There are three important problems arising from criminalization at the international level. The first problem arises from the lack of guidelines for deciding which act should be criminalized and which should not. The second problem arises from the lack of clarity in human rights instruments. The third problem arises from the lack of consistency in the advice provided by the various international mechanisms regarding the implementation of criminalization policies. A significant example illustrates the contradictions in the United Nations and European documentation regarding collective memory. Accordingly, this research shows that decisions and recommendations on memory laws are not consistent across entities within the United Nations and European Union documentations.
