Thank you for asking that, actually, because it's very interesting. One of the members commented that security certificates are used in Europe. In fact, returns, under the immigration laws, yes, are made in Europe, and in France there have been a number of them.
You may have heard of radical Islamist imams preaching certain things in certain mosques having vulnerable immigration status and being deported, and then in some of those instances, even after having been deported, lodging an appeal in either a French court or, for example, with the Committee against Torture or with the European Court of Human Rights. So it is a feature of the human rights and immigration landscape and counter-terrorism landscape in Europe that almost every single western European country--and we just had a case in Slovakia--is attempting to deport or expel or otherwise transfer people who they suspect of having committed either offensive acts of speech or who may have been associated or alleged to be associated with terrorist activity.
Deportation, in some ways, is now very quickly becoming the tool of choice over prosecution. In Germany, it's very much the same thing. You may have heard of the case of Metin Kaplan, who is a radical Islamic imam who was extradited to Turkey. Deportations and returns, stripping of refugee status--I would say it's fairly well established in most of the west European countries that this is an acceptable counter-terrorism tool.
I might just add, however, that in one recent case that was just cited this year, the case of man named Adel Tebourski, who was sent back from France to Tunisia, I believe it was, the Committee against Torture ruled that France did violate his article 3 rights, that he was in fact at risk of torture.
So we do have slowly building, because this has happened mainly in the last couple of years, some jurisprudence that is saying that European governments themselves are violating the non-refoulement obligations by using immigration laws to send people back to places where they will be unsafe.