Meijers Committee standing committee of experts on international immigration, refugee and criminal law 4. Practice in four EU Member States and the UK Between 1998 and 2020, the provision on déchéance de nationalité in Article 25 of the French Code Civile was applied to 14 naturalised citizens after a criminal conviction for terrorist activities. Seven withdrawals occurred before 2007; none during the Sarkozy presidency (2007-2012); five in 2015 and one in 2019.39 The 2015 cases concerned five French citizens, four also having Moroccan and one also having Turkish nationality. These cases resulted in the Ghoumid judgment of the ECtHR in 2020.40 A 2016 proposal by president Hollande to expand the possibilities for withdrawal in relation to terrorism was unsuccessful (see paragraph 5). In Belgium, during the decade before the 2015 amendment of the nationality law, less than 10 naturalised Belgian citizens were deprived of the Belgian nationality after a criminal conviction for terrorist acts.41 The deprivation provision introduced in 201542 was applied during its first years in a few cases only, one concerning the leader of the Sharia4Belgium organisation. In 2019 13 naturalised Belgian citizens were deprived of that nationality after a conviction for terrorist crimes.43 Between April 2016 and November 2019 the Dutch minister of Justice withdrew the Dutch nationality of seven persons after a final criminal conviction for terrorist activities.44 Four of these persons returned to the country of their other nationality, three of them pending their appeal against the withdrawal decision.45 Between September 2017 and July 2020, the minister withdrew the Dutch nationality of another 24 persons on the ground of having participated in a terrorist organisation, for which a final criminal conviction is not required. The decisions in these cases were based either on a criminal conviction in absentia or on information of the national intelligence agency (AIVD).46 On the same day, they were declared to be undesirable aliens, which made future presence in the Netherlands a serious criminal offence. All 24 ex-Dutch nationals were outside the Netherlands at the time the decision was made. On the basis of their family names it is assumed that all 24 were Dutch nationals of immigrant origin; 18 were born in the Netherlands, five in Morocco and one in Iraq.47 In the 2017 coalition agreement between the CDU/SCU and the SPD in Germany it was agreed that a new rule on deprivation of nationality on the ground of active participation in fighting by a terrorist organisation abroad would be introduced. The relevant provision entered into force in November 2019, six months after Islamic State lost its final territory near the border 39 Le Monde 24 October 2019. ECtHR 25 June 2020, app.no. 52273/16, Ghoumid and others/France. 41 Estimate by Patrick Wautelet in Belga News 29 January 2015. 42 P. Wautelet, ‘Deprivation of citizenship for ‘jihadists’. Analysis of Belgian and French practice and policies of the principle of equal treatment’, in: P. Kruiniger (ed.), Jihad, Islam en Recht. Jihadisme en reacties vanuit het Nederlandse en Belgische recht, RIMO Vol. 30, 2017, p. 49-74. 43 Minister of Justice Koens in the Parliamentary Commission for Justice on 11 March 2020, https://www.dekamer.be/doc/CCRI/html/55/ic136x.html. 44 Art. 14 (2)(b) Rijkswet op het Nederlanderschap. 45 TK 29 754, nr. 528, letter of the Minister of Justice and Security of 1 November 2019. 46 Art. 14 (4) RWN Rijkswet op het Nederlanderschap. 47 Notices in the official journal Staatscourant. 40 8