As underlined in the OSCE/ODIHR and Venice Commission Joint Guidelines on Political Party Regulation, “Article 16 of the ECHR enables states to restrict aliens further than nationals in relation to their political activities under Articles 10 and 11 ECHR, such as establishing of and participating in political parties.” However, the Grand Chamber of the European Court of Human Rights has argued that Article 16 reflects an outdated understanding of international law […] in the specific context of the Perinçek case, which concerned the right to freedom of expression guaranteed under Article 10 ECHR “regardless of frontiers” and that consequently “no distinction could be drawn between its exercise by nationals and foreigners.” At the same time, the Court also held that Article 16 should be construed as only capable of authorising restrictions on “activities” that directly affect the political process. Furthermore, the Parliamentary Assembly of the Council of Europe in its Recommendation 799 (1977), recommended that that the restrictions at present authorised by Article 16 with respect to political activity by aliens should be excluded. Although these recommendations are not legally binding, the Venice Commission and the OSCE/ODIHR take the view in the Joint Guidelines that while the possibility of aliens to establish political parties can be restricted under Article 16, it should not be applied in order to restrict the membership of aliens in political parties.”