The presence of Islam in Italy has more than 13 centuries of history, beginning with the June 827 landing on the Sicilian coast by Arab forces led by Asad ibn al-Furat and the subsequent conquest of large parts of today's southern Italy. This first phase of Islamic history in Italy came to a close between the end of 12th and the beginning of 13th century, as popular insurrections, Norman troops, and Frederick II forced the Arabs out of the region. The second phase in Islam's history within Italy began in the 1980s, with the unprecedented influx of Muslim immigrants in the country.
Immigration itself is a new phenomenon in Italy. In the first three decades after World War II, when most other European countries were receiving thousands of extra-European immigrants, Italy was still a country of emigration, not immigration. Only by the 1970s did Italy begin to attract small numbers of workers, coming mostly from the Philippines and Latin America. The Muslim presence was limited to the diplomatic personnel from Muslim countries, a few businessmen and some students. Those numbers increased significantly in the 1980s, when immigrants from North and Sub-Saharan Africa began to choose Italy as their initial or final destination in their migration to Europe. Immigration has peaked since the mid-1990s, and, according to Italy's official census bureau (ISTAT), as of December 2006 there were 2,670,514 foreign citizens residing in Italy.1 While no exact data on the number of Muslims living in Italy exist, most estimates put their number at around 1 million, corresponding to almost 2% of the population.2
An analysis of the data available leads us to some observations on the Muslim community in Italy in comparison to that of other European countries. Firstly, most European countries received the bulk of their immigrant Muslim population from countries with which they had strong historical ties. North Africans (particularly Algerians) constitute the majority of Muslim immigrants in France, as do Pakistani and Indian Muslims in Great Britain and Turks in Germany. Italy's Muslim community, on the other hand, possesses a significant diversity in the countries of origin of its members, and most of them come from countries with no historical ties to Italy. Only a small percentage of Muslims living in Italy, in fact, come from former Italian colonies in the Muslim world (Libya, Somalia, and Eritrea). The two countries that have contributed the largest number of Muslim immigrants to Italy are Morocco (28.5%) and Albania (20.5%).3 Most other Muslims living in Italy come from Tunisia, Senegal, Egypt, Bangladesh, Pakistan, Algeria, Bosnia and Nigeria, contributing to the image of an extremely diverse community. Only in the sectarian aspect is Italy's Muslim community quite homogeneous, since 98% of it is Sunni.4
Equally typical of the Italian experience of Muslim immigration in comparison with that of other European countries are the higher number of non-citizens and irregular immigrants, the higher percentage of men, and the higher level of geographic dispersion.5 Italian citizenship laws are very strict and, while obtaining workand residency permits is not very difficult, in many cases even immigrants who have lived in the country for decades cannot obtain Italian citizenship. A 2001 study suggested that only 10,000 Muslims living in Italy had Italian citizenship.6 Large numbers of immigrants—Muslim and non-Muslim alike—live in Italy illegally, often employed in the country's large submerged economy. The situation might change in the near future, as more Muslims marry Italian citizens and if and when one of the many proposals to change citizenship laws is adopted. In any case, many point to the difficulty of obtaining Italian citizenship as an obstacle to better integration into Italian society.
Since immigration is a recent phenomenon and laws allowing legal residents to bring their spouses into the country have been passed only over the last few years, most immigrants are still first-generation. While this is true for all immigrant groups, Muslim immigration presents another peculiar characteristic in its composition. Unlike most other groups, the number of Muslim men living in Italy is significantly higher than that of Muslim women, as there are 227 men for every 100 women.7 This characteristic is markedly different from the reality in most other European countries, where immigration waves and family reunifications have take place for some time and, consequently, the imbalance between the number of male and females is much smaller.
Finally, another difference between the Muslim presence in Italy and that in most European countries is geographic dispersion. Since immigration in Italy began in the 1980s—when the post-industrial era had already begun and large factories were no longer hiring thousands of workers—Muslims did not concentrate in certain areas as they did in most European countries. With possibly the exception of two neighborhoods in Turin, Italy has no Muslim ghettos, which are an unfortunate reality in industrial areas such as the British Midlands or the suburbs of various French cities.
A Leaderless Community
Italy's Muslim community is conditioned by a number of factors: its relatively recent appearance in the country, its broad spectrum of the countries of origin, its small number of citizens, its high number of illegal residents, and its high geographic dispersion within Italy. All these characteristics, combined with Islam's intrinsic lack of clerical hierarchy, cause a weak internal cohesion and a poor level of organization, which reverberate in the inability to produce a unified leadership that can effectively represent the community when dealing with the Italian state, particularly at the macro level. Twenty years after the first massive wave of Muslim immigration, Italy's Muslim community is characterized by the presence of many Muslim organizations, none of which can legitimately claim to represent more than a fraction of it. Moreover, the relationships among these organizations are often characterized by sharp disagreements and even personal hatreds, leaving the country's Muslim community deprived of a unified leadership.
One of the oldest Muslim organizations in Italy is the Islamic Cultural Center in Rome, which is based out of Rome's Grand Mosque, Europe's largest. Rome's Grand Mosque is a quintessential example of institutional Islam, as it was built in over 20 years with funds coming from the governments of various Muslim countries and the ambassadors of the major contributing countries sit on the mosque's board. Positions of prominence are held by Saudi Arabia and Morocco, the two largest donors.8 Mario Scialoja, a former Italian ambassador to Saudi Arabia and a convert to Islam, plays a key role in the mosque's relations to the Italian state.9 Despite its ample means and ambitions, its geographic limitation to the Rome area and its close relation to foreign governments prevent the Grand Mosque from being a nationally representative Muslim organization.
Two smaller organizations are also aiming at becoming interlocutors of the state and representing the country's Muslim community: Coreis (Islamic Religious Community) and AMI (Italian Muslim Association). Both organizations embrace a moderate and progressive interpretation of Islam but consist of just a few members, many of them Italian converts. Even smaller is UMI (Italian Muslim Union), an organization that has often drawn the attention of Italian media for the deliberately provocative statements of its leader, Italian convert Adel Smith.10 The presence of converts at the helm of several Italian Muslim organizations is a possible consequence of the fact that only few Muslim immigrants have Italian citizenship and, consequently, many of them experience difficulties in attending to the legal and bureaucratic duties involved in heading an organization. Nevertheless, many Muslim immigrants do not feel duly represented by Italian converts and it is precisely the converts' overrepresentation that could be seen as one of reasons of the lack of legitimacy of most Muslim organizations.
A myriad of other minor entities dots the map of Italy's organized Islam. Many operate independently from any organization and act only at the local level. Others operate nationwide, such as the Moroccan Association of Italy, but can be defined Islamic only in the loose sense of the word, since they are based on ethnicity rather than religion. Sufi orders and brotherhoods also have a small presence, generally limited to small groups of Italian converts or communities such as the Senegalese or the Turkish. An array of unaffiliated makeshift mosques, often little more than garages or abandoned country houses, completes the panorama of Italian Islam.
In this fragmented scenario, where no organization can legitimately claim to represent a sizeable part of the country's Muslim population, a seemingly leading role has been taken by an Islamic revivalist organization called UCOII (Union of the Islamic Communities and Organizations of Italy). UCOII traces its origins to USMI, a small organization of Muslim students that, at the end of the 1960s, was created in Perugia and other university cities.11 Composed mostly of Jordanian, Syrian and Palestinian students, USMI was close to the positions of the Muslim Brotherhood, the Islamic revivalist movement that, from its origins in the 1920s in Egypt, has spread worldwide.12 By the second half of the 1980s, when the first massive wave of North African immigrants arrived in Italy, a student organization such as USMI could no longer satisfy the needs of the new, large Muslim population. In January 1990, representatives of USMI, six mosques from six Italian cities, and 32 individuals incorporated into UCOII.
Since its foundation, UCOII has been extremely active on the political scene, attempting to become the main, if not the only, interlocutor of the Italian state. UCOII has managed to achieve an important position within the Muslim community, thanks to its large control over Italian mosques. While its claim to control 85% of Italy's mosques is difficult to independently verify, it is undeniable that UCOII plays a predominant role in the life of Italy's practicing Muslim community and that a large number of mosques are, more or less directly, linked to it.13
UCOII has often been accused of being an extremist organization with ideological and/or organic links to the Muslim Brotherhood. Such links, sometimes proudly admitted, sometimes vehemently denied by UCOII, are not illegal per se, since the Muslim Brotherhood is not considered a terrorist organization nor is banned in Italy or in any Western country.14 Their existence is nevertheless important to better understand UCOII's actions and aims, and in order to do so it is important to briefly analyze the presence in Europe of networks related to the Muslim Brotherhood. Over the last 50 years the Muslim Brotherhood has established offshoots in various European countries that today, thanks to their activism and foreign funding, have managed to carve an important space for themselves within European Muslim communities. Revivalist organizations such as the Muslim Council of Britain (MCB) or the Union of Islamic Organizations of France (UOIF) have become the de facto representatives of the Muslim communities of their countries, controlling a large number of mosques and interacting with government institutions as preferential partners.15
Most of these organizations have severed all formal ties to the Muslim Brotherhood, which they understood could taint their reputation. When dealing with the media and governments they often show a moderate façade, publicly supporting integration and democracy. Yet, in their mosques, revivalist organizations espouse a diametrically different rhetoric, still embracing the ideology of the organization to which they trace their origins. Their aim, according to many of their critics, is the radicalization of European Muslim communities and the creation of what Israeli scholar Reuven Paz defines "non-territorial Islamic states"—separate Islamic states within the state, in which Muslims would have separate social spaces (from schools to swimming pools) and separate jurisdiction.16 Unlike other Islamist groups operating in Europe, Muslim Brotherhood-linked organizations do not resort to or advocate violence to achieve these goals, but have chosen to work within the system and the legal framework.
UCOII is the Italian branch of this informal European-wide network, adopting the same modus operandi of its counterparts in other countries. UCOII views Islam as a complete ideology, without distinction between religion and politics, private and public spheres.17 Its rhetoric is sometimes filled with encouraging statements favoring integration and tolerance, sometimes marred by endorsement of suicide bombings and strong anti-Semitism.18 As all other Brotherhood-linked organizations throughout Europe, UCOII aims at swaying the Muslim population to its strict interpretation through the activities of its capillary network of mosques. Given the lack of other structures on the Italian territory, many Muslim immigrants seeking the comfort of familiar faces, languages and smells congregate in mosques, which are often seen more as community centers rather than simply places of worship. UCOII seeks to use its virtual monopoly over mosques to spread its ideology and exercise what Italian expert on Islam Renzo Guolo has defined as a "diffuse cultural hegemony" over the country's Muslim community.19
Most Italian Muslims do not seem to share UCOII's politicized view of Islam and favor a more personal interpretation of it. According to polls, only 5 to 10% of Muslims living in Italy regularly attend Friday prayers at a mosque.20 Even though the percentage would probably be higher if there were more mosques throughout the territory, the data square with the analysis of most sociologists, who believe that the majority of Muslims living in Italy are not practicing ones. Most of them fast for Ramadan and celebrate Eid al Fitr, but are not significantly more practicing than Italian Catholics.21 Yet, taking advantage of its extreme fragmentation, UCOII has become the most visible, vocal and organized voice of Italy's Muslim community. It can be said that the control of the Italian Muslim community has been conquered by an active minority, which has easily prevailed over an unorganized silent majority.22
Criticism of UCOII is widespread in all quarters and particularly within the Muslim community. Mario Scialoja, the abovementioned former Italian ambassador to Saudi Arabia and a leader at the Rome Grand Mosque, is clear in stating what the problem with UCOII is. "Even if it is indeed so rooted in the territory," says Scialoja,"UCOII pursues the agenda of an international movement. Hence it does not represent a positive factor for the development of an Italian Islam."23 Others have called for a ban of UCOII, given its extremist positions and its support of violence against Israel. Yet, despite all the criticism, UCOII is a reality that cannot be ignored and all actors on the political scene have to interact with it in one way or another.
The Legal Recognition of Islam
The predominance of UCOII at the organizational level has strong repercussions on the relationship between the Italian state and the Muslim community and the legal recognition of Islam, a source of major political controversies. The Italian Constitution (Article 19) gives all citizens the right to freely practice and proselytize for any religion (unless its rites are deemed to be against morality). All religions are free to organize themselves and, according to Article 8, their relationship with the state is regulated by law, based on agreements signed by the state with the representatives of each religious community. The Catholic religion enjoys a separate and privileged treatment, which was negotiated by the Vatican and the Italian state in 1929 and then incorporated in the republican Constitution of 1948. In order to be recognized and receive legal and financial benefits similar to those of the Catholic religion, all other religions have to sign an agreement (known in Italian as ) with the government, which regulates mutual rights and obligations.
Over the last 25 years various religious communities (such as Jewish, Protestant and Buddhist) have done so. Even churches such as the Adventists and the Assemblies of God, which consist of only a few thousand members, have managed to sign an intesa. Islam, which is de facto the country's second religion (if not among Italian citizens, unquestionably among individuals living in the country), has not yet been recognized by the Italian state as a religion. While the opposition of some political forces to the recognition of Islam has in some cases interfered with the process, the main reason for this seemingly paradoxical situation is to be found in the lack of a unified leadership in the Italian Muslim community.
In order to sign the intesa, in fact, the Italian government needs to find a representative of the Muslim community, something the Italian Muslim community has thus far been unable to produce." Various groups have submitted intesa proposals over the years: Rome's Islamic Cultural Center did so in 1993, AMI in 1994, and Coreis in 1996. All these proposals have been rejected by various Italian governments because the proponents were not considered representative enough. While all these organizations enjoy excellent relations with Italian institutions and their drafts were considered quite reasonable, none was deemed able to legitimately claim to represent the majority of Italian Muslims.24
Conversely, the Italian state has experienced the opposite problems when dealingwith the proposals of intesa submitted by UCOII since 1990. UCOII seems to be prima facie the Muslim organization with the largest following and with characteristics the Muslim organization with the largest following and with characteristics that make it the closest of all Italian Muslim organizations to the notion of representation that Italian authorities are looking for. On the other hand, the contents of the proposals submitted by UCOII are what have stopped Italian authorities from reaching an agreement. UCOII's drafts are, in fact, quite ambitious, as they ask for the recognition of Islamic festivities, the introduction of Islamic education in public schools, the extension of legal values to weddings celebrated in mosques and the creation of "informational spaces" for Muslims on public television.25 According to its intesa drafts, the state would recognize UCOII as the sole representative of the country's Muslim community, granting it all the powers that come with the intesa. UCOII claims to be entitled to such status since it represents the vast majority of Italian Muslims and refers to its control over the majority of Italian mosques as proof of its position of predominance.
The Italian state has cited two reasons for turning down all of the intesa drafts submitted by the UCOII."26 The first is that some of the requests advanced by UCOII are incompatible with the legal framework and/or excessive. Moreover, it has understood that, if such an agreement were to be signed by the state, UCOII would achieve unchallenged power within the Muslim community. Only UCOII, for example, would choose the curriculum for the teaching of Islam in public schools, appoint imams serving in hospitals, prisons and the military, and celebrate weddings according to the Islamic rite that would have legal value. This position of virtual monopoly that UCOII would gain from such an agreement would not be accepted by minority groups within Italian Islam (such as Shia, Sufis, or Ahmadiyya), nor by all those Sunni Muslims—and they seem to be the majority—who do not share UCOII's conservative interpretation of Islam. Strong pressures on the Italian authorities to turn down UCOII's proposals have come, in fact, from various members of the Italian Muslim community and from the Muslim governments whose ambassadors sit on the board of the Rome Grand Mosque and whose ideological and political rivalry with UCOII has always been one of the main challenges to the creation of a unified Muslim leadership in Italy.27
The lack of unified leadership in the Muslim community has led Italian authorities to the conclusion that it is too early to sign an . The fragmentation and infighting have been perceived as a sign that the community is not yet mature and that the best option, despite the urgency of reaching an agreement that would regulate many aspects of Islam's presence in the country, is to wait until the community is better rooted and has proper representation.
Since 2001, given the increased attention devoted to Islam, Italian authorities have attempted to come up with new solutions. Even though the intesa was still considered premature, in 2004 then Interior Minister Giuseppe Pisanu decided to take a proactive role in favoring the creation of a unified leadership in the Muslim community. Months of intense consultations and research efforts led to the creation in late 2005 of the Consulta per l'islam italiano (Council for Italian Islam), an advising body for the Islamic faith composed of 16 members of the Muslim community selected by the Ministry of Interiors. The Consulta is supposed to research and advise the Ministry on all issues involving the Muslim community, with a stated goal of developing the dialogue between the Italian government and the Muslim community and the harmonious integration of the latter in Italian society.28 The Consulta meets when convened by the Minister of Interiors and at least three times a year, working on an agenda that is set by the Minister himself.
Aside from criticism from the Lega Nord party, which at the time was a part of the coalition government, Pisanu found little political opposition to his initiative. The major challenge he faced was in selecting the 16 members of the Consulta. Some had suggested that the members should have been elected through a voting process by Italian Muslims, following the example of the Conseil Français du Culte Musulman (CFCM), the elective body created by Nicolas Sarkozy in 2003. Pisanu instead opted for a solution similar to the Conseil de réflexion sur l'Islam en France (Corif), the body that had preceded the CFCM and that had been created by then French Minister of Interiors Pierre Joxe by appointing six known community figures.29 Pisanu so explained his decision: "I could have followed the path of the French Council. But French Islam is more consolidated, it has more than one hundred years of life. The Italian reality is still, on the other hand, very fragmented and indefinite. Islam is much more pluralistic and diverse than what we think and it does not have hierarchies, so it is difficult to find interlocutors. So I say: let us first try to get to know it, then let us find a way to make it express itself in the most democratic fashion possible."30
The 16 individuals Pisanu selected for the Consulta originally came from 12 countries, mirroring the diversity of the Italian Muslim community. Several of them are North Africans, the largest regional group in Italy, but there is also a Senegalese, a Somali and an Albanian, representing communities that traditionally have had only a small voice within Italian Islam. Four of the members are women, also a novelty in the male-dominated panorama of Italian Muslim organizations. Some of the members of the Consulta are religious and represent the so-called "Islam of the mosques." Others are representatives of the so-called "cultural Islam," secular Muslims that, even though they might occasionally frequent a mosque, believe in a firm separation of religion and politics and that Islam should not shape all aspects of their lives.
The most controversial issue faced by Pisanu in selecting the members of the Consulta was whether members of UCOII were to be included. Some of Pisanu's advisors noted that, while the organization is unquestionably one of the best represented throughout Italy, its extremist positions should disqualify UCOII from being part of a government-appointed body whose stated goal is the development of a Muslim community that respects Italian laws and national identity.31 Others pointed out that UCOII had repeatedly and publicly denounced terrorism, condemning various terrorist attacks perpetrated by al Qaeda and affiliated groups in Europe and elsewhere. On the other hand, UCOII seems to maintain that attacks carried out by Palestinians against Israel, no matter what the target, constitute legitimate resistance and not terrorism. The debate spilled from the corridors of government buildings to the editorial pages of major Italian newspapers. At the end, Pisanu decided to include UCOII's president Nour Dachan in the Consulta. Some wondered whether including UCOII in the Consulta granted undue legitimacy to an organization whose positions are contrary to Italian moral values and, possibly, Italian laws. Khaled Fouad Allam, a sociologist and an influential journalist with La Repubblica, saw UCOII's inclusion in the Consulta as a sound realpolitik move. "UCOII," said Allam, "has an important control over Italy's mosques. It's better to have them inside [the Consulta} than outside, otherwise their exclusion would have further radicalized their positions.32"
The problems generated by UCOII's inclusion in the Consulta have only grown as the body held its first meetings in 2006. On most issues the Consulta has been divided in two: on one side, generally the majority, secularists and moderates led, respectively, by the president of the Association of Moroccan Women in Italy, Souad Sbai, and COREIS vice-president Yahya Sergio Yahe Pallavicini, and on the other side conservatives led by Dachan. In February 2006, for example, the Consulta signed a document expressly recognizing Israel's right to exist, but two of its members, Dachan and Salerno-based imam Rachid Amadia, did not sign it.33 Similarly, Dachan refused to sign the so-called Charter of Values of Citizenship and Integration, a general document approved by the majority of members of the Consulta which condemned Islamic fundamentalism and stated Italian Muslims' commitment to the country's secular laws.34 According to the initial intentions of the Ministry of Interiors, those who refused to sign the document, a basic declaration based on principles taken from the Italian constitution and the Universal Declaration of Human Rights, would have been removed from the Consulta.35 No such measure has been officially taken against Dachan and Amadia, but their refusal brought the activities of the Consulta to a standstill and the body has been mostly inactive since the end of 2006.36
The intense discussions within the Consulta were probably inevitable and could be optimistically viewed as a necessary step toward the formation of an understanding among Italy's Muslim leadership. The Consulta does not have the authority to make any binding decision, but it is mostly a platform where Muslim leaders can discuss their issues and from which Italian authorities can gather suggestions. Most members of the Consulta have stated that they see the Consulta simply as the first step towards the signing of the intesa. Whether this will happen or not is to be seen. But, in any case, the Consulta can be a useful experience for Italy's Muslim community, as it can make it mature and find a way to reconcile its internal differences in order to reach some form of unified leadership, the necessary first step towards a better recognition of Islam in the country.
Nevertheless, as the Consulta faced its problems, some of its most moderate members decided to pursue separate negotiations with the Interior Ministry and create a new organization called the Federation of Italian Islam.37 In open opposition to UCOII and its refusal to sign the Charter, the Federation aims at becoming the body that will eventually sign the intesa with the Italian state.38 The Federation, which was launched in April 2008, has received substantial backing from the Italian government, which seems to have abandoned the idea of working with UCOII (despite UCOII's recent statements that it is now ready to adhere to the Charter of Values39). On the other hand, authorities still have doubts on the representativeness of the Federation, whose members have only limited clout inside Italian mosques.
The Jihadist Threat
A separate level of analysis should be devoted to the presence of jihadist activities in Italy. While attracting only a small minority of Muslims living in the country, Salafi ideology has had a relatively long history in Italy and is espoused by a growing number of mosques throughout the territory. As a virtually inevitable direct byproduct of the spread of Salafi ideology, over the last fifteen years Italian authorities have monitored and, often times, dismantled, several networks involved in terrorist activities. The majority of these cells limited their actions to providing various forms of logistical support to jihadist outfits operating throughout the world. Nevertheless, over the last few years, some dismantled networks had planned attacks inside the country, indicating Italy's shift from a convenient base of operation to a potential target.
The role of the city of Milan and of one of its mosques in the spread of Salafism and jihadism in Italy cannot be overemphasized and must be analyzed in order to understand their history in the country. The Milan area has traditionally been Italy's financial engine and, since the 1970s, has attracted a disproportionately high number of immigrants from various countries, becoming the main hub for, among other groups, Egyptian and Moroccan immigration in Italy. In 1977, a small group of Middle Eastern and North African students and immigrants affiliated with Muslim Brotherhood- linked USMI founded the Islamic Center of Milan and Lombardy, which grew progressively more active as immigration fluxes brought more Muslims to Milan.
By the mid-1980s several members of various Egyptian jihadist groups had also made their way to Milan, either receiving asylum or living illegally in the Italian city.40 Soon the men, mostly members of the Gamaa Islamiya, the notorious Egyptian terrorist organization that has killed hundreds of Egyptians and Westerners in its attempt to overthrow the country's secular government, became increasingly dissatisfied with the strain of Islam that was preached inside the Islamic Center. In 1988, with the financial support of a wealthy Milan-based Eritrean Muslim businessman, Ahmed Idris Nasreddin, the Egyptians broke with the Islamic Center and founded their own mosque inside a former garage on the northern outskirts of Milan.41 The mosque, which was incorporated as the Islamic Cultural Institute (ICI), immediately became the main headquarters for the European operations of the Gamaa.42
Unlike other European mosques, such as London's Finsbury Park, which were founded by moderates and then taken over, often with violent means, by more radical forces, the ICI was created as a jihadist mosque. The ICI focused its activities on providing false documents, safe haven, and financing to Egyptian militants as well as on spreading the group's radical ideology. From Milan, Gamaa militants kept in close contact with other Egyptian radicals in the Middle East, Europe, and even the United States, where they communicated with the group's spiritual leader, Omar Abdel Rahman (the so-called Blind Sheikh).43 The ICI became crucially important in 1992 as the conflict in Bosnia broke out. Along with the Sahabah mosque in Vienna, another major bastion of the Gamaa, the ICI became the headquarters for Muslims who wanted to fight in the Balkans.44 The Institute provided documents, money, transportation and all other forms of logistical support for Arab volunteers, while its imam—Anwar Shabaan, one of Gamaa Islamiya's most important leaders—became the commander of the Mujahideen Battalion, a paramilitary unit made up of Arab fighters that fought against Serbs and Croats.45
1995 proved to be a difficult year for the Institute. Shabaan was killed in an ambush by Croatian police and, in what was Europe's first suicide bombing, Gamaa militants attempted to retaliate for his death with a car bomb attack against a police station in the Croatian city of Rijeka (the only victim was the suicide bomber, a Milan resident of Egyptian descent).46 Moreover, the developments of a routine crime investigation led Italian authorities to focus on the Institute. An Egyptian butcher, in fact, had told authorities that individuals linked to the ICI had organized a racketeering scheme against the city's halal slaughterhouses, alleging that local Muslim butchers were forced to buy the meat from a distributor linked to the Institute, and that those who refused were threatened with arson.47 The inquiry into the ICI, which soon developed into a full-fledged counterterrorism investigation, ended with a dramatic raid on the mosque in June 1995 and the indictment of seventeen militants—only a fraction of those investigated.48 Inside the Institute, police found hundreds of false documents, radical magazines, tools for forging documents, and documents proving its ties to extremists worldwide.49
Despite these blows, the ICI continued its activities throughout the 1990s. The Institute established various businesses, which provided money and the possibility to sponsor visa applications for several radicals that were hired as employees.50 Radical preachers of global stature occasionally visited at the Institute, which kept close contact with other extremist mosques throughout Europe.51 The imams' sermons and the literature available at the Institute spread Salafi ideology to the growing number of Muslim immigrants that frequented the mosque.52 ICI militants also developed a strategy of concentric circles to expand their influence beyond Milan, setting their sights on mosques and Islamic centers in Lombardy and in other regions. Relying on their charisma and, when they found opposition, on the use of violence, ICI affiliates established or took over mosques in Lombardy cities such as Como, Cremona, Gallarate and Varese, and in other northern Italian regions (mostly Piedmont, Emilia Romagna, Veneto and Tuscany).53
While the leadership of the Institute remained Egyptian, militants from other countries began to congregate there, turning the ICI into a hub for radical networks spread throughout northern Italy. Mirroring immigration patterns, by the mid-1990s Tunisian, Algerian and Moroccan networks began to operate in Italy, generally gravitating around the ICI.54 At the end of the 1990s, the Institute, together with its satellite mosque strategically located in the southern outskirts of Milan, was one of the key neuralgic centers for jihadist activities in Europe, leading U.S. authorities to dub it "the main al Qaeda station house in Europe."55 The intersection with Milan's immigrant criminal underworld made the ICI particularly important. Hundreds of documents forged by a cluster of Moroccan ICI worshippers were used by al Qaeda militants worldwide.56 Money made by members of Milan's networks through drug smuggling, petty thefts and other minor criminal activities was sent, along with zakat funds, to jihadist outfits in North Africa and Afghanistan.57 Moreover, as the Institute funds, to jihadist outfits in North Africa and Afghanistan.57 Moreover, as the Institute had been a hub for recruitment for the Bosnian jihad, by the late 1990s it started sending volunteers from various European countries to Afghanistan.58
Between 2000 and 2002 authorities dismantled various networks of Milan-based militants. While listing all of them would be tedious and pointless, some general observations on them should be made. All the individuals arrested were first-generation immigrants from Tunisia, Morocco, Libya or Algeria. Many of them had started their activities to support groups fighting in their home countries, but later switched their focus to supporting al Qaeda's efforts worldwide, and many of them had been trained in the organization's Afghan camps. While the wiretapped conversations introduced by Italian authorities at the various trials clearly showed their deep disdain towards Italy, the clusters were not planning attacks in the country, but limited their activities to providing logistical support to the global al Qaeda network.59
The arrest and subsequent conviction of dozens of ICI-linked militants did not halt the activities of ICI-based networks, which displayed a remarkable ability to regenerate themselves. Months before the war in Iraq began, the remnants of Milanese networks that had recruited for Afghanistan for years began to send volunteers to Iraq, where they joined forces with the Kurdish Islamist group Ansar al Islam.60 Two waves of arrests in 2003 dismantled at least part of the network, but Italian officials estimate that the men had recruited no fewer than 200 militants throughout Europe, 70 of them from Italy alone.61 Forged Italian documents, the trademark of Milan's ICI, have been found on foreign fighters in Iraq.62 And, more disturbingly, Muslims recruited in northern Italy are believed to have carried out brazen suicide operations in Iraq. One of them, Milan resident Lotfi Rihani, reportedly died in September 2003 when he, along with two other Tunisian passengers, struck U.S. forces with a car laden with explosives.63 Algerian national Fahdal Nassim died in the August 2003 bombing of the United Nations headquarters in Baghdad that killed 22 people, including UN special envoy to Iraq Sergio Vieira de Mello.64 Kamal Morchidi, a 24-year-old Moroccan who had served on the board of an ICI front company, died in October 2003 during an attack against Baghdad's Rashid Hotel.65
By 2004 the continuous waves of arrests and the realization that the ICI was under strict surveillance from authorities led many militants to take their activities away from the ICI. The "rendition" of Abu Omar, the Egyptian imam of the ICI's satellite mosque abducted by the CIA while walking near the ICI in February 2003, also contributed to an outward moderation of the Institute's leadership.66 The Institute still openly preaches a strict Salafi ideology, which is also preached at the Farj al Islam, the unauthorized grade school for hundreds of Muslim children operated by the ICI's satellite mosque on the southern outskirts of Milan.67 Nevertheless, while still serving as a gravitational pole for various jihadist networks, the ICI has partially changed its ways in that recruitment and most criminal activities, previously held inside the ICI with the consent of the Institute's leadership, have been mostly moved to other mosques or to private gatherings.
If the ICI is no longer the undisputed beacon of jihadism in Italy, many of the mosques and networks that have partially filled the gap trace their origins back to the Institute. That is the case of various radical mosques in Lombardy, the Italian region with the highest number of Muslim immigrants. Over the years, radical networks composed mostly of North African militants have been uncovered around mosques that had been created by or kept subordinate relations with the ICI. Particularly noteworthy is the cluster of Moroccans and Tunisians that developed around the mosque of the quiet rural town of Cremona. Born out of the initiative of members of the Moroccan Islamic Combatant Group, since the mid-1990s the Cremona network had been active in recruiting, fundraising and spreading propaganda for various jihadist outfits. The cluster's leader, Ahmed el Bouhali, reportedly died under American bombs in Tora Bora in 2001, but the network continued its operations until 2004, when most of its members were convicted of various terrorism-related crimes. The network had also allegedly planned attacks against Cremona's cathedral and Milan's underground system.68
Most northern Italian regions host radical mosques and networks, albeit to a much lower degree than Lombardy. The Turin area, for example, has also seen the presence of Salafi networks, facilitated by the fact that the Piedmontese city is home to Italy's only two "Muslim neighborhoods," Porta Palazzo and San Salvario.69 Algerian militants linked to the GIA had created a base in Turin already in the early 1990s, taking advantage of the city's proximity to the French border, and Safe Bourada, one of the masterminds of the 1995 Paris bombings, settled in Turin in 1994.70 But the bulk of militants operating in Turin is composed of Moroccans, who gravitate around the mosques of Porta Palazzo. Bouiriqi Bouchta, the imam of the most famous of Porta Palazzo's mosques, was considered a "danger to the security of the country" and deported to Morocco in September 2005 with an emergency decree issued by the Ministry of Interiors.71 Bouchta's right hand man and successor, Moroccan imam Mohammed Kohaila, was expelled in January 2008 for similar reasons.72 Salafi networks and preachers linked to the Moroccan movement Justice and Charity are also active in Turin and in various cities throughout Piedmont where Moroccan immigration is high.73
Several cities in Emilia Romagna have also seen the presence of jihadist networks. A Bologna-based network of militants played an important role during the war in Bosnia, while during the second half of the 1990s a network of Tunisians linked to the Tunisian Islamic Combatant Group operated in various cities of the region.74 All these networks and a Parma-based Kurdish cluster that was dismantled in 2003 for recruiting volunteers to fight in Iraq held close links to Milan's ICI.75 The influence of Milan's Islamic Institute is also deeply felt in Tuscany, where most of the region's radical mosques have been taken over by imams affiliated with the ICI. While several mosques in the region belong to this ICI-dominated network, the main hub of jihadismin the region is the al Salam mosque, located in the Florence suburb of Sorgane. Confirming the radicalism of the al Salam mosques, two of its imams have been recently arrested for terrorism. Moroccan national Mohammed Rafik was arrested in 2003 for his role in the Casablanca suicide bombings, while Algerian national Rashid Mahamri was arrested the following year for his alleged role in a network that was recruiting for Iraq.76
Naples has also been an important pole of radical activities in Italy. In the early 1990s top members of the Algerian Islamic Salvation Front (FIS) established a branch of the organization's executive committee in Naples and, since then, the southern Italian city has been a crucial node in the European logistical network of all Algerian groups. Djamel Lounici, the historical leader of such networks, over time switched his support from FIS to the GIA and finally to the GSPC, swaying large segments of Naples' radical community to his increasingly militant views.77 Naples, a port city with a global reputation for its criminal activities, is the ideal base for the operations of the Algerian networks, and close links to local crime syndicates have allowed them easy access to weapons and forged documents that have often been sent to Algeria or to other Algerian clusters operating in northern Italy and throughout Europe.78 Some of the leaders of the Naples-based Algerian network have been arrested (including Lounici, who has been sentenced to eight years in prison ) or deported over the last few years, but militants close to the GSPC are still operating in both.
Naples and Its Metropolitan AreaRadical networks also operate in Genoa, Rome and various cities of Veneto (Padua, Verona, Vicenza and Motta Livenza). A common trend seems to be the de-localization of jihadist networks, as clusters seem to be forming increasingly outside of mosques and in small urban centers. Italy has not yet seen homegrown networks of the kind seen in most other European countries, which are characterized by the fact that most of their members are second generation immigrants and converts. The vast majority of individuals that have been arrested in Italy over the last few years are still first generation immigrants from the Maghreb region. Yet several recent police operations have shown that, unlike in the past, an increasing number of clusters operate independently from any group. And, unlike many of their predecessors, such networks have shown an intention to carry out attacks in Italy. A perfect example of this new trend is the independent cluster dismantled by authorities near Perugia in the summer of 2007, which had accumulated chemical substances for a possible attack inside the country.79 Despite the small resources they have to work with, Italian authorities have been quite successful in dismantling jihadist networks operating in the country and almost a dozen of them have been uncovered since 9/11. Most networks limited their activities to supporting groups operating in other countries (mostly in Algeria, but also Morocco and Tunisia). Three large waves of arrests crippled, but not completely dismantled, various networks that were recruiting volunteers in Italy and in various European countries to fight in Iraq.80 While several individuals over time have been taped by authorities discussing attacks in the country, it appears that in most cases no specific plan was made and, in fact, only few individuals have been charged with planning attacks inside Italy.
To conclude, it is necessary to mention other organizations that, while not directly or publicly endorsing violence, have been monitored by Italian authorities for their radicalism. Hizb ut-Tahrir has a presence but is not as active as it is in most other European countries. Authorities are more worried about the activities of Tabligh Jamaat, the peaceful Islamic missionary movement that intelligence agencies worldwide suspect of having been infiltrated by radicals.81 The Moroccan movement Justice and Charity has a significant influence on several mosques of northern Italy and authorities fear the effects that its radical teachings can have on the local population. 82 Finally, two Shia organizations, Naples-based Ahl al Bayt and its Romebased spin off Imam Mahdi, have attracted the attention of authorities because of their radical positions and because many of their members are Italian converts with a past in militant right wing groups.83
Prospects for the FutureThe probability of a terrorist attack in Italy, while still elevated, seems to have decreased over the last two years. Italy is a close ally of the United States and, while it has withdrawn its troops from Iraq, it still has almost 2000 soldiers in Afghanistan. Moreover, the country's deep Christian roots hold a symbolic value that is not lost on jihadists. "Rome is a cross," are the words of famed jihadist theoretician Abu Qatada, "the West is a cross and Romans are the owners of the cross. Muslims' target is the West. We will split Rome open."84 Yet, the withdrawal of troops from Iraq and aggressive counterterrorism efforts seem to have made Italy less vulnerable to a terrorist attack than two years ago.
Nevertheless, prevention of terrorist attacks, while crucially important, is only one of the issues that authorities have to deal with when confronting radical Islam. Another issue that, in a way, is more problematic to confront is the spread of Salafism and other extremist interpretations of Islam. As all other Western countries, Italy finds itself with very few practical options to make sure that its mosques are not taken over by radical elements. The battle that takes place on a daily basis for the control of Islamic places of worship is something that Italian authorities can only watch from afar, as they rarely possess the legal tools to intervene. To what extent radical currents, whether Salafi or the Brotherhood's, will take hold inside Italian mosques and Italy's Muslim community is something that will become clear only in the years to come.
If there is one certainty about the future of Islam in Italy, it is that its presence will only grow. The influx of immigrants from North and Sub-Saharan African seems to be virtually unstoppable, given migration patterns and socio-economic conditions in Africa. Moreover, in the next few years Italy will start to see second generation Muslim immigrants, like most other European countries already have. Many of them will hold Italian citizenship and, furthermore, the number of Muslims carrying an Italian passport will also increase through marriages and conversions. It seems clear that Islam is destined to have a more visible and stable presence in the country and this is already evident in the impressive increase of mosques throughout Italy. According to a report of the security services, Italy had 351 mosques in 2000, 696 in 2006 and 735 in the first semester of 2007. The report also indicates that 39 new mosques and Islamic organizations were set up just between January and May 2007, an average of one every four days.85
Some problems would be resolved if the Muslim community could find a leadership that was, at the same time, widely representative and moderate. The lack of representative leadership constitutes one of the biggest problems for the Italian Muslim community, which finds itself unable to negotiate and obtain rights that the Italian state is, for the most part, willing to give. Things work better at the local level, where cooperation is facilitated by the fact that it is easier to identify an interlocutor. But at the national level there is the need to find a leadership that would include all voices of Italy's Islam, not only the most vocal. It is necessary for this representative leadership to include not only the "Islam of the mosques," but also "cultural Islam," because, as Italian citizen of Pakistani descent and Consulta member Eyaz Ahmed explained, "Islam is not only inside the mosques, but also in the social and cultural life of those who live in Italy."86
The next ten years appear to be crucial for the future of Islam in Italy. As the first large generation of Italian-born Muslims comes of age, it will dictate the community's direction. If it finds a legal, political and social environment that it can consider open and receptive, it will be more likely to seek full integration, maintaining its religious identity while becoming a full-fledged part of the increasingly multicultural Italian society. If the new generation perceives that Islam is still considered a foreign and, by some, even an inimical religion, its incentives to become part of Italy's social fabric will be limited and more likely to embrace radical messages.87
1. ISTAT population findings for the year 2006.
2. Stefano Allievi, "I musulmani in Italia: chi sono e come ci vedono," Limes, Issue 3/2004, page 97. The 2007 annual report by Caritas/Migrantes puts the number at 1,202,052.
3. Federico Di Leo, "Il nostro Islam in cifre," Limes, Issue 3/2004, page 123.
4. Stefano Allievi, "Islam in Italy," in Shireen T. Hunter, ed., Islam, Europe's Second Religion, (Westport, CT: Praeger Publisher, 2002), p. 82.
5. Stefano Allievi, "Islam in Italy," in Shireen T. Hunter, ed., Islam, Europe's Second Religion, (Westport, T: Praeger Publisher, 2002), pp. 79-80.
6. Enciclopedia delle Religioni in Italia, study by the Centro Studi sulle Nuove Religioni, 2001.
7. Federico Di Leo, "Il nostro Islam in cifre," Limes, Issue 3/2004, page 123.
8. Stefano Allievi, Musulmani d'Occidente, (Rome: Carocci, 2002), page 56.
9. Stefano Allievi, "I musulmani in Italia: chi sono e come ci vedono," Limes, Issue 3/2004, page 101.
10. Smith has repeatedly and publicly asked the Pope to convert to Islam, led a campaign to remove crucifixes from public buildings (claiming that "those small cadavers" frighten Muslim children), and sued Italian writer Oriana Fallaci for vilifying Islam.
11. History of UCOII, available at: http://www.islam-ucoii.it/artcomuni.htm
12. Stefano Allievi, "I musulmani in Italia: chi sono e come ci vedono," Limes, Issue 3/2004, page 100.
13. History of UCOII, available at: http://www.islam-ucoii.it/artcomuni.htm
14. It is noteworthy that, in the September 2007 decree denying UCOII's claim to sue for defamation, Shaykh Abdul Hadi Palazzi, the leader of the Italian Muslim Association (AMI) who had accused UCOII of being linked to the Muslim Brotherhood, Milan Public Magistrate Gaetano Ruta openly stated that "historically documented circumstances" prove UCOII's links to the Brotherhood.
15. Lorenzo Vidino, "Aims and Methods of Europe's Muslim Brotherhood," Current Trends in Islamist Ideology, Volume 4., Volume 4.
16. Reuven Paz, "The Non-Territorial Islamic States in Europe," paper published by the Project for the Research of Islamist Movements (PRISM), Herzliya, Israel.
17. Renzo Guolo, Xenofobi e Xenofili: Gli Italiani e l'Islam, (Bari: Laterza, 2003), page 10.
18. Nour Dachan and Roberto Piccardo, respectively UCOII's president and spokesman, have been indicted for incitement to racial hatred for a strongly anti-Israeli and possibly anti-Semitic insertion published by UCOII in various newspapers during the summer of 2006.
19. Renzo Guolo, Xenofobi e Xenofili: Gli Italiani e l'Islam, (Bari: Laterza, 2003), page 11.
20. Maurizio Stefanini, "Le forme degli Islam nostrani," Limes, Issue 3/2004, page 116.
21. A survey conducted by the Veneto Region at the local level revealed that 38% of polled Muslims considered themselves practicing, while 36% considered themselves believing but not practicing. 81% said they fasted during Ramadan and 84.5% celebrated Eid al Fitr.
22. Renzo Guolo, Xenofobi e Xenofili: Gli Italiani e l'Islam, (Bari: Laterza, 2003), pp. 5-6.
23. Elena Dusi, "Il fantasma della Consulta," Limes, Issue 4/2007, page 150.
24. Elena Dusi, "Il fantasma della Consulta," Limes, Issue 4/2007, page 155.
25. UCOII's intesa draft, available at: http://www.islam-ucoii.it/intesa.htm
26. Interviews with Italian government officials and Muslim community leaders, Rome, February and July 2007.
27. Renzo Guolo, Xenofobi e Xenofili: Gli Italiani e l'Islam, (Bari: Laterza, 2003), pp. 20-1. UCOII and Rome's Grand Mosque had once created together an organization (the Islamic Council of Italy, founded in 1998), which was supposed to act as a unified interlocutor with the Italian government. The experiment failed due to ideological differences and internal power struggles.
28. La Consulta per l'Islam Italiano, website of the Ministry of Interiors. Available at: http://www.interno.it/mininterno/export/sites/default/it/temi/religioni/sottotema003.html
29. Jonathan Laurence and Justin Vaisse, Integrating Islam: Political and Religious Challenges in Contemporary France, (Washington, DC: The Brookings Institution, 2006), page 146.
30. Elena Dusi, "Il fantasma della Consulta," Limes, Issue 4/2007, page 154.
31. Interviews with Italian government officials and Muslim community leaders, Rome, February and July 2007.
32. Mostafa El Ayoubi, "Una Consulta per l'islam italiano," Confronti, undated. Available at:
33. Magdi Allam, "Consulta islamica, il compromesso impossibile," Corriere della Sera, March 16, 2006.
34. Text of the "Manifesto dell'Islam in Italia," March 7, 2006.
35. Elena Dusi, "Il fantasma della Consulta," Limes, Issue 4/2007, page 150; Interviews with Italian government officials and Muslim community leaders, Rome, February and July 2007.
36. Hamza Boccolini, "La Consulta sull'Islam Bloccata dall'UCOII," Libero, October 21, 2007.
37. Interior Ministry's website:
38. Interior Ministry's website:
39. Andrea Morigi, "Anche l'islam radical cede, ‘Si alla Carta dei Valori'," Libero, April 24, 2008.
40. DIGOS, report on the searches at the ICI, September 15, 1997 and DIGOS memorandum on the ICI, May 20, 1994.
41. Nasreddine was also one of the founders of Bank al Taqwa, which was designated by the U.S. Treasury Department in November 2001. Nasreddine was also designated as terrorism financier in August 2002, but his designation was revoked by the Treasury Department in November 2007.
42. Divisioni Investigazioni Generali e Operazioni Speciali (DIGOS), note on ICI, November 9, 1996.
43. Divisioni Investigazioni Generali e Operazioni Speciali (DIGOS), note on ICI, November 9, 1996;
Paolo Biondani, "Alla Sbarra gli Estremisti Islamici," Corriere della Sera, December 13, 1995.
44. Divisioni Investigazioni Generali e Operazioni Speciali (DIGOS), note on ICI, November 9, 1996.
45. Evan F. Kohlmann, "Al-Qaida's Jihad in Europe; The Afghan-Bosnian Network," (Oxford, Berg, 2004). Pp. 19-23.
46. DIGOS, report on the searches at the ICI, September 15, 1997.
47. DIGOS memorandum on the ICI, May 20, 1994.
48. Fabrizio Gatti, "Islamici della Sfinge, Tutti a Casa," Corriere della Sera, January 3, 1996.
49. DIGOS, report on the searches at the ICI, September 15, 1997.
50. DIGOS memorandum on the ICI, May 20, 1994.
51. Some of the known visitors included Moroccan preacher Mohammed al Fizazi, Gamaa leader
Abu Talal al Qassimy, and Ansar al Islam founder Mullah Krekar.
52. See, for example, the book by Marcella Andreoli, Il Telefonista di Al Qaeda, (Milan, Baldini Castoldi Dalai, 2005).
53. Interview with Italian security official, Milan, June 2007.
54. See, for example, the indictment of Mohamed Ben Belgacem Aouadi and others, Tribunal of
Milan, April 4, 2005 (N.5236/02 R.G.N.R.).
55. David S. Hilzenrath and John Mintz, "More Assets on Hold in Anti-Terror Effort; 39 Parties Added to List of Al Qaeda Supporters," Washington Post, October 13, 2001.
56. Indictment of Tarek Maaroufi and others, Tribunal of Milan, April 2, 2001.
57. See, for example, the indictment of Lased Ben Heni and others (Tribunal of Milan, October 1, 2001), or verdict against Essid Sami Ben Khemais and others (Tribunal of Milan, May 13, 2002).
58. Indictment of Abdelhalim Hafed Remadna and others, Tribunal of Milan, November 21, 2001.
59. For an overview of the arrests between 2000 and 2002 see DIGOS reports Muhajiroun 2 (October 5, 2001) and Muhajiroun 3 (November 21, 2001).
60. Indictment of Radi Abd El Samie Abou El Yazid El Ayashi and others (Tribunal of Milan, March 31, 2003) and indictment of Muhamad Majid and others, (Tribunal of Milan, November 21, 2003).
61. Victor L. Simpson, "European Militant Network Shut Down," Associated Press, December 19, 2003.
62. Stefano Dambruoso, Milano Bagdad: Diario di un magistrato in prima linea nella lotta al terrorismo islamico in Italia, (Milan: Mondadori, 2004), p. 63.
63. Indictment of Muhamad Majid and others, Tribunal of Milan, November 21, 2003.
64. Paolo Biondani, "Pestaggi dei Camorristi contro i Detenuti Islamici," Corriere della Sera, December 10, 2004.
65. Indictment of Muhamad Majid and others, Tribunal of Milan, November 21, 2003; DIGOS report, March 27, 2001; interview with Italian security official, Milan, June 2007.
66. Indictment of Osama Mostafa Hassan Nasr, Tribunal of Milan, April 4, 2005.
67. Magdi Allam, "Mediatori e Burattinai nella Scuola della Discordia," Corriere della Sera, October 6, 2005.
68. For the history of the Cremona network, see indictment of Kamel Ben Mouldi Hamraoui and
Nourredine Drissi, Tribunal of Brescia, 2006.
69. Augusto Tino Negri e Silvia Scaranari Introvigne, Musulmani in Piemonte: in moschea, al lavoro, nel contesto sociale, (Milan, Guerini, 2005).
70. Interview with Italian security official, Milan, June 2007.
71. "Antiterrorismo, Espulso l'Imam di Torino," Corriere della Sera, September 7, 2005.
72. Massimo Numa, "Espulso l'Imam che voleva la jihad," La Stampa, January 10, 2008.
73. See, for example, the indictment of Abdellilah Kaflaoui and others, (Tribunal of Turin, May 7, 2005).
74. Magdi Allam, Bin Laden in Italia, (Milan, Mondadori, 2002). Pp. 73-96.
75. Indictment of Radi Abd El Samie Abou El Yazid El Ayashi and others (Tribunal of Milan, March 31, 2003) and indictment of Muhamad Majid and others, (Tribunal of Milan, November 21, 2003).
76. Indictment of Kamel Ben Mouldi Hamraoui and Nourredine Drissi, Tribunal of Brescia, 2006;