-7II. A. FACTS FOUND DURING THE VISIT AND ACTION PROPOSED Foreign nationals deprived of their liberty under aliens’ legislation 1. Preliminary remarks a. Background 11. At the outset, the CPT wishes to recall that in the period since 2005, it has paid particular attention to the issue of foreign nationals deprived of their liberty under aliens’ legislation in Greece. The most recent visit on this topic took place in April 2018.9 The CPT has over the years been extremely critical of the way in which the Greek authorities treat migrants who enter the territory in an irregular manner. It has advocated that any immigration detention facilities established are not punitive and meet basic minimum standards. Regrettably, despite repeated recommendations by the Committee, the approach of the Greek authorities has not evolved substantially. 12. The adoption of Law 3907/2011 which transposed the provisions of the EU Return Directive 2008/115/EC into Greek law as well as the establishment of an Asylum Service and First Reception System combined with the Action Plan on Asylum and Migration Management adopted in 2010, and updated in December 2012, heralded a new approach. In particular, the concept of the pre-departure centres appeared to meet the basic requirements set out by the CPT of offering decent living conditions and a purposeful regime. In reality, the operation of the centres was based on a security approach, with detainees treated in many respects as criminal suspects. Such an approach is even more pronounced in the case of the police pen-like holding facilities of Filakio and Petrou Ralli, which the CPT has repeatedly criticised since 2005. A belief apparently remains that harsh conditions will deter migrants from arriving in Greece, without taking into consideration the push factors driving people to risk their lives to enter the country. The European Union’s determination to seal its external borders has resulted in severe difficulties for Greece since 2015; however, the punitive approach pursued by the Greek authorities throughout that time has done nothing to resolve the underlying issues. 13. The CPT fully acknowledges the difficult context and the significant on-going challenges faced by the Greek authorities in dealing with the high number of foreign nationals arriving in the country, both on the Aegean islands and in the Evros region. The Committee has repeatedly stressed the need for a coordinated European approach to address this phenomenon. 9 See CPT and Greece for the report on the 2018 visit and the preceding nine visits reports on this topic.