European States’ Obligations to Repatriate the Children Detained in Camps in Northeast Syria representatives located nearby, and NGOs active on the ground to effectively carry out repatriation. 107 The international and European human rights standards cited in this briefing paper should be assessed together with States’ obligations under international criminal law and international counter-terrorism laws. Arguably, the failure to repatriate the detained children and their caregivers in northeast Syria goes against the principle of international cooperation in combating terrorism108 and undermines States’ ability to fulfill their obligation to investigate and prosecute international crimes and/or terrorist offenses.109 Extraterritorial Jurisdiction of European States in Syria The application of human rights obligations is dependent on States’ jurisdiction.110 Under European and international human rights law, jurisdiction is primarily territorial111—but not exclusively so. States’ jurisdiction can be exercised extra-territorially under three models: a) the spatial model, conceived as a State’s effective control over territory; 112 b) the personal model, which considers States’ authority or control over an individual outside the States’ own territory;113 and, more recently, c) the 107 UNHCR guidance on voluntary repatriation addressing the duty of country of origin to take affirmative action towards making this right actionable should be also used by analogy: e.g. dialogue between the major parties must be established at the earliest possible stage, and return must be orderly and in safety and dignity. See: UNHCR, Discussion Note on Protection Aspects of Voluntary Repatriation, EC/1992/SCP/CRP.3, 1 April 1992; para. 8(c) and 8(d); UNHCR, Handbook - Voluntary Repatriation: International Protection, January 1996, 2.6 Responsibilities of the Country of Origin.” 108 UNSC, “Resolution 2178 (2014) on Threats to International Peace and Security Caused by Foreign Terrorist Fighters”, S/RES/2178 (2014), 24 September 2014, para. 11-14. UNSC, “Twenty-Third Report of the Analytical Support and Sanctions Monitoring Team Submitted Pursuant to Resolution 2368 (2017) Concerning ISIL (Da’esh), Al-Qaida and Associated Individuals and Entities,” S/2019/50, 15 January 2019, para. 93. 109 PACE, “Withdrawing Nationality as a Measure to Combat Terrorism: A Human-Rights Compatible Approach?”, Resolution 2263 (2019), para. 8. 110 International Covenant on Civil and Political Rights ( “ICCPR”), Article 2; CRC, Article 2; Convention Against Torture ( “CAT”), Article 2; ECtHR, Article 1. 111 ECtHR, “Bankovic et al v. Belgium,” Application No. 52207/99, 12 December 2001, para. 59-61. 112 ECtHR, “Bankovic et al v. Belgium,” para. 70; ECtHR, “Ilașcu et al v Moldova and Russia,” Application No. 48787/99, 8 July 2004, para. 314-316; ECtHR, “Loizidou v. Turkey,” Application No. 15318/89, para. 52; See also: Human Rights Committee ( “HRComm”), “General Comment No. 31, The Nature of the General Legal Obligation Imposed on States Parties to the ICCPR,” CCPR/C/21/Rev.1/Add.13, 26 May 2004, para. 10. 113 ECtHR, “Al Skeini and others v. UK,” Application No. 55721/07, para. 131-140; HRComm, “General Comment No. 31, The Nature of the General Legal Obligation Imposed on States Parties to the ICCPR,,” para. 10. 22