Between Europeanisation and Local Legacies: Holocaust Memory and Contemporary Anti-Semitism in Romania

This article addresses the persistence of anti-Semitism in Romania, placed in the context of some recent debates concerning the memory of the Holocaust in the country, as well as in the area of Central and Eastern Europe more broadly. It argues that, despite significant improvements in terms of legislation, the memory of the Holocaust remains a highly contested issue in contemporary Romania, torn between the attempts to join in the European memory of the Holocaust and local legacies that on the one hand focus primarily on the suffering of Romanians under the communist regime, and on the other perform a symbolic “denationalisation” of the Jewish minority in the country, whose own suffering is thus excised from national memory. It does so by focusing in particular on the debates surrounding the adoption of Law 217/2015, meant to clarify earlier legislation on Holocaust denial, and comparing them with those prompted by the Ukrainian “memory laws” passed in the same year. Taking into account both the national and international reactions to these very different pieces of legislation, the article shows the still-persisting discrepancy between a (mostly Western) “European” memory of the legacy of the twentieth century and local memory topoi characteristic of the countries that were part of the former socialist bloc.


Introduction
In a recently published report resulting from a partnership between the european Union for Progressive Judaism (eUPJ), grinnell College, and Yale University and proposing the first-ever attempt at rating all the individual member states of the european Union on how they relate to the Holocaust, the section on Romania opens with the words: "after a slow start, Romania has become a model of success in acknowledging and confronting its role in the Holocaust. It is a rare positive story among new european Union Central european members." 1 The statement appears remarkable for a number of reasons. First, the project's summary argues that Holocaust revisionism is most visible in the new Central european member states, identifying Poland, Hungary, Croatia, and Lithuania as the worst offenders; Romania is included in this group of new member states, where the only other positive example is that of the Czech Republic, which is a "star student" but not quite "a model" though. 2 Second, the "slow start" mentioned above is a rather euphemistic way of referring to the fact that for the entire first decade after the collapse of communism Romania was consistently singled out as the east european country witnessing revisionism, Holocaust denial, and a resurgence of far-right political organisations that explicitly invoked the legacy of interwar fascism on a far larger scale than any other member of the former socialist bloc. 3 Third, the statement is also surprising given the long legacy of anti-Semitism in Romania, whereby "anti-Semitism was part of Romanian history ever since the establishment of the state." 4 Taking its cue from the aforementioned report's very positive assessment of Holocaust remembrance in present-day Romania, this article argues that, despite significant improvements in terms of legislation and institutional infrastructure, the memory of the Holocaust remains a highly contested issue in contemporary Romania. This contestation occurs in the interplay between the official attempts to join in the european memory of the Holocaust and local legacies that often diverge from, or even contrast with, the institutional remembrance efforts. These alternative, "unofficial" local memory topoi focus primarily on the suffering of Romanians under the communist regime, performing at the same time a symbolic "denationalisation" of the Jewish minority in the country, whose own suffering is thus excised from national memory. The present article addresses this tension between official and popular memory of the Holocaust in contemporary Romania by focusing in particular on the debates surrounding the adoption of Law 217/2015, meant to clarify earlier legislation on Holocaust denial, and comparing them with those prompted by the Ukrainian "memory laws" passed in the same year. In doing so, it aims to relate the Romanian case study to discussions of the "europeanisation" of Holocaust memory, as well as to consider the ways in which the comparison with Ukraine might hint at broader patterns encountered in other spaces within the area of Central and eastern europe.
The key element to be introduced into the discussion for the purposes of clarification is the long-standing legacy of anti-Semitism in Romania. Briefly mentioned in the 2018 report mentioned above, its account of it starts with the rise of fascism in the 1930s, 5 ignoring earlier developments that had their roots in the nineteenth century. Without exploring in too much detail a topic on which a significant literature already exists, 6 and a comprehensive survey of which would far exceed the scope and purpose of this article, the following section will highlight one of the salient features of this legacy, namely the exclusion of the Jewish minority from the attempts to define the boundaries of the Romanian "nation". non-citizens, the Jewish minority in the country was effectively "denationalised," cut off from the "nation", however imagined, and linked decisively to "foreign interests." This placing of "the Jew" beyond the boundaries of the Romanian "nation" was to have extremely negative consequences, resulting in legal discrimination that was tantamount to effective exclusion from political life, as well as from Romanian society.
a radicalisation of anti-Semitism occurred after World War I in a context that saw similar developments at a european level, and more prominently in Central and eastern europe. The impact of the violence of World War I and the Russian Civil War, and the association of Jews with communism, exacerbated after the Russian Revolution into "the myth of Judeo-Bolshevism," 17 both contributed to this radicalisation. In Romania, where Jewish emancipation was only formalised in the 1923 Constitution, rendering the country the last in europe to emancipate its Jewish population, interwar anti-Semitism could draw on the pre-war legacy of legal exclusion. Far from being confined to the fringes of Romanian society, anti-Semitism was mainstreamed in interwar Romania, and the popularity of the third largest fascist movement in europe, the "Legion of the archangel Michael," 18 ensured that the type of anti-Semitism that was popularised among the Romanian public was as extreme and violent as the Nazi one. 19 Consequently, despite the insistence of apologists of the legionary movement in contemporary Romania that the Legion was not directly involved in perpetrating the Holocaust, having been disbanded following its abortive coup in January 1941, the Romanian fascist movement played a pivotal role in "desensitising the general population towards the plight of Romanian Jews and making possible the gradual escalation of discriminatory measures into outright extermination policies." 20 The Holocaust in Romania was thus marked by its pre-war legacy, resulting in its apparent paradox. On the one hand, between "280,000 and 380,000 Romanian and Ukrainian Jews were murdered or died . . . in Romania and the territories under its control." 21 as Raul Hilberg noted, "no country, besides germany, was involved in massacres of Jews on such a scale." 22 On the other hand, more Jews survived the Holocaust in Romania than in any other of the territories that came under the control of Nazi germany or its allies during World War II. This was the result of antonescu's policy of selective deportation, whereby Jews from the territories acquired by Romania after World War I and lost to the Soviet Union in 1940 were deported en masse, whereas those from within the borders of the Old Kingdom of Romania and the part of Transylvania that remained under Romanian control during World War II were (mostly) not deported, albeit being subject to confiscations of property and forced labour within the borders of Romania proper. 23 It was also the result of his adamant refusal to comply with the german requests to deport the Jewish population in Romania to Nazi extermination camps in Poland. Of these two accounts, it is the one of perpetration that contemporary Romanian anti-Semites who deny Romanian responsibility for the Holocaust usually leave out, focusing instead primarily or exclusively on the refusal to deport the Jews to Poland and the allowing of emigration to Palestine after 1943. 24 If at the end of the war some of the perpetrators were brought to justice under special courts with the participation of the Soviet High Command, 25 the socialist regime that was established in 1948 in Romania practised amnesia with regard to the Holocaust. While explicit manifestations of anti-Semitism disappeared from public space, returning only in the late 1970s and 1980s as part of the nationalist turn of Nicolae Ceauşescu, 26 Romania's role and responsibility for the Holocaust was never discussed. Instead, in a pattern familiar for countries in the socialist bloc, the responsibility for the Holocaust was squarely placed on Nazi germany, as well as on "fascism"-a term so loosely employed it eventually came to denote all the noncommunist political organisations in interwar and wartime Romania, rendering it practically meaningless. Consequently, the national-communist historiography focused mostly on the "anti-fascist" struggle of Romania after august 1944 and its contribution to winning the war. The most prominent aspect that characterised the life of the Jewish community under the socialist regime in Romania was aliyah, itself fluctuating with the position of the government and its relations with both Israel and the Soviet Union. Starting in 1958 when the country was under the leadership of gheorghe gheorghiu-Dej, and continued by Nicolae Ceauşescu after 1965, a veritable "trade" was conducted by the Romanian state with Israel, with exit visas issued for Romanian Jews in exchange for foreign currency or goods, whether industrial equipment or agricultural implements and livestock. 27 This massive emigration, from which the Romanian socialist regime profited significantly, led to a dramatic decrease of the Jewish community living in Romania. If in 1946 there had been more than 420,000 Jews in the country, the largest number of all countries in the socialist bloc except for the Soviet Union itself, 28 in the 1992 census, the first one carried out in the post-communist period, there were 8955 persons who declared Jewish ethnicity left out of a total population of 22,810,035, or 0.03 percent of the population. 29 Thus, the socialist regime in Romania brought about what earlier generations of Romanian anti-Semites had intensely militated for, the almost complete elimination of Jews from Romanian society, while also drawing a profit in the process.

Post-Communist Romania and "Anti-Semitism without Jews"
given the numbers presented above, the re-appearance of anti-Semitism in the Romanian public sphere after the collapse of communism is clearly a case of "anti-Semitism without Jews." 30 Considering the minute size of the Jewish community (which has in the meantime further decreased to slightly more than three thousand persons according to the latest census), 31 as well as its predominant concentration in a few urban centres, it is very likely that many of the anti-Semites in contemporary Romania would have never met an actual Jew. Consequently, the persistence (or 318 east european Politics and Societies and Cultures return) of anti-Semitism in the country has more to do with issues of memory and with debates over the country's history, in particular the legacy of "totalitarianisms" (fascism and communism), than with any pressing concerns related to the actual Jewish community currently living in the country. a recent study carried out in 2016-2017 by the "elie Wiesel" National Institute for the Study of the Holocaust in Romania (Institutul Naţional pentru Studierea Holocaustului în România "elie Wiesel," henceforth INSHR-eW) on anti-Semitism and anti-Roma hate speech in social media comes to similar conclusions when comparing these two types of narratives: while anti-Roma discourse refers predominantly to "arguments derived from immediate daily reality," anti-Semitism is much more elaborate and typically relates either to a nationalist interpretation of Romanian history or to abstract and intricate conspiracy theories of international circulation. 32 Consequently, the focus for someone interested in monitoring anti-Semitism in contemporary Romania should be less on cases of discrimination, harassment, acts of vandalism, or violent attackswhich, while not entirely absent, are thankfully far less frequent than in many countries in Western europe (e.g., France or germany), 33 an aspect most likely related to the minute size of the Jewish community-but on the politics of memory, the proliferation of revisionist historical narratives, and the different forms of Holocaust denial existing in contemporary Romania.
In the immediate post-1989 environment, the resurgence of anti-Semitism in the Romanian public space occurred, as elsewhere in Central and eastern europe, against the background of strident anti-communism that to some extent still persists to this day. This feature marks the specificity of anti-Semitism in eastern europe, rendering it distinct from the so-called "new anti-Semitism" visible in Western european countries, mostly associated with criticism of Israel and its policies in the Israeli-Palestinian conflict, or, alternatively, seen as having its epicentre in "Islamic anti-Semitism." 34 In a country where the 1978 american TV miniseries Holocaust that had done so much to popularise the Shoah in Western europe has never been shown to date but where The Memorial of Suffering-a Romanian TV documentary series comprising 140 episodes and 150,000 minutes of footage about the communist repression-ran on prime time television between 1991 and 1996, and intermittently until 2004 (with numerous re-runs), 35 the immediate suffering of Romanians under the communist regime was much more prominent than the distant memory of the Holocaust. Not only temporal distance, but also spatial considerations came into play: as most of the crimes committed during the Holocaust by the Romanian administration-with the notable exception of the June 1941 Iaşi pogrom-took place in areas that are currently outside the borders of contemporary Romania, most of the population living within Romania proper would not have been directly exposed to them. 36 In addition to lack of knowledge about the Holocaust, for all the reasons mentioned above and in the previous section, there is also the element of "wantingnot-to-know" that Simon geissbühler, using Paul Ricoeur's term, mentions in a recent article, denoting "a devious form of forgetting . . ., as it is seen, for example, in forgetting by avoidance, . . . motivated by 'an obscure will not to inform oneself'". 37 a rehabilitation of Ion antonescu that had already begun in oblique ways during Ceauşescu's regime came to the fore after 1989, with several organisations campaigning for his exoneration from the "war crimes" and "treason" sentence that had led to his execution in 1946. 38 While the juridical rehabilitation these organisations aimed at did not occur, a veritable cult of antonescu developed in the first decade after the collapse of communism, with the wartime dictator being presented as an anti-communist patriot. By 2004, "between six and eight statues had been erected in memory of the marshal, 25 streets and squares had been renamed after him, and in Iaşi even the 'Heroes' Cemetery' carried the dictator's name." 39 a feature film directed by Sergiu Nicolaescu (the most prominent director associated with the series of historical epic films produced during the Ceauşescu regime that glorified Romania's past), as well as two documentaries claiming "historical objectivity," also put forth a positive image of antonescu. 40 This was the "radical continuity" (with Ceauşescu's regime) that Michael Shafirthe most prolific author writing on anti-Semitism, Holocaust denial, and the radical right in post-communist Romania-identified and distinguished from the "radical return" (to the interwar legacy) occurring at the same time. 41 as I noted elsewhere, "[p]aradoxically perhaps, the prevailing anti-communism in Romania after 1989 did not preclude the continuation of many of the ideological features of the Ceauşescu regime into the post-communist period, nor indeed of many of the former collaborators, affiliated intellectuals and second-rank bureaucrats of the regime, who reinvented themselves as anti-communist 'democratic' politicians." 42 The main political representatives of this "radical continuity"-the greater Romania Party (Partidul România Mare [PRM]) and the Romanian National Unity Party (Partidul Unităţii Naţionale a Românilor [PUNR])-entered the governing coalition in 1992-1996, alongside one of the "successor parties" of the former Romanian Communist Party, and their popularity peaked in 2000, when the far-right candidate Corneliu Vadim Tudor got to the second round of the presidential elections and received 33.17 percent of the vote. 43 This peak marked however also the beginning of a steady decline, as PUNR disappeared altogether and the greater Romania Party managed to pass the 5% threshold required to enter parliament for the last time in the 2004 general elections.
alongside (and in opposition to) the parties of "radical continuity," the end of communism in Romania witnessed the proliferation of numerous organisations of "radical return," which denounced the communist regime as a criminal one and as a foreign-imposed caesura in the country's "natural" development, looking instead to interwar radical right models, the most prominent of which was that of the fascist "Legion of the archangel Michael" (also known as the "Iron guard") and its leader, Corneliu Zelea Codreanu. according to Michael Shafir, reports of the Romanian Intelligence Service in 1998-1999 counted no fewer than twenty-eight radical right organisations, as well as twelve foundations and associations set up by supporters of the Iron guard. 44 all of these espoused a radical version of anti-Semitism directly inspired by the legionary one. although none of these organisations had anything resembling the electoral clout of the "radical continuity" parties, and none of them ever entered parliament, they remain no less dangerous because of their radicalism and open glorification of interwar fascism. Furthermore, to this day, such circles remain the main proponents of an extreme form of anti-Semitism that continues to posit an abstract representation of "the Jew" as the main enemy of the "Romanian nation" (and nations in general), despite the numerical insignificance of the Jewish minority in the country. as the aforementioned INSHR-eW report notes, "the cult of Corneliu Zelea Codreanu, the criticism of the historiography that denounces the abuses and crimes committed by the legionary movement, the exaltation of members of the legionary movement as "prison saints," or the promotion of legionary ideology as a political model worth following today are frequent among the users involved in the dissemination of hate speech." 45 and as a later section dealing with the reactions to Law 217/2015 will show, their influence in contemporary Romania goes far beyond their (very limited) membership. Moreover, while the cult of antonescu has declined recently in parallel with the fortunes of the "radical continuity" parties and politicians that (mostly) espoused it, recent surveys show the opposite trend with regard to the popularity of the legionary movement and its leadership, which seems to be on the rise in present-day Romania. 46

Holocaust Memory and Anti-Semitism in Contemporary Romania
as elsewhere in Central and eastern europe, the change in perceptions of the Holocaust in Romania only came around the turn of the millennium, against the background of the country's efforts at integration into euro-atlantic structures. While President emil Constantinescu was the first to acknowledge Romanian responsibility for the Holocaust during his term in office (1996)(1997)(1998)(1999)(2000), his recognition was nevertheless qualified by invoking Romania's refusal to take part in the "Final Solution," 47  against the prevailing tendencies to assign responsibility for the Holocaust primarily or exclusively to Nazi germany, the Final Report established unequivocally the responsibility of the Romanian state for perpetrating the Holocaust in Romania and the territories that came under Romanian control during World War II. 49 However, despite the fact that it led to the establishment of a National Holocaust Commemoration Day, on October 9, the day when deportations of Jews to Transnistria began, as well as to Romania's membership of the International Holocaust Remembrance alliance (IHRa)-both occurring in 2004, the year when the report was made public-this official acknowledgment did not translate into a wide publicization of the results of the report among the population. 50 Beyond its pragmatic political purposes, the recognition of Romania's role in and responsibility for the Holocaust came against the background of a "europeanisation" of the memory of the Holocaust that both intensified after the collapse of communism and extended its scope to include the former members of the socialist bloc, hitherto exposed to very different public memory processes. However, while this "europeanisation" of Holocaust memory is widely recognised, its implications for countries in Central and eastern europe have rarely been spelled out. First of all, crucially, as Ferenc Laczó notes in a recent article, "notwithstanding some notable exceptions, such as Spain or Ukraine, the geographic scope of the Holocaust closely overlaps that of the european Union today"; moreover, "this statement . . . could not have been made before the eU enlargements of the early 21st century." 51 This is all the more important since "Jews from east european countries came to account for the large majority-well over five million, or about 90 percent-of all the victims of the Holocaust," with the much better documented-and remembered-"Jewish victim groups from germany, the Netherlands, Belgium and France together [constituting] around 6% of all victims." 52 However, because of the lack of public debate about the Holocaust in the socialist bloc, countries in Central and eastern europe had not experienced the tortuous, painful, and long-term process of coming to terms with responsibility for collaboration or outright perpetration. as we know from the historiography dealing with this process in Western european countries, such acknowledgment was slow to come about (with authors usually pointing to 1968 as the starting point of such engagement with the past), 53 engendered very heated polemical debates-one need only think of the Historikerstreit in West germany during the 1980s 54 -and only came to a relative consensus in the 1990s, at the same time as this still emerging european memory was already being exported to the would-be members of the european Union in eastern europe. However, in that context, countries in Central and eastern europe found themselves in the position of rapidly adapting to and adopting this end product of protracted and intense debates without having had such meaningful debates within their own societies.
This wholesale adoption of the europeanised memory of the Holocaust at the institutional level in the absence of meaningful public debate had several effects or unforeseen consequences for collective memory within countries that were formerly part of the Soviet bloc. First of all, as alon Confino aptly notes in his comments on Henri Rousso's seminal book on Vichy France, its focus on "memory created from above . . . ignores the construction of popular memories of Vichy and their links to the everyday level of experience." 55 The absence of discussions about Vichy in French public space, just as similar processes in West germany, for the first two decades after the war does not denote general amnesia about it; instead, it contributed 322 east european Politics and Societies and Cultures to the proliferation of a selective memory emphasising victimhood rather than responsibility for collaboration or perpetration. 56 Collective memory can be highly divergent from the historiography, as it is primarily based on sentiments, which "are above all shared, which means that not only historians, not only politicians or writers, not just university or high-school graduates, but also shopkeepers, blue-collar workers and peasants constitute the make-up of memory." 57 The fact that in the countries of the former socialist bloc this mnemonic process continued for five decades and only changed gear as a result of international pressures to adapt to a narrative that originated elsewhere has significant consequences for the evolution of Holocaust memory in contemporary eastern europe. Consequently, the "europeanisation" of public memory could be read in Romania along the familiar lines of "foreign intervention," as something that was externally imposed rather than developed as a demand from the Romanian public. This was all the more so since the priority for Romanians, as mentioned above, was to engage with the legacy of the communist regime, as both much more familiar spatially and temporally and more directly related to the sufferings of Romanians as a "nation"-from which, as we have seen earlier, Jews had long been symbolically excluded. Moreover, the rediscovery and revalorisation of interwar radical right narratives led to the resurgence of the "Judeo-Bolshevik" trope, whereby the hated communist regime could be depicted as not only "foreign" (because of being Soviet-imposed) but also "Jewish." 58 Thus, a pattern of representation that, as argued above, originated at the Congress of Berlin, in which Jews were "denationalised" and foreign intervention on their behalf denounced as an encroachment on sovereignty, casts its long shadow even over contemporary Romania. a partly related dimension of "europeanisation" that is often ignored is its contribution to increasing polarisation within societies in Central and eastern europe. While initially enthusiasm for european integration was widespread, and this was the case in Romania more than anywhere else except the Czech Republic, the consensus in favour of the eU began to dissipate once eventual membership sharply brought to the fore the unequal distribution of such benefits and the division between "winners" and "losers" that it created. Part and parcel of global processes associated with neoliberalism and globalisation which for many have a certain air of "inevitability," 59 this social polarisation had, however, a "human face" in Central and eastern europe, and could be clearly associated with specific actions (eU integration, the related policies of austerity after 2008) and the political actors who promoted them. This partly explains the right-wing radicalisation sweeping the region presently, complete with denunciations of the eU and its alleged encroachment on national sovereignty, as well as going some way toward accounting for why reading "the ideological opposition between liberalism and illiberalism as a transparent description of the situation" would be quite simplistic. 60 a similar polarisation occurs at the level of collective memory, with the "european" one associated mostly with elites and state institutions, while popular memories that have much more explicit links to lived experience not only continue to exist in parallel to official, institutionalised memory but, when mobilised by right-wing actors, can come to directly challenge it. and if the situation in Romania has certainly not reached the critical levels currently experienced in Hungary or Poland-mostly because of the absence of a far right organisation that would be able to channel and mobilise such tendencies-the state of Holocaust memory and anti-Semitism in contemporary Romania is far from the rosy picture painted in the report mentioned at the beginning of this article. a brief discussion of a highly contested law on Holocaust denial, Law 217/2015, compared to the so-called "decommunization laws" in Ukraine, will be used to illustrate this.

Comparing Memory Laws
In 2015, Romania and Ukraine both passed "memory laws" that in certain respects could be described as complete opposites of each other. While they both deal with the "totalitarian" legacies of the two countries in question, they do so in very different ways. Law 217/2015 in Romania brought a much-needed clarification to the existing legislation on Holocaust denial, Law 107/2006, by including within its scope cases of selective denial, that is, of Romania's role in its perpetration, as well as explicitly including the legionary movement in the category of fascist organisations whose symbols and propaganda are prohibited in public space. 61 In Ukraine, the four so-called decommunization laws (comprising Law 2558, Law 2538-1, Law 2539, and Law 2540) instead condemned the communist and Nazi "totalitarian" regimes, prohibiting their symbols and public denial of their crimes (Law 2558), while "honouring the memory of fighters for Ukrainian independence in the 20th century," and conferring them a legal status that includes state benefits (Law 2538-1). 62 In addition to equating communism with Nazism, a staple feature of contemporary anti-Semitism in eastern europe in its engagement in what alan Rosenbaum has termed "competitive martyrdom" (in this case between the Holocaust and the gulag), 63 an even more problematic aspect concerned Law 2538-1, which included within its jurisdiction the Organisation of Ukrainian Nationalists (OUN) and the Ukrainian Insurgent army (UPa), two organisations responsible for collaboration with the Nazis, participation in the Holocaust in Ukraine, and the mass murder of Poles in Volhynia and eastern galicia between 1943 and 1945. 64 as such, not only were Holocaust perpetrators elevated to the status of "heroes of Ukraine"-with their leader, Stepan Bandera, commemorated since 2019 (which was also designated as the "Stepan Bandera Year" in his native region of Lviv) with a national holiday 65 -but identifying them as fascists or Nazi collaborators constitutes a punishable offence under this legislation.
From the perspective of the europeanisation of the memory of the Holocaust described above, the laws in Romania and Ukraine can thus be seen as proceeding in opposite directions: While the Romanian one shows alignment with it, the Ukrainian laws diverge significantly from the european condemnation of fascism, and align themselves instead with memory practices characteristic of the former Soviet bloc, where the crimes of communism are emphasised as taking priority over the Holocaust. Ukraine is certainly not alone in prohibiting communist symbols, as all three Baltic states have similar pieces of legislation, all adopted after the countries joined the european Union (in 2007 in estonia, 2008 in Lithuania, and 2013 in Latvia, respectively), 66 as does Bulgaria, 67 with similar legislative initiatives currently being discussed in Hungary and Poland. In a very recent development, a similar legislative proposal-that would ban both communist symbols and any attempts at association with the purposes of promoting communist ideas, carrying very harsh prison terms, of three to ten years-has been made in the Romanian Parliament in March 2019 by a new right-wing party (the "Save Romania Union," USR) established in 2016. 68 Currently the third largest in the Romanian Parliament following the 2016 general elections, the party presents itself as an alternative to the corrupt political establishment, in a classic incarnation of the commonplace right wing populist trope in contemporary europe and beyond. Identifications of the legislative proposal as "legionary-anti-communist" by leaders of left-wing political parties in Romania are certainly exaggerated, 69 with no evidence so far suggesting any legionary sympathies for USR. However, in light of the aforementioned association of communism in Romania with "the Jews" in contemporary anti-Semitic discourse, as well as of the challenges such legislation poses to freedom of speech and association, this remains a worrying development.
Returning to the 2015 legislation in Romania and Ukraine, not only the letter of the laws but also the respective reactions to them are very significant. While the Ukrainian legislation has been highly criticised internationally, from international organisations such as the OSCe or the Council of europe's Venice Commission 70 to scholars and experts on Ukraine, 71 it proved less divisive than initially anticipatedgiven the presumably divergent memories of World War II and the Soviet regime prevalent in eastern and Western Ukraine-and no significant challenges have been mounted against it within Ukraine. 72 Instead, as the recent decision to commemorate Stepan Bandera shows, the government has proceeded unabated with glorifying fascists and extreme anti-Semites as national heroes, with the quiet acquiescence if not support of the Ukrainian population. In contrast, the 2015 legislation in Romania has been positively received abroad and by scholars working on fascism and the Holocaust in Romania, while sparking huge controversies within Romanian public space.
The law was nicknamed the "anti-legionary law" (with the curious implication that this would somehow be a bad thing), 73 and, with very few exceptions, the Romanian historical establishment and some of the country's most prominent public intellectuals spoke out against it. The arguments employed and their level of sophistication varied, from neo-legionary apologists who called it "a frontal attack on the National Memory of anti-communist heroes and martyrs"; 74 through those of Marius Oprea, Romanian historian and member of the Special Investigations Department of the Romanian Institute for the Investigation of the Crimes of Communism and the Memory of the Romanian exile (IICCMeR), who claimed that those falling under its incidence were being condemned a second time and their "past nationalism, including their adherence to the Legionary Movement, was being stigmatized as fascism"; 75 to andrei Pleşu, arguably the most visible public intellectual in post-communist Romania, who, while clarifying that he "consider[s] the Holocaust a disgusting crime" and "the legionary movement deficient precisely at the level of its principles: it is un-Romanian and un-Orthodox, through a (rather Muslim) overvaluation of death," found it "inadmissible not to speak, in the text of the law in question, also about the bloody symmetrical catastrophe, that of communism" and found it reminiscent of the "scourge of cultural interdiction" of the "previous regime." 76 a statement issued by the Director of the Romanian Institute for the Study of Totalitarianism of the Romanian academy, Radu Ciuceanu, in June 2015, citing an earlier public statement of Dan Berindei, member of the academy and President of its History section, specified that "the Legionary Movement cannot be qualified as 'fascist,' insofar as it does not meet, through the elements of doctrine that it adopted and promoted, a fascist ideological character." 77 This assessment of the most prestigious historical establishment in the country is directly contradicted by virtually all of the specialist literature on interwar fascism, from the most prominent international experts on the subject, such as Roger griffin, Stanley Payne, Robert Paxton, etc., to Romanian scholars of the legionary movement, such as Mihai Chioveanu, Constantin Iordachi, Valentin Săndulescu, or myself. 78 The claim of the Director of IICCMeR, Radu Preda, that the "anti-legionary law" was "pro-communist" by omission, since it did not prohibit the apology of communism, prompted the resignation of five members of the institution's Scientific Council-Dennis Deletant, adrian Cioroianu, Zoe Petre, Cristian Pârvulescu, and William Totok-after their demand for his resignation was not met. 79 Worse yet, the whitewashing of the Romanian legionary movement in the context of the "double genocide" and the related depictions of its members as victims and "martyrs" of the communist regime was accompanied in the reactions to Law 217/2015 by explicit anti-Semitic overtones. Thus, even though the law had been initiated by three politicians from the National Liberal Party, its "moral author" was invariably identified as the National Institute for the Study of the Holocaust in Romania "elie Wiesel." From less-than-subtle irony such as that of andrei Pleşu, who found that its Director, alexandru Florian, "goes about with a calliper through Romanian cultural space, armed with a self-certainty that is a little strident" 80 to Marius Oprea bringing into discussion Florian's ethnicity and questioning his empathy for the suffering of Romanians, the "Jewishness" of the INSHR-eW and its leadership as well as the communist past of Florian and others were invoked. 81 In more extreme views, the INSHR-eW was depicted as "hunters of Romanians," 82 "a Jewish gestapo," 83 or, in a formulation familiar from anti-Semitic conspiracy theories, Romania was presented as being "under the control of INSHR-eW." 84 From the more sober opponents of the law, it became clear that what was at stake were the reputations of interwar luminaries of Romanian culture, including Constantin Noica, emil Cioran, and Mircea eliade, all three sympathisers of the legionary movement, 85 as well as of personalities such as Nichifor Crainic, Vintilă Horia-both authors of numerous anti-Semitic, pro-fascist, and pro-Nazi articles during the interwar period-and Mircea Vulcănescu. The latter was Sub-secretary of State at the Ministry of Finance under the antonescu government, a capacity in which "he participated in cabinet discussions about the legal definition of the Jew, proposed and made decisions regarding discriminatory taxation of Jews, [and] praised the ghetto system utilised in Nazi germany." 86 Despite sentences for war crimes passed for Crainic and Vulcănescu, and for promoting fascism (in absentia) for Horia by the special courts established after World War II, their juridical rehabilitation remains on the agenda in contemporary Romania, and has been accomplished in 1995 in the case of Crainic. 87 Moreover, as an article authored by Ion Papuc and suggestively titled "The Country under Occupation" shows, this reputation of exponents of Romanian culture with fascist sympathies is juxtaposed to that of "foreigners," according to the familiar dichotomy of "autochthonous and allogenous," where the latter are alternatively identified as persons of different ethnicity or "communists" irrespective of nationality: Instead, ours are still more visible, with all their mistakes, no matter how big: g. Călinescu and Tudor Vianu, Tudor arghezi and Lucian Blaga, Mircea eliade and C. Noica, emil Cioran and Mircea Vulcănescu. They, only they are our moral values, our heroes and our saints. . . . Noting this is not an act of xenophobia, just establishing the equation of a reality that includes us. I love foreigners, but this love, no matter how strong, cannot metamorphose them into indigenous people. They remain what they have been and we really are what we are! 88 With such a statement, it is clear that the nineteenth-century legal definition of Jews as "foreigners" and their consequent exclusion from Romanian society is still a visible feature in contemporary Romanian public discourse, doubled by an association with communism developed by fascist and radical right movements during the interwar period and still persisting in the post-communist one. It is also clear that the influence still exercised by the legionary movement goes far beyond the small number of its contemporary apologists, and that people otherwise adverse to or dismissive of it can rally to defend its interwar members or sympathisers from accusations of "fascism."

Conclusion
The example of the memory laws briefly presented above demonstrates the discrepancy between different memories-official and unofficial, scholarly and unscholarly, public and private, european and local-in Romania and post-communist space more generally, as well as the persistence of anti-Semitism even in situations where both the Jewish minority is numerically insignificant and the legal framework appears to provide appropriate tools for combatting discrimination and Holocaust denial. accounting for this discrepancy, in the framework of the "europeanisation" of Holocaust memory mentioned earlier and its local contestations, is crucial for understanding the "memory wars" over the legacy of World War II and the Holocaust in eastern europe, which, in Romania as elsewhere in the former socialist bloc, are never lacking a certain anti-Semitic component. While an act of vandalism against the childhood home of elie Wiesel in Sighetu Marmaţiei, with grotesque anti-Semitic graffiti reading "Nazi Jew lying in hell with Hitler" and "Public toilet, anti-Semite pedophile," 89 made both national and international headlines last summer, such actions are rare and less widespread than in Western europe. Furthermore, outside the extreme right fringe responsible for them, such acts draw quasi-unanimous condemnation and contempt. as shown above, this is certainly not the case for instances of historical revisionism, where the memory of interwar fascists and anti-Semites is "absolved" by their suffering under communism, a regime that, more often than not, is associated with "the Jews." Such discourses enjoy an aura of respectability and legitimacy, can be espoused not only by far-right sympathisers but by mainstream intellectuals or politicians who equate communism with fascism, and find more resonance with a public for whom the crimes of the former are closer to personal experience than those of the latter. 90 It would be unfair to paint an exclusively negative picture of the issue of anti-Semitism in contemporary Romania. Important scholarly progress on the topic has been made recently, including several excellent works on the role of Romanian institutions in perpetrating the Holocaust 91 and an edited volume dealing with Holocaust memory in post-communist Romania. 92  )-responsible for monitoring it undoubtedly played a major role. The Holocaust is currently mentioned in most of the Romanian history textbooks edited after 1989. However, recent analysis by ana Bărbulescu of its presentation in the six alternative textbooks presently available reveals that only one of the six can be said to represent "a thorough reconstruction of the historical events," with four others having various shortcomings and one omitting it altogether. 95 a project for establishing a Museum of the Holocaust in Bucharest, first launched in 2016, was only approved by President Klaus Iohannis on 8 October 2019, following intense debate over its location. 96 Very importantly, unlike almost any country in europe today, Romania does not have any far-right nationalist parties espousing anti-Semitic discourse in its parliament, and this has been the case for the past eleven years, a situation that also appears likely to continue in the near future.
To return to the January 2019 report on Holocaust remembrance in eU member states mentioned in the introduction to this article, the analysis carried out here qualifies some of its findings with respect to Romania. While progress has certainly been made recently, both in legal terms and at the level of the politics of memory, contemporary Romania is far from representing a "model" when it comes to dealing with anti-Semitism or in terms of public Holocaust memory. Official initiatives in this respect, themselves arguably motivated by instrumental concerns rather than genuine commitment, do not seem to find resonance with the Romanian public, which remains largely opaque and uninterested in such issues. When visible, such interest tends to manifest anti-Semitic overtones, as seen with the controversy surrounding Law 217/2015 and the persistence of the "Judeo-communist" trope. The recent increase in popularity of the legionary movement, possibly in response to the controversy surrounding the 2015 law, is a worrying development, as is the mainstreaming of perceptions of former legionaries as (primarily) victims of the communist regime and the attempts at their posthumous rehabilitation. as such, my assessment of contemporary Romania with regard to manifestations of anti-Semitism is more aligned with that of Michael Shafir: "Compared to other places in east-Central europe, Romania is neither the worst plate (meaty, or fleishig in Yiddish) nor the best portion (dairy, or milchig). It is rather a mixture of the two. and that, without doubt, is not kosher." 97 In this respect, one thing worth re-emphasising is that, as is often the case with anti-Semitism, perceptions of the Jews in contemporary Romania have less to do with the actual Jewish minority living in the country, numerically minute, but rather with long legacies of anti-Semitism in Romanian history and the resulting public memory. against the deeply rooted tendency to perceive Jews not as fellow citizens but as a different and separate national group with its own interests-diverging from or even opposed to Romanian ones-there is a need for emphasis on the "Romanianness" of Romanian Jews, as well as on the fact that anti-Semitism is an inextricable part of Romanian history and not a specialist, "niche" subject of research. This ultimately amounts to reading Jewish suffering not along the lines of empathy for an external persecuted group, but for members of one's own community, as the suffering of Romanian citizens of Jewish faith or nationality. This is also the conclusion Marta Petreu reaches in a book dealing with the "generation of 1927" and their exposure both to fascist ideology and communist repression: Romania has lived through both catastrophes and has the tendency to remember only one of them. . . . and perhaps some day a historian of Romanian thought or culture will be able to speak about this tragedy . . . as a Romanian who knows that Romanians feel as offended as the Jews because during the war Romanian citizens of Jewish ethnicity were killed. . . . Perhaps there will come a time when, accepting our Jews as our own, we will speak about them, about those who perished in the Holocaust-not personally, but collectively-as an irreparable loss: as we speak about our dead from the [Danube-Black Sea] Channel. 98 Beyond the case of Romania, it is clear from the presentation above that the europeanisation of memory still poses major challenges in the region of Central and eastern europe, mostly related to its divergent experience of World War II and its aftermath. given the persistence of the "Judeo-Bolshevik" trope in the region, as well as the importance of the memory of suffering under the communist regimes for the local population, addressing such issues in a european context appears to be a pressing need. after joining the european Union, "the Baltic states and Poland have emerged in the vanguard of the so-called 'new european' commemorative politics, demanding the inclusion of their wartime experiences in the pan-european remembrance of this war," in "a combination of simultaneously seeking recognition from and exercising resistance to the hegemonic 'core european' narrative of what 'europe' is all about." 99 Considering that europeanisation has mostly proceeded as a one-way transfer from West to east, and that (imposed) mimesis of the West and its institutions has stoked animosity in the east, "the abhorrence of compulsory imitation," as Ivan Krastev and Stephen Holmes argue in a recent essay, is central to the current success of "illiberalism" in the region. 100 In a move reminiscent of postcolonial theory, to which some authors make explicit reference, the demand for recognition of the region's "subaltern pasts" 101 can proceed not just to rejection of the Western models, but to their inversion, as when Orbán or Kaczyiński claim that "if the West wants to save itself, it will have to imitate the east." 102 Preventing such reversals, themselves indicative perhaps more of synchronicity with similar developments in Western europe than (just) of a backlash to europeanisation, 103 calls for an engagement with memory on a european level, across the east-West divide, remarkably enduring in Western perceptions 30 years after the collapse of communism. This is certainly not an easy task, entailing "an integrated history of Nazi and Stalinist violence in central and eastern europe that explores the connections between them while clearly distinguishing between their varied forms to thereby also demonstrate what was truly unprecedented about the Holocaust." 104 Navigating this minefield of mutual misperceptions to reach a shared european understanding of the past, while difficult, is however preferable to leaving individual countries to their own mnemonic devices, both from a methodological standpoint-as doing otherwise would reinforce methodological nationalism and would not do justice to historical phenomena that were transnational in nature-and from a political one. Forging an integrated european modern history deserving of the name thus requires also reading the history of anti-Semitism in the entangled contexts of nation-building, a process that in the countries of the former socialist bloc continues even in the post-communist period.