{"id":317249,"date":"2026-03-16T13:38:25","date_gmt":"2026-03-16T17:38:25","guid":{"rendered":"https:\/\/www.un.org\/unispal\/?post_type=document&p=317249"},"modified":"2026-04-22T13:44:07","modified_gmt":"2026-04-22T17:44:07","slug":"how-eu-funding-and-exports-of-high-risk-ai-systems-exacerbate-severe-human-rights-violations-in-palestine-and-the-broader-region-report-by-7amleh-non-un-document","status":"publish","type":"document","link":"https:\/\/www.un.org\/unispal\/document\/how-eu-funding-and-exports-of-high-risk-ai-systems-exacerbate-severe-human-rights-violations-in-palestine-and-the-broader-region-report-by-7amleh-non-un-document\/","title":{"rendered":"How EU funding and exports of high-risk AI systems exacerbate severe human rights violations in Palestine and the broader region – Report by 7amleh (Non-UN Document)"},"content":{"rendered":"

 <\/p>\n

This is a non-United Nations document. The United Nations provides these documents only as a convenience for reference purposes, and the inclusion of a document does not imply the endorsement of its content by the United Nations.<\/em><\/p>\n

16 March 2026<\/p>\n

 <\/p>\n

Introduction:<\/strong><\/h2>\n

In 2024, the European Union (EU) adopted the world\u2019s first most comprehensive legislation regulating Artificial Intelligence (AI), the EU AI Act. The Act bans AI systems that pose \u201cunacceptable risk\u201d such as those that deploy \u201csubliminal\u201d or \u201cpurposefully manipulative or deceptive\u201d techniques, social scoring, and those that exploit \u201cany of the vulnerabilities of a natural person or a specific group of persons.\u201d Further, it imposes a number of requirements including risk management, transparency, and human oversight for developers and deployers of high-risk AI systems such as those used in migration, border control, law enforcement, and the provision of public services.<\/p>\n

However, as the EU moves to regulate high-risk AI systems to prevent harm to fundamental rights within its borders, beyond its borders, and specifically in the Arab region, EU-origin and EU-funded high-risk AI systems particularly those used in migration control, predictive policing, biometric identification, and warfare are exacerbating surveillance and rights violations, hindering democratic participation, and reinforcing discrimination.<\/p>\n

This research maps the key instruments through which the EU enables the transfer and deployment of high-risk AI systems in countries of the Arab region, with a specific focus on Egypt, Morocco, Lebanon, Palestine, and Tunisia. The paper further maps the human rights risks and impacts of EU funding and exports of high-risk AI systems. It specifically looks at how EU funding and AI technologies are exacerbating severe human rights violations in Palestine. It further identifies key shortcomings in existing EU legislation and internal procedures that fail to protect human rights in funding and transfer of high-risk AI systems.<\/p>\n

The key questions guiding this research are:<\/strong><\/p>\n

    \n
  • What are the key instruments under which the EU enables the deployment of high-risk AI tools in Arab countries?<\/li>\n
  • What types of EU-origin and EU-funded high-risk AI systems are deployed in select neighbouring Arab countries (Egypt, Lebanon, Morocco, Palestine, and Tunisia)?<\/li>\n
  • How do these tools impact fundamental rights and freedoms? Who is likely to be affected the most by the deployment of such systems?<\/li>\n
  • In what ways do relevant EU legislation and institutions address or fail to address the cross-border implications of AI tools used in non-EU countries?<\/li>\n<\/ul>\n

    To answer these questions, comprehensive desk research was conducted to map the different mechanisms, specifically funding programs and agreements with third countries and regulations that enable EU funding and transfer of high-risk AI systems to Arab countries. Additionally, the different types of technologies in question and companies involved in exporting them were mapped in addition to human rights concerns raised and impacts documented by human rights groups, journalists, researchers, and academics. In addition, two interviews were conducted with two experts specializing in analysing and scrutinizing EU policies, their shortcomings, and human rights impacts.<\/p>\n

    \/…<\/p>\n

    Conclusion:<\/strong><\/h2>\n

    EU funding and exports of invasive AI technologies such as facial and fingerprint recognition, smart city tech, smart border crossing gates, systems for screening of travelers and risk analysis, and drones pose severe risks to human rights in MENA. This is taking place with little due diligence and independent oversight, and despite evidence of funds and exports being used in human rights violations.<\/p>\n

    The Commission and Member States continue to sideline human rights in their migration control deals and partnerships with Arab States. Funding is allocated for the purchase and installation of equipment and technologies, including high-risk AI systems, that facilitate the tracking, control and abuse of people on the move. In a region where public space surveillance and digital space monitoring is conducted by authorities with little to no safeguards for privacy and human rights, EU funding of such technologies will only further the surveillance capabilities of repressive regimes.<\/p>\n

    Action is yet to be taken to ensure EU funds, including those allocated under the Horizon programme and the EDF, do not go to companies who remain complicit in the prolonged occupation of the Palestinian Territory and in the commission of war crimes in Gaza. At the time of publishing, an EU Commission proposal to partially suspend Israeli companies from Horizon has still not been approved. Additionally, the EU continues to be one of the biggest clients of Israel\u2019s weapons industry, helping sustain the Israeli military-industrial complex, and as such Israel\u2019s military violence, which in the words of the Special Rapporteur on the situation of human rights in the Palestinian territories, \u201cremains the engine of its settler- colonial project.\u201d<\/p>\n

    Further, EU companies can still export high-risk AI systems and even systems that are prohibited under the AI Act to MENA countries despite severe risks of their use in human rights abuses. Some of the technologies being exported include facial recognition cameras, biometric fingerprint recognition, digital identity systems, electronic components and communications systems for drones that deploy AI, and smart city systems. While exports of these systems can fall under different EU legislation, specifically the 2021 EU Regulation for the exports and transfer of dual-use items and the 2024 EU Corporate Sustainability Due Diligence Directive (CSDDD), there are loopholes that allow for EU-origin high-risk AI systems to be abused by authoritarian regimes in the region. Open language and lack of guidance in EU Regulation for the exports and transfer of dual-use items make its robust implementation dependent on the interpretation and political will of Member States. While the CSDD, which mandates human rights due diligence for businesses, would not apply to most companies in the European tech industry.<\/p>\n

    In the meantime, a year after the entry of the force of the EU AI Act, European human rights groups are alarmed at a proposal by the Commission to weaken its implementation. In particular, the proposal, if approved, would delay enforcement of transparency requirements for high-risk systems and exempt small mid-cap companies from the requirement to prepare detailed technical documentation of their high-risk AI systems before they are introduced to the market or put into service. The proposal to weaken the Act is part of a broader digital and sustainability \u201cderegulation\u201d agenda pursued by the Commission, supported by some Member States, and pushed for by the tech industry lobby and the Domald Trump administration in the U.S. \u201cUnless the European Commission changes course, this would be the biggest rollback of digital fundamental rights in EU history. It is being done under the radar, using rushed and opaque processes designed to avoid democratic oversight,\u201d a group of 133 civil society organizations, trade unions and defenders of the public interest said in a statement.<\/p>\n

    It is still unclear how the deregulation agenda would further exacerbate abuses enabled by EU-origin technologies and funding of high-risk AI systems. However, the ways with which Europeans\u2019 hard-won digital rights gains are being rolled back\u2014with opacity, no democratic oversight, and a prioritization of political and economic interests over fundamental rights\u2014 bears the same hallmarks of the Commission and EU Member States\u2019 own practices in Palestine and the broader region as they fund the deployment of invasive invasive technologies to control migration, invest and import in Israeli weapons and systems that sustain genocide and apartheid, and refuse to adequately regulate exports. Resisting these strategies can thus benefit from cross-regional and collective actions that document, raise awareness, campaign and organize for a broader political shift in the EU in the medium to long term.<\/p>\n

    Recommendations:<\/strong><\/h2>\n

    Civil Society:<\/strong><\/h3>\n