The September 11, 2001 terrorist attacks on the United States and the subsequent attacks on European countries such as the United Kingdom and Spain have prompted both sides of the Atlantic to reinvigorate their respective efforts to ensure homeland security and combat terrorism. However, U.S. and European approaches to these issues differ. While the United States has embarked on a wholesale reorganization of its domestic security and border protection institutions, European countries have largely preferred to work within their existing institutional architectures to combat terrorism and respond to other security challenges and disasters, both natural and man-made. This report examines homeland security and counterterrorist measures in six selected European countries: Belgium, France, Germany, Italy, Spain, and the United Kingdom. None of these European countries currently has a single ministry or department equivalent to the U.S. Department of Homeland Security. In most of these countries, responsibility for different aspects of homeland security and counterterrorism is scattered across several ministries, and inter-governmental cooperation plays a key role in addressing threats and challenges to domestic security. In some countries, such as the UK, Germany, and Belgium, responsibility for homeland security affairs is also split among federal and regional or state governments. The approaches of many European countries to protecting their publics and infrastructure have grown out of decades of experience in dealing with domestic terrorist groups, such as the IRA in the UK, the Basque terrorist movement ETA in Spain, or the anarchist Red Army Faction in Germany. Even after the terrorist attacks of the last few years, European countries have continued to view combating terrorism primarily as a task for law enforcement and intelligence authorities. Some critics suggest that many European countries have been slow to bolster domestic protection efforts, reduce societal vulnerabilities, strengthen border controls and transport security, and push the defense of European territory as far out as possible. Others contend that European governments have sought to integrate counterterrorism and preparedness programs into existing emergency management efforts, thereby providing greater flexibility to respond to a wide range of security challenges with often limited personnel and financial resources. European parliamentary systems influence government decisions regarding homeland security policy and budgetary priorities. In the UK, for example, the government has a parliamentary majority and as a result, the government's proposed budgetary levels are not usually contested in the same way as they often are in the United States. A strong executive in France largely directs homeland security efforts with minimal parliamentary oversight. Spending priorities in the different countries vary, but most have devoted increased funds over the last several years to intelligence and law enforcement efforts against terrorism. Funding for measures to strengthen transport security, improve emergency preparedness and response, counter chem-bio incidents, and protect critical national infrastructure are more difficult to determine and compare among the countries, given that responsibility for these various issues is often spread among the budgets of different government ministries. All of the countries discussed in this report are members of the European Union (EU), which in the years since September 11 has sought to boost police and judicial cooperation among its 25 member states, bolster external border controls, and harmonize immigration and asylum policies. Some analysts believe, however, that the EU should take a more active role in ensuring European homeland security, given the EU's largely open borders and the accession of central European countries that border less stable regions such as the Balkans. They also argue that more extensive EU efforts to coordinate homeland security affairs would help bring order and greater coherence to the myriad of government institutions engaged in protecting domestic security within each EU member state, and encourage common security and budgetary priorities among all members. Some have proposed that the EU should establish at a minimum a "homeland security czar" similar to its recently appointed counterterrorism coordinator. Other experts are skeptical that member states would be willing to cede greater sovereignty to the Union in the area of domestic security, which is central to national authority. Similar to the United States, European countries are also struggling to find the appropriate balance between measures to improve security and respect civil liberties. In the UK, there has been vigorous debate on such issues. Germany, Spain, and Italy have traditionally guarded civil liberties strongly in light of their histories with authoritarian regimes, but recent terrorist activity has prompted greater discussion of strengthening measures to ensure domestic security. While France has long championed civil liberties such as free speech and freedom of religion, French society also emphasizes the need for public order and has taken steps to enhance security since September 11. Some U.S. policymakers and Members of Congress are taking an increasing interest in how European countries are organizing and managing homeland security issues and emergency preparedness and response, in light of both recent terrorist activity and Hurricane Katrina, which devastated the U.S. Gulf Coast in August 2005. In seeking to protect U.S. interests at home and abroad, many U.S. officials recognize that the actions or inaction of the European allies can affect U.S. domestic security, especially given the U.S. Visa Waiver Program, which allows nationals of many European states to travel to the United States without a visa or other checks on their identities. Some experts suggest that greater U.S.-European cooperation in the field of homeland security is necessary in order to better guarantee security on both sides of the Atlantic. After the terrorist attacks of 9/11, an American official characterized Belgium's political will to cooperate in the global war on terrorism as "fairly strong," chiefly because it is linked to Belgium's self-interest: the Belgians do not want any terrorist activity to occur on their territory. Because the European Union (EU) and NATO are headquartered in their country, the Belgians are sensitized to the terrorist threat but they are said to be anxious over whether they have sufficient resources to protect personnel at the two institutions. Some analysts believe that the Belgians' ability to deliver on their promises is at times somewhat challenged, and that any type of domestic "coordination" is problematic in Belgium's federated system of government, in which policies must navigate the shoals of several levels of government and three official languages. In addition, Belgium's domestic political dynamics act as something of a constraint on cooperation; the ethnic mistrust between the Dutch-speaking Flemings and the French-speaking Walloons complicates matters. Finally, some observers believe that Brussels tends to place a great deal of emphasis on process, and, as a result, the government is slow and bureaucratic. Belgium showed early leadership in coordinating international counterterrorist activities. At the time of the September 11 attacks, Belgium held the revolving presidency of the European Union. Shortly thereafter, police and anti-terrorist officials from Germany, the Netherlands, and France met with their Belgian counterparts in Brussels to discuss efforts to share information and coordinate counterterrorist strategy. In addition, Belgium pushed within the Union for acceptance of EU-wide fast-track extradition procedures for serious crimes. Like other EU countries, however, Belgium has refused to deport suspected terrorists to countries where they might face the death penalty. In 1987, Belgium and the United States signed a bilateral extradition treaty. A mutual legal assistance treaty signed the following year expedites communications by permitting requests to bypass standard diplomatic channels and be made directly between the U.S. Department of Justice and the Belgian Ministry of Justice. Extraditions may now be sought using a "provisional arrest request pending extradition," and are conducted in accordance with a Mutual Legal Assistance Treaty signed in January 2004. In June 2002, the U.S. and Belgian governments initialed an agreement permitting U.S. Customs agents to be stationed in the seaport of Antwerp, where they work with Belgian officials to screen freight containers to be loaded on vessels bound for the United States. The accord is part of the Bush Administration's Container Security Initiative (CSI), under which foreign ports are checked to prevent shipment to the United States of weapons of mass destruction. However, Belgium's laws on security-related matters have proved controversial in the past. For example, the two suicide bombers who assassinated former Afghan Northern Alliance leader Ahmed Shah Massoud on September 9, 2001, were found to be carrying Belgian passports. Until 1998, Belgian passports were issued by municipal officials, and an estimated 3,500 passports were stolen annually from poorly-guarded city halls. After the United States applied pressure, even indicating that it might begin requiring visas for Belgians, the country centralized its passport issuance process. In 2004, Belgium became the first country to introduce biometric-based electronic passports; the new travel documents are compliant with both U.S. and EU requirements. In addition, in 2001, an article in the Wall Street Journal criticized Belgium for having "some of the weakest antiterrorism laws in the European Union[,] ... making it popular among terrorists as a place to hide out and plan attacks." Citing Belgian sources, the article maintained that, because Belgium had not suffered directly from terrorist acts in the recent past, Brussels had largely relegated the terrorism issue to a back burner in the 1980s. In an editorial, the newspaper singled out Belgium as "simply the only country whose elected officials have failed to ensure that the bureaucracy does not provide an obstruction to broader interests." Belgium has since taken steps to address some of these issues. In 2003, the legislature passed the Terrorist Offence Act, which amended the criminal code by introducing definitions relating to terrorism, and spelling out punishment for belonging to or aiding terrorist groups. In 2004, Belgium passed a law addressing the financing of terrorism, and the following year approved legislation creating the legal framework for special anti-terrorist investigations. Belgium's approach to homeland security is less unified than that which was adopted after 9/11 by the United States; it has no counterpart to the U.S. Department of Homeland Security.