New Article: New targets, old tools - The G7 ups momentum around the use of sanctions against migrant smugglers and human traffickers

On 11 July, the GI-TOC published my article on the rising use of targeted sanctions to counter human smuggling, and good practices for those considering such approaches.

The article can be found here: https://globalinitiative.net/analysis/g7-sanctions-migrant-smugglers-human-traffickers/

It is reprinted below:

New targets, old tools - The G7 ups momentum around the use of sanctions against migrant smugglers and human traffickers

Human trafficking and the smuggling of migrants continue to dominate political debates and multilateral discourse as leaders search for new tools and strategies to address these crimes. In this context, targeted financial and mobility sanctions have recently emerged as a high-profile option for policymakers. 

In June 2025, the Group of Seven (G7) became the latest forum to endorse the use of sanctions to counter migrant smuggling and human trafficking. In a communiqué issued after their latest meeting in Kananaskis, Canada, G7 leaders stated: ‘We will explore, consistent with our legal systems, the potential use of sanctions to target criminals involved in migrant smuggling and human trafficking operations from countries where those activities emanate.’ 

This statement is in line with the growing interest in applying sanctions for this purpose. In January 2025, the UK announced its intention to create a sanctions regime specifically to target the smuggling of migrants, with other jurisdictions also considering the development of similar regimes. 

However, to date, actual designations of smugglers and traffickers have been rare, particularly compared to their use in cases of more frequently targeted forms of criminality, such as drug trafficking, corruption and cybercrime. The US has issued the majority of such sanctions, primarily through its ‘counter transnational crime’ regime (through executive order 13581), to designate migrant smuggling and human trafficking actors in a handful of countries, including Mexico, Guatemala, Pakistan and Myanmar. The UN has designated abusive human smugglers and associated security personnel in Libya and Mali, while the UK has sanctioned traffickers linked to scam centres in South East Asia. 

Due to their rarity, there are few case studies to gauge how sanctions influence and impact migrant smuggling and human trafficking, although there are indications that their use – coupled with other tools – have reshaped smuggling ecosystems in Libya. Research on this issue has identified a number of good practices that states and multilateral bodies should consider if they are looking to increase their deployment of sanctions against criminal actors driving these illicit economies. 

First, the concept of impact needs to be updated and redefined. In traditional nation state-focused sanctions regimes, targeted sanctions on individuals and entities – such as businesses – are aimed at coercing a cessation by the state of a specific activity, such as the development of weapons of mass destruction or involvement in conflict. The intended impact of sanctions is possible because there is a single issue at play, which can be halted by a state’s leadership.  

As research by the Global Initiative Against Transnational Organized Crime (GI-TOC) has underscored, the logic of impact is different when it comes to sanctions on criminal actors such as migrant smugglers and human traffickers, which act as small components of broad and highly adaptive ecosystems. While it may be possible to use sanctions to coerce a degree of individual change among designated individuals, there should be no expectation that this will lead to the complete cessation of these economies.  

Instead, the GI-TOC recommends that when designing sanctions against criminal actors, a more realistic and effective strategic aim involves disrupting and shaping criminal ecosystems. Strategic disruption involves repeated and regular designations that impact an ecosystem’s ability to operate in ways that cause defined harms of concern. Strategic shaping, in turn, involves altering the functioning of a criminal ecosystem by influencing the cost-benefit assessments made by non-designated actors in order to deter or minimize harms, or promote adherence to certain behavioural norms. Effectively, the goal is to move beyond reducing specific risks, as in disruption, to shifting activities and norms among a broad range of non-designated criminal actors through deterrence.  

The disruption and shaping of criminal ecosystems are not only feasible, but also valuable for states looking to counter highly problematic forms of migrant smuggling and human trafficking if properly conceptualized and strategically thought through. In Libya, for example, the use of sanctions has arguably played a role in shifting the prevalence and social acceptability of certain highly abusive forms of migrant smuggling.  

Second, there need to be follow-ups to designations. Sanctions should not be a ‘fire-and-forget’ tool, but rather one that continues to be fine-tuned. As part of this process, regular assessments of regional migrant smuggling and trafficking ecosystems need to be undertaken to identify how they are evolving and adapting to sanctions. Ideally, these assessments should be as widely shared as possible to catalyze coordination between states. 

Third, sanctions are not a silver bullet. They work best when they are part of a broader strategy involving a number of other tools, not all of which are punitive, such as prosecutorial approaches, local law enforcement capacity building and development aid to communities at risk of criminal infiltration. The strategy must also involve a number of countries, including those struggling to counter human trafficking and smuggling networks in their territory. Crucially, such a transnational strategic approach can also help build support for action in countries struggling with human trafficking and migrant smuggling, rather than leaving them singled out for what is, in reality, a transnational problem. 

Fourth, there is a need to understand and design interventions around the entire smuggling and trafficking ecosystems. Migrant smuggling is often considered in terms of individual criminal networks. While these are important, the much broader infrastructure that facilitates them (the private sector actors, corrupt government players and social enablers) must also be taken into account. Focusing sanctions and other tools on actors across an entire ecosystem makes deterrence and shaping far more feasible.  

Fifth, time horizons and public expectations of success are critical considerations. Unlike sanction regimes imposed on states, which may offer a ‘victory’ moment, regimes targeting criminals such as migrant smugglers and traffickers are unlikely to offer a clear end goal. Ending migrant smuggling is unlikely to be accomplished at any point. Rather, sanctions operating as part of a broader, multi-tool strategy are a long-term instrument that can change the functioning of, and the harms caused by, human trafficking and smuggling. This underscores a final point: the importance of proactively and clearly communicating to the public and politicians what they can expect.  

As the G7 leaders’ statement highlights, the imposition of sanctions on human traffickers and smugglers is likely to increase sharply in the coming years. As states consider this approach, it is important that they also acknowledge that sanctions on traffickers and smugglers – and on organized crime more broadly – require a rethinking of the aims, strategies, messaging and assessment of effects compared to the country-focused regimes with which state officials and sanctions units are most familiar. 

New Brief on the impacts of potential US deportations to Libya

I'm delighted to launch my latest policy brief 'Deported into Danger: How Potential US Migrant Expulsions to Libya Could Feed Into the Country's Criminal Economy and Instability.'

The brief focuses on the rumored US plans to deport Third Country Nationals to Libya, explains the migrant detention conditions and criminality they would face, and details how the deportation could further worsen instability in the country.

The brief can be accessed here: https://globalinitiative.net/analysis/how-potential-us-migrant-expulsions-to-libya-could-feed-into-the-countrys-criminal-economy-and-instability/

New article: Haiti - How US terrorist designations could deepen criminal rule and humanitarian tragedy

On 08 May, the GI-TOC published an article I co-authored with Romain Le Cour Grandmaison on the designation by the US of a Haitian gang coalition, as well as a separate gang, as foreign terrorist organizations. It details the potential impacts of the designation on humanitarian assistance and criminality.

The article can be found here: https://globalinitiative.net/analysis/haiti-how-us-terrorist-designations-could-deepen-criminal-rule-and-humanitarian-tragedy/

It is reprinted below:

Haiti: How US terrorist designations could deepen criminal rule and humanitarian tragedy

In the first quarter of 2025, at least 1 617 people were killed in Haiti. As the gangs have tightened their grip over the country, the need for aid is intensifying – more than a million people have been displaced and more than half of the population needs humanitarian assistance, a 9 per cent increase against 2024. Criminal groups have recently launched new offensives, particularly in the Central Plateau and Artibonite regions. The population of these areas risk joining the millions in the capital, Port-au-Prince, who already live under the de facto authority of gangs. 

In this constantly deteriorating situation, on 2 May 2025 the United States designated the Viv Ansanm gang coalition and the Gran Grif gang as foreign terrorist organizations and specially designated global terrorists. The measures bar members of the designated gangs from accessing financial institutions with a US link, and from being issued visas. They also provide for potential legal action and secondary sanctions against individuals or organizations providing various forms of support to the gangs.  

The action is the latest use of counterterrorism measures as a tool to combat organized crime, building on a previous tranche of US designations targeting Latin American gangs and cartels. However, the US designations may inadvertently worsen the situation on the ground by impeding humanitarian assistance, strengthening gang governance and empowering broader criminal networks. This may drive further entrenchment of designees in the illicit political economy. But in the short term, the most pressing concern is whether the US designations will prevent Haitian and international NGOs from continuing to deliver aid to communities in gang-controlled areas that lack public services.  

For NGOs working in areas under gang control in Haiti, as in other locations, negotiating access with criminal leaders is often a necessary condition for reaching affected populations. In such contexts, it is these non-state actors (and not official authorities) who dictate the terms of engagement, effectively exercising control over communities and restricting humanitarian access. Under prevailing sanctions regimes, these dynamics expose humanitarian organizations to legal and reputational risks, including potential liability for engaging – even indirectly – with sanctioned or criminal entities.  There is therefore growing concern within the aid community that organizations could lose funding or face legal risks – including prosecution. Under the terrorist designation, the assistance they provide could now be classified as ‘material support’ to terrorist groups. 

The inability to provide assistance could also indirectly deepen gang governance. If people find themselves even more isolated than they are today, living under the thumb of criminal leaders, the bargaining power of those bosses will be strengthened. Gangs are also likely to increase the pressure they exert through widespread extortion and territorial expansion to secure their sources of income. Finally, a halt to humanitarian support could be used by criminal leaders as another element of propaganda against international action in Haiti, which Viv Ansanm regularly condemns as foreign interference. 

‘Invisible’ exemptions  

US policy provides mechanisms to mitigate these risks, to the extent that exemptions exist to allow humanitarian activities to continue in such contexts. In December 2022, the US Department of the Treasury’s  Office of Foreign Asset Control (OFAC) issued a series of general licences that authorize certain humanitarian activities that might otherwise be prohibited under US sanctions programmes, including those targeted at terrorist actors. These were introduced as part of the implementation of the UN’s Security Council resolution 2664, which authorized a humanitarian exemption to asset freezes in various UN sanctions regimes.  

The issuing of these licences underscores the US government’s recognition of the complexities involved in conducting humanitarian operations in sanctioned jurisdictions. In the past, such measures have been taken to ensure that the provision of humanitarian aid is not impeded by overly stringent sanctions enforcement. Notably, the licences are self-executing, meaning that entities or individuals who reasonably determine that their activities fall within the scope of the authorization may proceed without needing to obtain pre-approval or additional guidance from the OFAC. 

Alarmingly, however, and reflecting the wider lack of strategic coherence currently blighting Haiti, whether these exemptions continue to apply in the face of the new designations does not appear to have been communicated to the humanitarian sector – either by the US authorities, the Haitian government or international partners.  

Therefore, despite this legal framework, there are concerns about its implementation on the ground, particularly in Haiti. The Trump administration’s commitment to the general licences issued under the Biden administration is uncertain. There is also lack of clarity in terms of how and to what extent NGOs working in Haiti are familiar with or can rely on the general licences. And questions remain about the coordination of these efforts with the Haitian authorities. The lack of a clearly articulated and coordinated strategy casts doubt on the effectiveness of these measures in practice. 

Fuelling the underworld?  

From a more structural perspective, the ability of humanitarian actors to carry out their operations is directly linked to their ability to access international financial services, which could be cut off or hampered in the context of sanctions. The perceived legal and operational risks associated with sanctions compliance may lead financial institutions and money transfer companies to scale back or even withdraw from Haiti. For example, companies such as Western Union may reduce or cease operations in the country due to potential exposure under US law, even if their activities are technically authorized.  

The broader concern is that a strict or inconsistent interpretation of sanctions might lead to widespread de-risking, whereby financial institutions disengage entirely from high-risk regions. Unable to use formal banking channels, NGOs are often forced to rely on informal systems, increasing operational risks and reducing oversight.  

This constrained operating environment also creates space for criminal networks and illicit actors to exploit the aid vacuum, which in the medium and long term could expand rather than constrain the power and scope of the gangs and associated illicit economies in Haiti. 

Regulated financial channels are heavily used by the diaspora to send remittances and by Haitian businesses to move funds. With those potentially blocked, unregulated intermediaries – including some fintech companies and money services businesses – could step in to facilitate transactions, potentially without adequate scrutiny. This not only hampers humanitarian access, but also risks increasing informality, further weakening local institutions and strengthening criminal financing structures. 

Previous research by the Global Initiative Against Transnational Organized Crime (GI-TOC) has underscored how far-reaching sanctions have a shaping impact on criminal economies – such as in Guinea-Bissau and the Central African Republic – with criminal actors exploiting new opportunities for profit. Moreover, the experience of Somalia provides a relevant comparative example. In response to the terrorist designation of al-Shabaab by the US, the UN and others in the international community, major banks cut ties with Somali money services businesses and clients, leading to a significant reduction in formal financial access. This, in turn, affected remittances from the diaspora and increased reliance on informal financial networks, which are more vulnerable to exploitation by criminal actors and can facilitate money laundering and other illicit activities.  

In the case of Somalia, de-risking in response to the terrorist designation arguably exacerbated rather than mitigated the risks posed by terrorism and criminality, such as by expanding financial channels used for arms trafficking. In the Haitian context, it is critical that US authorities engage with banks and money services businesses to prevent such de-risking. At the same time, however, humanitarian actors should prepare for the possibility of disruptions to remittances and financial access, and consider how this might affect humanitarian needs and their own operations. 

A 180-degree turn is urgently needed 

Without appropriate safeguards, the terrorist designations risk further destabilizing Haiti and inadvertently empowering gang structures, which previous GI-TOC research suggests are likely to remain largely unaffected by sanctions alone. And, without coordination with a clear security and judicial strategy, particularly to dismantle political-criminal networks, the designations risk becoming yet another policy tool that is poorly used or not used at all.  

It is troubling that these designations have not been accompanied by robust engagement, strategic coordination or technical support from the United States, the Haitian authorities and the international community. Immediate action is needed to provide clarity, facilitate the work of NGOs and ensure the continued delivery of life-saving assistance to a population whose latest misfortune is to have been left vulnerable to the rule of armed criminal groups. 

New Interview on China's Foreign Law Enforcement Assistance and US Responses

On 12 March, USIP’s Ena Dion and I were interviewed by USIP on China’s growing foreign law enforcement aid program and how the US should respond. The original interview can be found here: https://www.usip.org/publications/2025/03/how-china-uses-police-assistance-reshape-global-security

It is reprinted below:

What is foreign law enforcement assistance and why do states use it?

Dion: Foreign law enforcement assistance refers to one country’s support or aid to another country’s law enforcement agencies to assist them in combating crime, maintaining security and upholding justice. This assistance can take various forms. Some of the most common are training and capacity building for criminal justice actors, or transfers of technology and equipment to law enforcement bodies for investigations.

While this might seem like a one-way street, foreign law enforcement assistance is closely tied to broader security cooperation, wherein the law enforcement agencies of various countries work together to address transnational crime, terrorism and other security threats that transcend borders and are of common interest. This includes activities such as information and intelligence sharing, joint investigations and joint operations.

Why has China expanded its use of foreign law enforcement engagements?

Herbert: Since the early 2000s China has substantially increased the scope and geographic reach of its law enforcement assistance. Growth accelerated after the launch of the Global Security Initiative in April 2022, which lays out a framework for China to take on an expanded role and influence in international security. This is part of a broader movement toward increased external engagement. Growth in law enforcement assistance, however, has been less visible than parallel upticks in economic, military and diplomatic engagements.

This links to Beijing’s strategic-level goals, in which China has sought to develop a cadre of allies as a counterbalance to U.S. and Western power and to reshape the international security environment to their interests.

Dion: In September 2024, at a security forum attended by representatives from 122 countries, China’s Minister for Public Security Wang Xiaohong described China’s aims to train thousands of overseas law enforcement officers to “develop in a more fair, reasonable and efficient direction” for global security. While not wholly clear, China’s alternate vision for global security includes greater emphasis on preserving state or party strength and stability — and less focus on a strong civil society.

For policing, this includes a model that puts a significant focus on policing social order and relies heavily on surveillance technology. More operationally, China uses foreign law enforcement assistance to protect its interests abroad — such as investment projects, Chinese workers and diaspora populations — from terrorism, civil unrest or petty crime. This operational case is less discussed internationally but is very important for China domestically and has had a noticeable influence on where and how they provide assistance.  

Where does China’s law enforcement assistance currently stand?

Herbert: While increasing, Chinese law enforcement assistance is still relatively small in both the scale and breadth of packages offered. 

Starting with the scale — in 2023, China reportedly provided training to 2,700 foreign officers. Mostly, this involved two-to-three-week training opportunities in China offered to relatively small groups of officers. However, there appears to be movement toward increased field training. Nonetheless, there is a clear trend over time toward an increase in this training level, which Chinese officials have indicated will be sustained, with an aim to train 3,000 officers in 2025.

While this may sound large, it’s only a fraction of what some other major powers train in an average year.

And when it comes to equipment, there are examples where Chinese assistance has been consistent. Larger equipment packages are heavy on transfers of technology, particularly surveillance equipment. But more often, equipment aid is sporadic and small in scale — sometimes as small as constructing a single police post or providing a few motorcycles.

Dion: As for the breadth of assistance, many Chinese assistance efforts pursue targeted goals closely tied to Chinese interests. These include protecting Chinese economic interests or foreign investments, protecting or controlling the Chinese diaspora, and, many believe, gathering information through backdoors in security technologies.

This limited focus has been a point of frustration for some foreign law enforcement officers, who have stressed that there is frequently a divergence between China’s interests and their own core operational challenges and assistance needs — and that there was limited operational engagement with Chinese police after the assistance programs had been completed.

What concerns do China’s investments in foreign law enforcement assistance raise for the U.S. interests?

Dion: While still in the nascent stages, the uptick in Chinese investment in foreign law enforcement assistance has raised several concerns for U.S. observers.

First, there is a concern that law enforcement assistance will help China develop stronger relationships with strategically important countries, resulting in a coalition willing to back Chinese policies on the international stage. China hopes a strong coalition would allow them to reshape global norms and institutions, including those related to security. This is compounded by concern that safeguards on U.S. support — such as the Leahy Law, which disallows assistance to foreign security forces credibly accused of gross violations of human rights — give China, which has no similar restrictions, more ability to maneuver in such contexts.

Secondly, there is a fear that Chinese assistance will successfully export a model of policing that enables or encourages authoritarianism via trainings geared toward that approach, as well as via Chinese-provided technologies — both part of law enforcement assistance packages and transferred via other channels — that may enable politically motivated surveillance and unauthorized data collection, particularly of government opponents. Some also fear the prevalence of Chinese tech will lead to dependence on China for maintenance and repairs, thus undercutting U.S. technological cooperation.

Lastly, concerns about Chinese police assistance are closely tied to concerns about the growing network of Chinese “service centers.” These centers have been established by China’s regional public security bureaus (not police) in 53 countries globally, sometimes without the host country’s permission or knowledge. The Chinese Foreign Ministry claims they provide administrative services to Chinese citizens living overseas, like renewing drivers’ licenses and national ID cards. However, they’ve been implicated in monitoring, controlling and coercing Chinese dissidents abroad and spreading propaganda. Several countries — including the U.S., Canada and the U.K. — are investigating the centers, with the U.S. Department of Justice deeming them a threat to sovereignty.

How can the U.S. conceptualize a response to rising Chinese assistance?

Herbert: For the U.S., responding to the challenge posed by rising Chinese law enforcement assistance involves two elements: one regarding global engagement and the other a review and adaptation of our own approaches.

1. Use diplomatic and law enforcement engagement to underscore the risks associated with the Chinese approach to policing.

At a global level, the U.S. can avoid ostracizing recipients of Chinese law enforcement aid. Interviews have underscored there is a genuine demand, especially within security forces around the globe, for the type of training, equipment and operational support that the United States can provide.

Despite its efforts, China does not yet offer a credible alternative. And while there is also genuine international demand for Chinese assistance, particularly its technologic components, assessments of such support and the feasibility of the Chinese model abroad are decidedly mixed among its recipients. However, welcoming Chinese assistance does not necessarily imply a preference for Chinese style policing or politics. Rather, many security officials interviewed for our report described it as a pragmatic decision to fill gaps in capacity or equipment.

Notably, complaints about the utility of Chinese training and the performance of equipment are common. In turn, the instillation of extensive surveillance networks in a number of African cities, promoted by China as a key policing tool, have not been correlated with a substantial decline in crime rates — with crime in Nairobi actually increasing.

This creates an opportunity for the U.S. to buttress its influence with a wide swath of foreign countries through continued law enforcement support. It risks being counterproductive for the U.S. to simply cut off a country that accepts any support from China. A U.S. approach that focuses on the gaps in capacity that drive specific states to accept Chinese assistance would likely yield greater strategic benefit and undercut China’s long-term trajectory in this field.

Meanwhile, deeper U.S. study on the performance of Chinese law enforcement approaches in other states, coupled with active efforts to strategically disseminate those findings, could be a potentially powerful way to underscore the limited uses for Chinese law enforcement assistance.

2. The U.S. should review and adapt its own approach to providing foreign law enforcement support.

In responding to rising Chinese assistance, it’s important to also reflect on what the U.S. does right. Unlike China, the U.S. provides trainings around the world, mostly in host countries or at regional law enforcement academies. This localized approach maximizes the number of billets in training initiatives while minimizing extraneous costs, such as airline tickets and hotels.

U.S. programs also provide significant amounts of equipment and supplies that are readily used and are often important parts of long-term partnerships, including in strategically important countries such as Colombia, the Philippines and Kenya.

Finally, U.S. programs aim to strengthen effectiveness of whole systems, from investigations through prosecution and incarceration. The U.S. frequently aims to achieve systemic change — enhancing whole-of-sector capacity, building or reforming institutions. Underlying this approach is an understanding that it is more cost-effective for the United States to equip partner forces to address a security threat than to risk the need for direct U.S. intervention.

Building on this through a review and re-envisioning of the strategic goals of law enforcement assistance is an essential approach in responding to rising Chinese activity. A more efficient and cost-effective system focused on strategic objectives across different departments and bureaus can address threats to U.S. national security before their impacts are felt at home, reduce the need for direct U.S. intervention, and outcompete China’s security assistance model.

The United States can also make a substantial and much-needed difference on the provision of technology and technical skills — an area where China has already made extensive inroads.

Interviewed officers in multiple countries have stressed their concern about the data-integrity risks associated with Chinese-donated equipment. However, there are currently very few alternative options, particularly at a low price. A strategy to connect U.S. technology companies and foreign police officials can help undercut China’s growing dominance in this respect.

Finally, federal law enforcement staff operating abroad play a critical role, implementing trainings, offering investigative support and cultivating relationships with local law enforcement officers.

In interviews with foreign law enforcement officials in Africa, Latin America and Asia, a common thread was appreciation not only for the breadth and quality of U.S. programs, but also for the ways in which they lead to this tangible follow-up and operational coordination with U.S. law enforcement. 

These partnerships can sustain broader openness to U.S. security cooperation on areas of mutual interest in strategically critical regions around the world.