Domestic Violence (GREVIO) published an annual report focusing on child custody, visitation and domestic violence. In its 1st General Report, GREVIO51 commented that three shortcomings existed with regards to the protection afforded to women victims of domestic violence and their children in the context of custody and visitation decisions. These concern the provision of protection and support to child witnesses of domestic violence, insufficient measures to ensure the safety of mothers who are victims of domestic violence and their children in decisions regarding child custody and visitation, and mandatory mediation in civil procedures and divorce proceedings that address child custody matters. These shortcomings continue to persist while a number of additional issues have emerged. According to the report: “It is now clear that the minimisation of domestic violence within family court processes is closely linked to an increasing use of the concept of “parental alienation” to undermine the views of child victims of domestic violence who fear contact with parents who have perpetrated domestic abuse89 despite the obvious risks this would entail for both adult and child victims.”