Start-ups and smaller technology and social media companies face challenges developing and implementing many of these measures due in large part to the resources (human, financial, management) required to develop and sustain them. Technology can be used for good or for malicious purposes. That said, awareness among companies and developers of terrorist use of internet products and services often varies, largely due to the absence of tools or mechanisms to share such information between or with industry actors. In some cases, companies have been criticized for their collaboration with internet referral units (IRUs) on the grounds that such mechanisms allow law enforcement to rely on company terms of service to inform content-removal related decisions. Some criticism has touched upon perceived lack of transparency and accountability in this type of collaboration. In the EU context, and given mounting public security concerns surrounding terrorist activity, an internet referral unit was established within EUROPOL in 2015. It is a voluntary arrangement stemming from the European Agenda for Security and is accountable to the European Parliament.6 In addition to support provided to EU Member States, the EU IRU cooperates with third party partners within the framework of the EU Internet Forum, engaging with online service companies to promote ‘self-regulation’ activities by the online industry. The overall objective of the EU IRU is to reduce accessibility to terrorist and violent extremist propaganda on the internet by identifying and referring relevant online content to the hosting internet service provider, with a clear assessment of how terrorist material it has identified might be in breach of their terms of service. It uses the Consolidated UN Security Council Sanctions List as a basis for deciding what content to refer.7 According to its first annual report of activities, the EU IRU has proven to show effectiveness in the sense that since its inception, companies have removed a significant percentage of content referred to them.8 It has also committed to transparency through the publication of said annual activity reports, for which both companies and civil society actors have commended it. 9 There are concerns, however, about promoting such mechanisms globally as a good practice, in particular in those jurisdictions where principles such as transparency, accountability and remedy cannot be guaranteed. 10 2.4 Mechanisms for Information Exchange/ Sharing of Standards and Practices and Capacity Building In the United States, a number of voluntary initiatives have been established to support information/ practice sharing among technology and social media companies, sometimes involving companies from other regions and representatives from other sectors (e.g. financial services) as well as researchers or civil society actors. 11 These include 6 Zurich workshop, 25 August, 2016. See: http://ict4peace.org/wp-content/uploads/2016/10/Summary-Report-Zurich-WorkshopFINAL.pdf 7 See: https://www.un.org/sc/suborg/en/sanctions/un-sc-consolidated-list 8 See: EU Internet Referral Unit: Year One Report – Highlights. Available at: https://www.europol.europa.eu/publications-documents/euinternet-referral-unit-year-one-report-highlights 9 Zurich workshop, 25 August, 2016. 10 GNI (2016), Extremist Content and the ICT Sector: A Global Network Initiative Policy Brief. 11 In the banking sector there are already quite well established information sharing groups at international/ regional/local level, often with established government communication channels. These are more focused on misuse of banking services in general rather than 7