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Difference Between France and the United States Counterterrorism Policies Compare and Contrast Essay

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Updated: Dec 23rd, 2019


In the international fight in opposition to transnational terrorism, the European Union and the US are natural associates. However, cultural, bureaucratic, and differences in tactics are a threat to progress. Because of the Middle East situation in the 1980’s, France, one of the EU nations, found itself being the international terrorism target (Friedrichs 58).

Additionally, due to the Algeria’s Islamic Armed Group in the 1990’s, as well as from the year 2001 in regard to the international movements of jihadists’ connected or inspired by Al Qaida, France has not overcome terrorism.

The US on the other hand, has had to deal with terrorism after several attacks aimed at the country. This essay, therefore, aims at looking at different ways of fighting terrorism amid France one of the EU countries, and the United States, and the reason they chose the policies.

General Comparison between the two

Though fraternity, equality and liberty seem to appear to be the same to France and America, these two countries seem to have unlike notions of the same. The differences are also noted in the way they seem to combat homegrown terrorism. This is due to difference in legal systems, histories, and state conceptions. France started to fight terrorism from the year 1789.

It all started when a citizen of French whose parents emanated from Algeria, Merah, who was by then 23 years, claimed to be a member of Al-Qaida (Friedrichs 66). This is after he murdered seven people, something, which made France have a fierce debate concerning whether the security services as well as the police failed to recognize him in time.

Judgment and intelligence being what France depend on merely, the French had many questions regarding this wondering whether ‘the more expensive and automated reliance of the American style on computerized phone calls monitoring, and the internet, might have identified him more easily’(Corum 123). Of course, there remains no answer to that question,

In the United States, what seems to count is the system, while in France what seems to count is the men. After 9/11, every country with a Muslim population that was tiny, and most of all well integrated, had enormous computer time, money, and work force thrown in by the Americans into what they termed, “the terrorism global war” (Friedmann 299).

This was also meant to track people at home who seemed to be potential terrorists. On the other hand, with its colonial history, France has, for much longer, dealt with terrorism. Many Muslims have their originalities from Europe. Thus, France aims at curbing terrorists’ enrollment.

With most of the Muslims coming from areas that are more close to North Africa and Middle East, they tend to prevent these recruitments through a habitual mosques infiltration, as well as radical networks of Islam.

Contrasting to Americas automated telephone tapping and inspection, France seems to deal with terrorism in a much different way (Friedrichs 68). This is partially due to their history and partially due to limited budgets. This has made France thereby to depend more on human resources, local intelligence, and human contacts.

Moreover, France happens to be more centralized. They established the antiterrorist struggle coordination unit in 1984. In the Justice Ministry, they as well attempted something comparable (Bassiouni 385).

The intelligence France law that was governing by then got a reformation in 1986 with subsequent reforms on 1995 and 2001. It was reformed once more in the year 2006. In 2008, the Domestic Intelligence Central Directorate was founded. This is from the Intelligence Services and the Interior Ministry amalgamation. They were responsible for the state police, the counterespionage, and counterterrorism (Friedmann 299).

Furthermore, in the U S, counterterrorism is decentralized. This comes with its own complications. There are legendary tensions amidst the Central Intelligence Agency, the Federal Bureau of Investigations, and state or local agencies (Friedrichs 71).

This is especially amidst the Police Department of New York and the F.B.I. This seems different to France, which has just two police forces that are both national hence the agencies have less rivalry.

The French, legally too, have in a single court centralized cases related to terrorism. They have also attempted to reintegrate processes that fight terrorism into ordinary law. This is with more terrorism investigations flexibility, acting where suspicious, ordering surveillance or wiretaps, as well as holding suspected persons for a time, which is much longer (Bassiouni 387).

The United States has not yet reconciled the way forward in terrorism fighting. For instance, they had a difficulty while trying to shut down the Guantanamo Bay detention center. In addition, they did not know whether to hold military tribunals or criminal trials for detainees such as Khalid Sheikh Mohammed.

Moreover, despite both the US and France having counterterrorism strategies in place, the strategies differ in numerous ways. The US seems to embrace a four D system (Corum 179). This strategy involves:

  • Defeat global reach of terrorist organizations;
  • Deny terrorists further support, sponsorship, and sanctuary;
  • Diminish exploitable conditions by terrorists;
  • Defend their motherland, and broaden defenses overseas.

France’s Counterterrorism strategy as well encompasses four critical constituents that are triple P, and one R (Bassiouni 390). They include:

  • Prevent by looking into core causes, people becoming terrorists;
  • Protect the infrastructure, and its inhabitants;
  • Pursue terrorists, investigate them as well as make them face the law;
  • Respond or prepare by managing and minimizing attack consequences.

U.S Approach

As Erlanger identifies, only three words can be used to define the American strategy of dealing with terrorism: proactive, external, and war.Terrorism fight to the US is seen as “war”. The statement “America is at war” is what the National Security Strategy kicks off with whenever it is addressing the issue.

As a result, in disrupting networks of the terrorists, the armed forces, and the Defense Department have put in a heavy contribution. To the US, the war against Al-Qaida is not as the same as that amid nations, they refer to it as conventional military conflict. To them, the group is an actor, that is non-state, and hence it is an armed conflict (Corum 180).

Secondly, an emphasis by the US approach is placed on the external. The Al Qaida network, which is by nature extraterritorial to the US, made the country view it as an external threat. As a result, the consistent US approach has been to face the enemy directly by “taking the fight” to them, and pushing the borders out (Friedrichs 85).

The US seems to be consistent with this approach of “forward defense” since the Cold War ended. Thus, their counterterrorism strategy is aimed at reaching out to, outside Europe, as well as to other parts of the world including Russia, Pakistan, Philippines, China, Australia, and India.

The Container Security Initiative developed by the US, had the logic of reaching out for improvement of port security, prior to potential threats reaching American shores (Friedmann 301). The mechanism search was motivated by a similar basis. This is with airline passengers’ respect for using information of the Passenger Name Record to perform security checks.

Third, the US has engaged a proactive approach. When one looks from the perspective of the institution, the Department of Homeland Security along with major Intelligence Community were implemented for the country to get prepared in cases of threats in the future. The country launched the Proliferation Security Initiative in May 2003 in order for a more proactive, creative, and dynamic approach to be created.

This was in order to prevent propagation to, or from proliferation concern nations, as well as actors of non-state (Bassiouni 392). The initiative also explains the reason the US has, in the Middle East, promoted democracy and reform, is to identify that democratic and economic opportunities are required to contradict radicalized ideologies.

France Approach

The French Approach of dealing with terrorism is mainly crime, reactive and internal. According to France, terrorism is not a military, but a criminal act. Their strategy requires for the criminalization of terrorists by the legislation. Erlanger acknowledges that, for legislations like that, the main instruments are “framework decisions”.

The Home Affairs and Third Pillar of Justice is where counterterrorism falls, as compared to trade and economic legislation, where the significant power lies within the European commission. The national ministers are the ones who make framework decisions where the rule is unanimity. A reflection of a domestic flavor of criminal law is noted on one of Frances’ counterterrorism strategy, “pursue”.

Whilst France is working hard to pursue, disrupt and dismantle terrorist networks, the impression that EU fosters to the US terrorist dialogue engagement or a Third Party agreement clause is enough to make those by use of catastrophic terrorism, that wish to impose mass casualties, stop (Friedrichs 85).

Second, compared to the US, which externally counter fights terrorism, France focuses on the internal. Counterterrorism lead agencies are the justice and interior ministries, but not the defense ministries. The justice and interior ministers enact France counterterrorism policies. They, together with their respective services of intelligence mainly do disruption of terrorist networks (Corum 215).

Counterterrorism has had minimal direct connection with the ESDP (European Security and Defense Policy). The emphasis of ESDP lies on reconstruction and stabilization of regional conflict, rule-of-law, peacekeeping, and humanitarian missions. The notion that France military workers would be deployed to guard France has in the France capital, little resonance. This is for both political and historical reasons.

The interest of France is to protect its critical infrastructure, and pursue policies to perform the same (Bassiouni 394). For the EU to oversee management of external border, guard training of national border, member states operations and technicalities assistance, as well as risk analysis it created FRONTEX, Management of External Borders Agency (Bassiouni 397).

Finally, France counterterrorism approach can be looked at as reactive. As Erlanger identifies, this is because after every attack, they engage in very furious activity. Then a slowdown follows as sovereignty and politics submerge their implementation.

The primary reason why France and the EU in general have made progress is the actual shock or attempted terrorism attacks. The ones that are noted most are the 2004 Madrid bombings, the 9/11 attacks, the 2005 London bombings, and the UK plot in August 2006 (Friedrichs 87).


From the essay above, it is clear that France and the U.S differ widely in the way they look at terrorism, and hence the way they fight it. The US look at terrorism as “war”, and hence the reason they engage their military to fight the “enemy”.

This is different with France who view terrorism as a crime hence treats it as a criminal activity. Thus, their policies and way of fighting it differ in that while the US engage in war with the terrorists, France looks for ways of engaging with them, and having a talk with them, hence stop any recruitments bound to happen.

Works Cited

Bassiouni, M C. Legal Responses to International Terrorism: U.S. Procedural Aspects. Dordrecht: M. Nijhoff, 1988. Print.

Corum, James S. Fighting the War on Terror: A Counterinsurgency Strategy. St. Paul, Minn: Zenith Press, 2007. Print.

Erlanger, Steven. Fighting Terrorism, French Style. The New York Times. 30 March 2012. Web. <>.

Friedmann, Robert R. A Diary of Four Years of Terrorism and Anti-Semitism 2000-2004: Volume Ii. Lincoln, NE: iUniverse, 2005. Print.

Friedrichs, Jörg. Fighting Terrorism and Drugs: Europe and International Police Cooperation. London: Routledge, 2008. Print.

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