A Comparison of Different Countries' Approaches
ICSA e-Newsletter Vol. 7, No. 1, 2008.
A Comparison of Different Countries’ Approaches to Cult-Related Issues
Presented at the FECRIS (European Federation of Centres of Research and Information on Sectarianism) Conference “Cults and Esotericism: New Challenges for Civil Societies in Europe” (Hamburg, April 28, 2007), this paper examines some of the factors that give rise to the ways in which countries have approached the problems posed by cultic groups, discusses how the term “cult” is viewed by certain countries, and suggests some constructive measures that countries can feel comfortable taking toward addressing these issues.
Ich mochte zuerst FECRIS danken fur die Einladung an dieser Konferenz zu sprechen.
Ich bin sehr froh hier zu sein.
I would like to extend my thanks to FECRIS for inviting me to speak at this conference.
In this presentation, I will examine some of the factors that give rise to the ways in which countries have approached the problems posed by cultic groups. I will also discuss how the term “cult” is viewed by certain countries. I will conclude by suggesting some constructive measures that countries can feel comfortable taking toward addressing these issues.
Why is it important to compare different countries’ approaches to “cults” rather than simply stating why we do not do what France or the United States, for example, is doing?
Comparing the responses of different countries to “cults” can help us understand the factors that motivate countries to react in the ways they do. Such a comparison also can help us identify common themes that might provide a framework for appropriate and informed action by governments.
I want to clarify that I will be focusing on countries that are democracies, and in many cases I make references to groups that are religious. Although we may all agree that “cults” do not have to be religious in nature, many cult-related concerns have focused on groups whose beliefs are religious.
For the uninitiated, a cursory look at the issue of “cults” can lead the observer to believe that diametrically opposing positions exist in governments’ responses. On the one hand are France and Belgium, whose governments have taken what can be described as an active role in dealing with “cults.” On the other hand is the United States, where there is a strong opposition to any government involvement, be it the country’s own or other governments’.
However, upon closer examination, we see a more complex and nuanced picture of governments and “cults.” Consider Canada, the country I come from, where there is no position on this issue, or consider other countries such as Switzerland and the Netherlands, who have responded differently to the cult phenomenon.
Social, Cultural, and Historical Factors
Certain social, cultural, and historical factors can help us understand why some governments decide to intervene and deal with “cults,” whereas some do not. For example, a country's historical context can have a significant impact on the actions a government chooses to take with regard to the cult phenomenon. Consider the following:
During the course of its modern history, has the country come up against an antidemocratic or totalitarian group? For example, many European countries have had the first-hand experience of being occupied by a Totalitarian movement. The experience of “Nazism” during World War ll has had a profound impact on the psyche of many European countries, and therefore it should come as no surprise that many of these countries have a lower tolerance to groups that are viewed as totalitarian. A totalitarian group, in contrast, has never occupied North America.
Another consideration is whether or not a particular country has ever witnessed violent acts such as mass suicides or murders or terrorist attacks, perpetrated by “cult” leaders, and if so, how they have reacted to these tragedies. For example, the murders, arson, and “assisted suicides” carried out by members of the Order of the Solar Temple (in French, Ordre du Temple Solaire) (OTS) elicited different responses in the countries in which the tragedies occurred:
The French government set up a parliamentary commission.
Switzerland's federal government set up a commission of inquiry.
There was no commission set up in Canada, and the only official document was a coroner’s report into the deaths that occurred in the province of Quebec.
How can one explain the different responses of these countries to the same tragedy? It has been suggested that there is an anomaly between how North American and many Continental, Western European countries react to “cults.” It is interesting to note that most of the recent cult tragedies have occurred in the United States—the Manson Family, Ervil LeBaron, Jonestown, the Branch Davidians, and Heaven’s Gate—and to a lesser degree in Canada—the group led by Rock “Moses” Theriault and the OTS. This situation might lead one to assume that a stronger response would occur in North America compared to Continental Western Europe whose residents have witnessed only one such tragedy (the OTS). Compared to some Western European countries, however, North America has remained relatively unresponsive.
One factor that might account for this difference is that Canada and the United States were settled by immigrants from different countries with diverse ethnic, cultural, and religious backgrounds, and, in the case of the United States, separation of church and State was institutionalized early on. Over the years, this multicultural mosaic might have led, in part, to a more tolerant—some would say permissive or laissez-faire—approach toward “cults” and new religious movements. In contrast, Western European countries were, until relatively recently, mostly homogenous societies with a dominant secular-humanist tradition; a belief that governments could handle any situation; anxieties about national integration in a globalist context, including a new Euro-nationalism; anti-American nationalism; and a tradition of anticlericalism that can be perceived as being displaced to reactions against totalistic “cults.”
A second factor that might account for a government’s actions is how it positions itself with regard to religious groups. In most democratic and so-called secular countries, the roles of religion and State are clearly defined. Mechanisms for recognizing religious groups are clearly set out. Groups that wish to obtain status as a religious organization must meet specific criteria. In other countries, the relationship between religion and State is ambiguous.
Many ways characterize the relationship between so-called secular countries and religious groups. Note that the following characteristics are not all present in each country:
Neutral attitude toward religion, which means that the country does not support any religion to the detriment of another.
Restriction of religious groups' implication within public social services or social institutions.
France, for example, views religious beliefs as a personal and individual matter. Therefore, religious symbols are not present in schools or other social institutions. Several countries, including Denmark and the United Kingdom, have a State religion that is declared “dominant” according to the country’s constitution.
Freedom of religion, which means that citizens are allowed to practice the religion of their choice.
Specific procedures/policies for recognizing religious and nonreligious groups.
In Canada, obtaining the status of Religious Corporation offers groups certain privileges, such as tax exemptions. For example, the Raelians and Scientology have religious status in the province of Quebec.
In the United States, an Office of Community and Faith-Based Initiatives was the first presidential action by Georges W. Bush when he took office in 2001. The goal of this Office, the first of its kind, was to compete with secular agencies for public funds. This initiative is an anomaly because historically the United States has maintained what can be described as nonpreferential neutrality in regard to all religion. Consider the fact that the United States has more than 2,000 laws on the State and Federal levels that spell out in some detail the nature of church-State separation. Most of the laws deal with areas in which the government may not meddle.
In Belgium, Germany and Denmark, religious communities, which are recognized by the government, enjoy public funding. In Belgium, the government pays the salaries and pensions of religious ministers, as stated in the constitution of 1831. In Denmark, ministers of the Evangelical Lutheran Church are State employees. They are paid from special taxes collected from citizens who were baptized as Evangelical Lutherans and who did not formally request exemption from the religion.
In the Netherlands, religious communities benefit from indirect funding, including public donations, which are tax deductible; religious buildings are maintained in part by the State, the provinces, and the communities; and many social activities organized by the religious communities are financed by the State or local communities.
In Germany, churches, which have been recognized by the government in accordance with Article 137-6 of the Weimar Constitution, are entitled to ‘worship taxes,’ which, as in Denmark, are collected by the government from citizens who were baptized by those religions and who did not formally request religious exemption.
In contrast, France does not give status to or subsidize any religious groups. Article 2 of the 1905 law states that the “Republic does not recognize, does not pay, and does not subsidize any worship.”
Switzerland provides us with an interesting example of the range of governmental stances toward religious groups. This small country contains 26 cantons or provinces. Each Canton defines its own relations with religions and has laws that legislates the use of public funds. Positions range from a complete separation between church and State in some provinces (Geneva and Neuchatel), to a province that has a State religion (Zurich).
Another factor that might account for a country’s approach to cult-related Issues merits consideration and more time that I presently have: namely, the role of government.
Are countries that have a more centralized governing structure more prone to taking an aggressive stance toward cultic groups than countries that have a less centralized, more laissez-faire approach? What role do charities play? For example, in countries such as the United States and Canada, which are seen as having a less centralized, more laissez faire style of government, the charity sector plays a vital role in filling the gaps left by the government.
As some researchers have noted, religious groups have to fight for access to privileges. The more difficult it is for a particular group to acquire status and privileges associated with government recognition, the more conflicted the relationship is between that group and the government.
Governments have approached the issue of “cultic” groups in different ways:
No official governmental reaction, as in the case of the United Kingdom and Denmark;
Some limited governmental response, as in the case of Austria (with publication of a brochure by the Ministry of Environment, Youth, and Family)
Governmental responses in the form of parliamentary commissions, reports, or studies (For example: in Canada, Belgium, France, Germany, the Netherlands, Switzerland, and the United States).
The Western European Governmental response to “cultic” groups can be described as global; that is, instead of looking at one tragedy or a unique situation, the governments attempt to understand “cult” phenomena and assess the risk that “cults” represent for their respective countries.
With the exception of the 1980 Hill report on the Study of Mind Development Groups, Sects and Cults in the Canadian province of Ontario, one can describe Canada’s and the United States’ responses to “cultic” groups as situational. This means that a specific issue related to a cult or religious group is addressed instead of the cult phenomenon in general. Consider, for example, the United States’ government reports dealing with the Moon Organization (the Fraser report), and those that followed the tragedy of the People’s Temple and that of the Branch Davidians in Waco, Texas.
In most of the parliamentary reports that I have examined, the solution most widely recommended is to provide the public with information about “cults,” “new religious movements,” spiritual, or other groups. Government reports emphasize the need to educate the public about how these groups function, their recruitment methods, and their philosophies. The goal is to provide the public with as much information as possible so that individuals can make informed choices about whether or not to join a group.
Parliamentary reports from Switzerland, Belgium, and Germany propose the creation of information centers that are open to the public. These centers would also conduct research on “cults” and “new religious movements” with the understanding that some individuals must be protected from the potential danger of certain “cults”:
German consumers are informed that treatment given by some therapists or practitioners of alternative medicine can cause psychological, physical, or financial harm. Public awareness campaigns are, therefore, effective tools for educating the public and preventing victimization.
A recent commission in France proposed 50 recommendations to deal with the influence on children of cultic movements.
The Netherlands recognized that their laws were adequate for protecting members and punishing those who were deviant.
Germany and Switzerland proposed legislation regarding the commercial aspect of some groups.
The Gest and Guyard Commission recognized that France's existing laws were, for the most part, adequate in punishing “cults” that break the law. The Commission also considered it important to further develop or amend some of the points set out in specific laws to enable a more effective response to abuses perpetrated by “cults.” Consequently, France's National Assembly adopted a bill designed to strengthen the government’s power to prevent and suppress problems associated with cult-like groups. This bill became known as the About-Picard law.
How Countries View the Term “Cult”
It is interesting to note how the term “cult” is viewed in certain parliamentary commissions, reports, and legislation.
For example, in the Canadian study, the term “cult” was considered to be pejorative and often used imprecisely. The term “new religion” was seen as subject to abuse and misuse.
Switzerland considered that the term “cult” is often used in a pejorative manner.
In the Netherlands, the term “cult” was avoided in light of its perceived negative impact and replaced by the term “new religious movement,” which was described as “a group or people that lately manifests itself in the spiritual field and is characterized either by a (charismatic) leader or by specific religious conceptions, or else by a specific behavior as a group, or by a combination of these aspects.”
Belgium’s commission report concluded that “cult” in its present usage was pejorative; although it did not consider that “cults” or “new religious movements” in themselves constituted a danger or were harmful. Rather, the Commission used the term “harmful cultic organization,” which it defined as “Groups that claim to have a psychological or spiritual vocation and that carry out or organize harmful illegal activities, harm individuals or society, or impact on human dignity.”
Germany’s 1998 commission used the term “sect,” not “cult,” and even recommended the limited use of that term. The report distinguished between “conflict-prone” and “nonconflict prone” groups. As well, the term “psychogroup” was used to describe psychological and pseudo-psychological services offered outside of professional health and psychological services.
France’s Gest and Guyard Commission report provided indicators for classifying a group as a “cult.” These indicators included:
Exorbitant financial requirements;
Forcing members to sever ties with their former lives;
Antisocial rhetoric, disturbance of public order, and legal disputes;
Infiltrating public bodies.
The countries that I have discussed thus far all claim to recognize and protect the rights and freedoms of their citizens. The protection of these rights and freedoms can appear in a country's constitution, in its Charter of Rights, or in international agreements.
In reality, however, each country regulates its own relationship with religious groups. To understand the actions of individual countries, we need to understand who grants religious status and which groups are entitled to it. We also need to learn more about the privileges granted to groups who have acquired an official status. Above all, we must closely scrutinize what a government says and how its words are translated into action.
I used examples from Western European and North American countries to illustrate some of the ways in which governments have approached the issue of “cults” and how they view or define the term. Looking at other countries such as Russia, Greece, Japan, or China, to name but a few, would reveal more of the broad continuum of governmental views on the “cult” phenomenon and how certain groups are perceived and treated.
We have seen how governments cover the gamut from taking a strong position in opposing "cults" to doing nothing. With such a range of responses, is there a common approach for dealing with “cults,” be it in Europe or elsewhere?
Is it possible to achieve a broad consensus, given that our actions are rooted in assumptions about ourselves and others that, in turn, are inseparable from the historical, political, legal, cultural, social, personal context/worlds in which we live? As the author and diarist Anais Nin (1903–1977) wrote, “We don't see things as they are; we see things as we are.”
With that observation in mind, I suggest that implementing laws to deal specifically with “cults” might be possible in a few countries. However, I would argue that a consensus to that approach is not feasible. Instead, I propose that we look at the most critical areas, such as information and education (I & E), victim assistance, and research, where the potential exists for getting governments to devote time, energy, and resources.
Information and Education, Victim Assistance, Research
Support for informing and educating the public about “cults” has been recommended in different governmental reports. As well, government officials and private and professional organizations in many countries have voiced their support for this option when asked to respond about problems related to “cults.”
I would strongly recommend that governments adopt a common approach for informing and educating the public about cults by:
Supporting the rights and freedoms we all cherish;
Implementing educational programs by working together with existing structures, such as the Ministry of Education, to establish goals and program content, and to identify competent educators;
Using terms that have shared meanings;
Keeping up-to-date on any given “cult”-related subject.
Support for individuals who have been harmed by a group is sorely lacking, and I believe it is not necessary for governments to acknowledge whether or not a group is a “cult” in order to recognize that people can be and are harmed as a result of group experiences. As Michael Langone, Executive Director of the International Cultic Studies Association has stated: “Some groups may harm some people sometimes, and some groups may be more likely to harm people than other groups.”
Families with children involved in cultic groups are a concern in most governmental reports, and there is a continued need for vigilance, where warranted, to guarantee the protection and safety of children in particular.
Governments profess their concern for the well-being of their citizens, so why do they not acknowledge and provide the necessary support for those who need it, regardless of how the group to which they belong or did belong is labeled? I am referring to access to professionals trained in this area, transition homes if necessary, and free services to those who are unable to pay.
There is a pressing need for ongoing funding to carry out research on the “cult” phenomenon and its impact on individuals and society, in order to achieve a sustained influence on governments. Specifically, research is needed to reveal the extent of the problem and the most effective means to deal with it.
Education is the glue that binds the three areas I’ve mentioned. Most governments, even the United States, can take this limited action. In 1999, the Maryland state legislature created a Task Force to Study the Effects of Cult Activities on Public Senior Higher Educational Institutions; and among other recommendations, it indicated the need to “Create an educational program for incoming students and ongoing education programs thereafter through graduation as necessary to assist students in assessing their decisions whether to join groups and how to recognize destructive behavior that may be affecting them.”
When I first proposed this topic for this conference, I envisioned possibly uncovering a common governmental approach for dealing with “cultic groups.” My overall conclusion that education is the solution is not a novel one. However, I believe that Education is the key.
An educated public will be less at risk of getting involved in questionable groups and more aware of the risks that some groups pose. We need to educate the media, the public, mental health professionals, and students, and last but not least, our government officials
After nearly thirty years of involvement in this area, I have experienced many frustrations, not the least of them being that, for decades, the issue of “cults” has been on and off governmental agendas. It is unfortunate that most of the elected officials who have spoken to this issue have mostly pontificated about it, and that little effective action has been taken.
Yet many countries have taken small steps in responding to “cults” and cult-related issues, and I remain hopeful that, with continued efforts, we will be able to have an impact on the way governments respond that will neither result in a Draconian approach nor cause them to avoid dealing with this issue altogether.
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Supreme Court Justice Hugo Black, Engel v. Vitale, 370 U. S. 421, 431 (1962).
 J. Gordon Melton, “The Fate of NRMs and their Detractors in Twenty-first Century America,” Nova religio vol. 4 no 2, 2001, p. 248.
 Sénat, services des affaires Européennes. Le financement des communautés religieuses. 2001. http://www.senat.fr/lc/lc93/lc933.html#toc30
 Ibid., http://www.senat.fr/lc/lc93/lc931.html#toc8
 Ibid., http://www.senat.fr/lc/lc93/lc934.html#toc42
 Ibid., http://www.senat.fr/lc/lc93/lc933.html#toc30
 Ibid., http://www.senat.fr/lc/lc93/lc934.html#toc42
 Ibid., http://www.senat.fr/lc/lc93/lc937.html#toc77
 Ibid., http://www.senat.fr/lc/lc93/lc931.html#toc8
 Ibid., http://www.senat.fr/lc/lc93/lc930.html
 S. Cattacin, C. R. Famos, M. Duttwiler, H. Mahnig. (2003) État et religion en Suisse. Luttes pour la reconnaissance, formes de la reconnaissance. Étude du forum suisse pour l'étude des migrations et de la population (FSM). http://www.ekr-cfr.ch/ekr/dokumentation/shop/00019/00070/staat_religion_kurz_def-f.pdf?lang=fr&PHPSESSID=173f3f4aae0d3aa9ed8733e3662f15c8
 B. Wilson and J. Cresswell. (Eds.). New Religious Movements Challenge and Response. New York: Routledge, (1999), pp. 5–21.
R. Stark and W. S. Bainbridge. The Future of Religion: Secularization, Revival and Cult Formation. Berkeley: University of California Press, (1985).
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R. Stark, W. S. Bainbridge, and D. P. Doyle. “Cults of America: A Reconnaissance in Space and Time.” Sociological Analysis 40 (1979), pp. 347–459.
 Bundesministerium für Umwelt, Jugend und Familie, Sekten: Wissen schützt, Wien (1999).
 D. Hill, Study of Mind Development Groups, Sects and Cults in Ontario: A Report to the Ontario Government, Toronto (1980).
Canadian Security Intelligence Service. Doomsday Religious Movements (1999). http://www.csis-scrs.gc.ca/en/publications/perspectives/200003.asp
 Chambre des Représentants de Belgique. Enquête parlementaire visant à élaborer une politique en vue de lutter contre les pratiques illégales des sectes et le danger qu'elles représentent pour la société et pour les personnes, particulièrement les mineurs d'âge. (1996–1997). http://www.lachambre.be/FLWB/pdf/49/0313/49K0313007.pdf and http://www.dekamer.be/FLWB/pdf/49/0313/49K0313008.pdf
 A. Vivien. Les Sectes en France : expression de la liberté morale ou facteur de manipulations? Documentation Française (1985).
A. Gest, & J. Guyard. op. cit.
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 Final Report of the Enquete Commission on “So-called Sects and Psychogroups”: New Religious and Ideological Communities and Psychogroups in the Federal Republic of Germany, Bonn (1998), http://www.bundestag.de/ftp/9000500a.html
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 «Sectes» ou mouvements endoctrinants en Suisse: op. cit.
 F.B.I. Project Mediggo (1999), http://permanent.access.gpo.gov/lps3578/www.fbi.gov/library/megiddo/megiddo.pdf
 Investigation of Korean-American Relations: Report of the Subcommittee on International Organizations of the Committee on International Relations U.S. House of Representatives. Washington, D.C. (1978).
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 Commission d'enquête relative à l'influence des mouvements à caractère sectaire et aux conséquences de leurs pratiques sur la santé physique et mentale des mineurs (2006), pp. 181–193.
 T. A. M. Witteveen. op. cit., p. 317 (taken from English summary accessible at http://www.math.mcgill.ca/triples/infocult/DutchReport.pdf, p. 5).
 Final Report of the Enquete Commission on “So-called Sects and Psychogroups, op. cit., p. 286.
 «Sectes» ou mouvements endoctrinants en Suisse: op. cit., p. 42.
 LOI no 2001-504 du 12 juin 2001, http://www.legifrance.gouv.fr/WAspad/UnTexteDeJorf?numjo=JUSX9903887L
 D. Hill, op. cit., p. 66
 «Sectes» ou mouvements endoctrinants en Suisse: op. cit., p. 51.
 T. A. M. Witteveen. op. cit., p. 314 (taken from English summary accessible at (http://www.math.mcgill.ca/triples/infocult/DutchReport.pdf, p. 1).
 Chambre des Représentants de Belgique., op. cit., p. 100, http://www.lachambre.be/FLWB/pdf/49/0313/49K0313008.pdf
 Final Report of the Enquete Commission on “So-called Sects and Psychogroups, op. cit., p.30.
 Ibid., p. 32.
 .A. Gest, & J. Guyard. op. cit., p. 15.
 See the United States Department of State 2006 Report on International Religious Freedom Russia: http://www.state.gov/g/drl/rls/irf/2006/71403.htm; Greece: http://www.state.gov/g/drl/rls/irf/2006/71383.htm; Japan: http://www.state.gov/g/drl/rls/irf/2006/71342.htm; China: http://www.state.gov/g/drl/rls/irf/2006/71338.htm
 As appears in different countries’ constitutions, in their Charter of Rights, or in international agreements such as the Universal Declaration of Human Rights and the Declaration on the Elimination of All Forms of Intolerance and of Discrimination Based on Religion or Belief.
 Besides the term “cult” where there appears to be no common consensus on its definition, other terms such as “new religious movements,” “brainwashing,” “deprogramming,” “pro-cult” and “anti-cult” are sometimes used in discussing the cult phenomenon; they generally stigmatize and simplify rather then inform and provide a broader understanding of this issue.
 Groups go through different periods in their evolution; therefore, information of a group’s behaviour from the past (positive or negative) is not necessarily reflective of how the group functions in the present. In addition, providing only one source of information might not accurately portray the group. Various sources should be used.
 M. Langone, Cultic Studies Journal, Vol. 18, 2001, p. 1.
 Former members of cultic groups have unique needs that are not generally being addressed by the existing mental health systems, and training programs for professionals are needed to address this.
 Other areas of research, as noted in the ICSA Research Plan (November 1999) can include the following: What are the cultural implications of the cult issue? What is the relationship between person, group, and treatment variables, and amelioration in post-group distress? What is the prevalence of membership in psychologically abusive groups, and how many such groups are there in the United States and in other countries? Accessed online at http://www.icsahome.com/infoserv_icsa/icsa_researchplan.htm
 Maryland Task Force to Study the Effects of Cult Activities on Public Senior Higher Education Institutions (Recommendation #9, http://www.religiousfreedom.com/tskfrce/MDrpt.htm).