“9·11”事件后,各国反恐法呈勃兴态势,在立法模式上有英美和欧陆之分,前者致力于制定单行的反恐法,后者以修订刑事法典为主;在立法内容上表现出强调追诉机关的协作、强化强制措施处分权甚至突破国际人权法规范的趋势。尽管因金融危机和拉登之死,反恐短暂式微,但后“9·11”时代的反恐法仍然具有重要借鉴意义,包括提供极端犯罪的治理经验和危机处理方法,促进国际区域刑事法的整合,以及谨守国际人权和法治底线的重要性。中国反恐法方兴未艾,立法模式上注重英美和欧陆模式的结合,但仍需要注重立法上的衔接;立法内容上回应了国际上的立法趋势,但在坚持法治底线方面还要进一步完善。 After the “9.11” incident, the counter-terrorism laws of various countries have been booming. There are the Anglo-American and European divisions in the legislative model. The former is devoted to formulating a single anti-terrorism law, while the latter is mainly based on the revision of the criminal code. In terms of legislation It shows that it emphasizes the coordination of the prosecution authorities and strengthens the tendency of the compulsory measures to dispose of and even breaks through the norms of international human rights law. Despite the short-lived anti-terrorism campaign due to the financial crisis and bin Laden’s death, anti-terrorism laws in the 9-11 era are still of important referential significance. They include the provision of governance experiences and crisis management methods for extreme crimes and the promotion of criminal law in international jurisdictions Integration and the importance of observing the bottom line of international human rights and the rule of law. While China’s anti-terrorism law is in the ascendant and the legislative model focuses on the combination of Anglo-American and European models, it still needs to pay attention to the convergence of legislation. While the content of the legislation responds to the trend of international legislation, it still needs to be further consummated in adhering to the bottom line of the rule of law.