There is a tension between implementing resolutions of the U.N. Security Council and simultaneously respecting human rights embedded in national constitutions and other international treaties. This tension is also evident when the United Nations lists the persons against whom counterterrorism sanctions should be imposed under its resolutions. The courts can examine whether the sanctions in themselves may contain a violation of human rights or whether they are to be applied in compliance with human rights requirements; however, the issue of whether placing persons on the list could in itself be a violation of human rights is a more complex matter. Access to the courts to contest such resolutions or lists is impossible for private individuals. In dealing with this gap in human rights in European states, the first step should be for the Council of Europe to change the obscure way in which persons, organizations, and entities are placed on terrorist lists. At a minimum, this means developing objective criteria for assessing whether to place a person or organization on the list, so as to prevent as much arbitrariness as possible. There should certainly be a restriction on the unquestioning adoption of names from the lists of the U.S. presidential executive orders and from the lists of the 1276 Committee. A second step should be a "delisting" procedure introduced at the level of the European Union.