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U.S.-led troops are under attack every day from foreign fighters in Iraq. But just how many of those insurgents are coming from Europe? A string of recent arrests suggests that a small but determined band of extremists is exporting young Muslim men in Europe to Iraq for jihad. Last week, German authorities arrested two men in Mainz: one an Iraqi who police say is an al-Qaeda-trained militant and recruiter of local Muslim youths for the insurgency, the other a Palestinian who is allegedly one of his recruits. In Paris, police arrested 11 people they say were involved in a recruitment cell with links to four French nationals killed in Iraq since July. Two of the 11 were preparing to leave for Syria en route to Iraq, according to French investigators. Security officials across the European Union are moving to stop the flow, while in Britain the government has caused a storm with proposals for powers to sentence some suspected terrorists to indefinite house arrest — without charge or trial.

Intelligence officials and independent experts estimate that there are between 1,000 and 3,000 foreign insurgents in Iraq. Between 30 and 50 of those are believed by French authorities to have been recruited and deployed from Europe. But E.U. governments are worried that any initial success in ferrying Europeans to Iraq will inspire recruiters and potential volunteers alike, posing a threat not just to coalition troops in Iraq but to Europeans back home. "The total number involved in recruitment or as fighters in Iraq is small," says one French counterterrorism official. "But it holds a truly terrible potential if it were allowed to grow. If these people manage to get to Iraq and learn how to wage jihad, we risk seeing them return to continue in Europe."

Police suspect the two men nabbed in Germany were preparing to stage a fatal car accident in Egypt so one of them could collect on life insurance policies worth just over j830,000. German federal prosecutor Kay Nehm said the money would have funded attacks in Iraq. Prosecutors also allege that one of the men tried to buy 48 g of enriched uranium in Luxembourg — not enough for a bomb but, as E.U. terror czar Gijs de Vries said, "a risk we must take seriously."

Apprehending terror suspects is one thing; convicting them is another. That difficulty was highlighted last week in Milan when five Muslim men who had recruited fighters for Iraq were acquitted of terrorism charges. Judge Clementina Forleo noted that the 1999 draft U.N. convention on terrorism stipulates that paramilitary activity in war zones does not violate international law as long as it does not target civilians. Because there was no evidence that the men recruited by the two Moroccan and three Tunisian defendants planned to attack civilians, Forleo ruled that their actions hadn't "exceeded guerrilla activity" — even though she conceded that the men had signed up militants to go to Iraq. They were convicted of immigration offenses. The terror judgment sparked "rage and disbelief" from Italian Foreign Minister Gianfranco Fini, who termed the verdict "a shameless distortion of reality before the eyes of the entire world." Prosecutors plan to appeal the decision.

Since existing rules don't always allow officials to prevent local radicals from getting to Iraq — or causing mayhem in Europe — the British government wants to change the rules. British Home Secretary Charles Clarke last week announced plans to dramatically extend the state's powers to deal with suspected terrorists in Britain.

Antiterrorist legislation introduced after Sept. 11 has allowed 11 foreign suspects to be held in high-security jails without charge or trial, a situation human-rights activists have dubbed "Britain's Guantánamo." The U.K.'s highest court of appeal in December declared that the measures unlawfully discriminate against non-British citizens; the laws don't apply to U.K. nationals. In response, Clarke wants to expand the law to encompass Britons, too. But instead of prison, suspects will be subject to house arrest and other "control orders" like electronic tagging and curfews in cases where prosecution or deportation is impossible. "First we go down the prosecution route," Clarke said, "but in the event that we can't do that, I'm not prepared to ... allow these people to succeed."

The human-rights community is up in arms. "House arrest seems to be something that happens in places like Burma," said lawyer Louise Christian, who represents two of the four British detainees who returned from Guantánamo Bay last week. A major concern is that the Home Secretary, not a court, would impose a control order, and also that "people may not be allowed to know the evidence held against them," says Doug Jewell of the human-rights organization Liberty. But the British government appears undaunted. Balancing the need to protect the public from terrorism while upholding individual civil liberties has never seemed harder.

• BRUCE CRUMLEY | Paris and HELEN GIBSON | London
• How Europe is trying to stop militants from going to Iraq