European Court of Human Rights, p. 22 (Jan. 2022), available at https://www.echr. coe.int/documents/fs_hate_speech_eng.pdf 16. “Addressing antisemitism through education” (UNESCO), available at https://en.unesco.org/preventing-violentextremism/education/antisemitism 17. “Addressing antisemitism through education: guidelines for policy makers” (UNESCO and OSCE, 2018), available at https://unesdoc.unesco.org/ark:/48223/pf0000263702_ eng