EU Externalization of Migration Control and Its Human Rights Implications
- Human Rights Research Center
- Nov 13, 2025
- 16 min read
Author: Carla Lagemann
November 13, 2025
![[Image source: European Parliament]](https://static.wixstatic.com/media/e28a6b_9188da324d224ec19fd048fbe552877a~mv2.png/v1/fill/w_980,h_616,al_c,q_90,usm_0.66_1.00_0.01,enc_avif,quality_auto/e28a6b_9188da324d224ec19fd048fbe552877a~mv2.png)
Introduction
The European Union’s (EU) recent agreements with partner countries to curb migration into its territory have raised serious questions about its complicity in human rights violations and its accountability. EU externalization of migration control does not yet have a unified definition, however, it can be described as a set of policies that manage migration beyond the physical territory of EU Member States.[1] The main objective of externalization is “to stop incoming migrants before they reach their final destination.”[2] The EU’s externalization of these practices has significant implications for the protection of human rights, particularly when looking at case studies of partners such as Libya and Mauritania, which serve as bridges for migrants between continental Africa and the EU. As a result, these observations raise two main concerns: 1) what human rights violations migrants face in Libya and Mauritania, and the EU’s role in them, and 2) how responsibility can be attributed to the EU and its Member States in light of legal frameworks and accountability gaps.
Background on EU Externalization
In 2005, the European Council signed its Global Approach to Migration and Mobility (GAMM), a framework that coordinates the EU’s external migration policy with non-EU partner countries.[3] The main objectives of the GAMM are to create opportunities for legal migration, promote international protection, and reduce irregular migration.[4] Several direct agreements between the EU and individual external states for cooperation in mobility and migration emerged from the GAMM as early as 2008 with the Treaty of Friendship, Partnership, and Cooperation between Libya and Italy.[5] Italy provided $5 billion US dollars to Libya in exchange for tightening control of its territorial waters and “accept[ing] disembarkation on its soil of individuals intercepted at sea by Italian vessels,” which led to over 1,000 individuals being returned to Libya within a span of 4 months in 2009 alone.[6]
The EU now has ongoing agreements with countries such as Türkiye, Morocco, and Mauritania. The 2024 deal between Mauritania and the EU provided Mauritania with $244 million US dollars to curb undocumented migration to the Canary Islands—a common destination for African migrants attempting to reach mainland Europe. However, these agreements are not limited to financial assistance. Beyond funding, these agreements encompass a range of operational measures, including the provision of surveillance equipment—such as vehicles and vessels—and the expansion and improvement of databases and information systems. For example, EU funding has been channeled toward equipment, such as specialized patrol vessels for the Libyan Coast Guard, drones, and remote sensing systems.[7]
The EU presents its externalization processes as necessary for shared responsibility and tackling irregular migration and migrant smuggling. From its own perspective, partnering with external states allows for a coordinated approach to migration management while relieving pressure from its own borders. While effectiveness and control are viewed as necessary for the EU to advance its migrant policy objectives, its externalization of migration management has been heavily criticized for enabling or facilitating human rights violations committed by partner countries.
Human Rights Violations
In order to provide a thorough understanding of the human rights consequences of the EU’s externalization of migration control, this section considers two significant case studies, Libya and Mauritania, which have been heavily scrutinized for their human rights abuses in recent years.
Libya
As a central partner in the EU’s externalization of migrant control, Libya has received hundreds of millions of US dollars for migration control, such as in 2018 where it received over 388 million euros.[8] These funds have supported the Libyan Coast Guard, bolstered the country’s detention infrastructure, and provided surveillance technologies used to mitigate migration into EU territory.[9] The Libyan Coast Guard has been under international scrutiny for its human rights abuses, with the Office for the High Commissioner of Human Rights (OHCHR) reporting a “pattern of reckless and violent behavior” by the Libyan Coast Guard—including actions such as firing at migrant vessels, intentionally ramming boats to capsize them, and even physical violence against migrants.[10] The Coast Guard is notorious for forcibly sending migrants back to Libya, despite the country being considered an unsafe place for return or disembarkation of returned migrants,[11] potentially violating the human rights principle of non-refoulement.[12] Migrants who are returned to Libya have been found to face the risk of death, disappearance, arbitrary detention, torture, ill-treatment, gender-based violence, exploitation, and other human rights violations and abuses by both Member State and non-Member State actors.[13] Many migrants in the country face imminent arbitrary detention with no formal registration, no legal process, no access to judicial remedies, and their documents and personal belongings are often confiscated.[14] They are also held in unofficial places of detention in conditions “falling far short of international human rights standards”—with severe overcrowding, little ventilation and natural light, lack of access to sanitation facilities (causing the rapid spread of diseases such as scabies and chickenpox), and the lack of provision of sufficient calories provided to migrants (leading to acute malnutrition).[15] Amnesty International has also reported that security forces, armed groups, and militias have “continued to commit widespread and systematic human rights violations and abuses against refugees and migrants with impunity” in Libya.[16]
By funding and equipping the Libyan Coast Guard and other Libyan groups with the tools to intercept, detain, and forcibly return migrants, the EU and contributing Member States have been found to be complicit in Libya’s human rights violations. According to Amnesty International, using financial and technical leverage to implement stricter border control measures—particularly with a country such as Libya, where systematic human rights violations against migrants have been extensively documented—risks leaving thousands of refugees and migrants trapped in unsafe conditions, with little or no access to effective protection.[17] OHCHR suggests the evidence is not a “tragic anomaly, but rather a consequence of concrete policy decisions and practices” not only of the Libyan authorities, but also of the EU and its Member States and institutions. This has created an environment where the “dignity and human rights of migrants are at risk.”[18] By not only being fully aware of these abuses but also continuing to provide support to the Libyan authorities in their abusive migration control tactics, the EU is complicit in them.[19]
Mauritania
The EU has similarly funded Mauritania’s Police, Coast Guard, and Gendarmerie, providing assistance in training procurement of equipment and operational support for border management.[20] The first cooperation agreement with Mauritania was signed in 2003, spearheaded by Spain through a bilateral agreement with the country. In the EU’s new deal with the country, signed in early 2024, the EU allocated 210 million Euros to Mauritania, further reinforcing Europe’s involvement in Mauritania’s migration control practices. Amongst the agreement’s primary objectives is the effort to “build capabilities and capacities … for border management … including through enhanced cooperation between Mauritania and Frontex.”[21] Frontex, the EU border guard agency, has been criticized by Human Rights Watch for failing to “safeguard people against serious human rights violations at the EU’s external borders,” and, despite repeated human rights violations being brought to its attention, the agency failed to “credibly investigate or take steps to mitigate abuses against migrants.”[22] In 2024, Frontex’s Operation HERA—an operation found to have “unclear screening activities” of migrants as well as “accountability and transparency deficits”—had still not yet been evaluated on its “impact on … the human rights of migrants.”[23]
An OHCHR report from September 2025 found that Mauritania is involved in numerous human rights violations—causing increased concern over its consideration for human rights—flagging practices such as collective expulsion of migrants with no possibility of appeal or legal aid, physical and sexual abuse of women, and racial discrimination perpetrated by law enforcement officials in the country.[24] The United Nations Special Rapporteur on the human rights of migrants reports that migrants’ United Nations High Commissioner for Refugees (UNHCR)-issued documents—such as refugee cards, asylum-seeker certificates, and appointment slips—are confiscated and destroyed, which has left these migrants with no means of identification and, consequently, vulnerable to refoulement. In addition to the potential violation of this human rights principle, the Special Rapporteur noted that this practice occurs repeatedly for the same individuals, and collective expulsion without individual assessment is a violation of the 1951 Refugee Convention and the Convention Against Torture.[25] A Human Rights Watch report from August 2025 documented interviews with 78 victims of violations in Mauritania in which the individuals detailed abuses including violence and physical abuse, torture, rape, recurring inhumane conditions of detention, and extortion.[26] Similarly, a European Parliament report from 2023 found a “high risk of violations of fundamental rights and international protection obligations that are of a serious nature and likely to persist” in Mauritania and that there are potential “severe accountability gaps in the event of … rights violations.”[27]
The EU’s funding for the expansion and strengthening of Mauritania’s migration control apparatus—both through financial support and Frontex cooperation—despite its awareness of Mauritania’s human rights abuses over the years, raises concerns about the EU’s role in these violations. Human Rights Watch concludes that “by funding, equipping, and collaborating with Mauritanian forces for years to bolster border and migration controls without ensuring adequate human rights safeguards, the EU and Spain [incentivize] repression of migration and share responsibility for abuses in Mauritania.”[28] Indeed, this exploration raises questions of legal accountability not only in Mauritania and Libya, but also in the EU’s dealings with other partner countries.
EU Accountability and Gaps
A 2025 Amnesty International briefing highlights that recent migration agreements by the EU and its Member States have “taken an informal format” and have been “negotiated by ad hoc configurations of actors,” which plays a significant role in limiting transparency on the beneficiaries and impact of EU funds.[29] Amnesty notes that the lack of consultation with EU civil society organizations and third countries has raised doubts about the EU’s statements of commitment to support civil society in these partner countries. Additionally, the absence of concrete efforts being made to ensure human rights compliance further exacerbates concerns over EU accountability. There have been no impact assessments on human rights prior to the agreements being signed, casting additional doubt on their adherence to human rights obligations. The absence of these assessments and the creation of the agreements themselves has “weak[ened] Europe’s credibility as an autonomous global power and credible human rights actor.”[30] These practical gaps in transparency, consultation, and human rights due diligence highlight the broader legal and conceptual challenges surrounding the EU’s accountability for its externalization policies.
The legal responsibilities of the EU regarding its externalization of migration control with partner countries, as well as applicable accountability measures, have been the subject of extensive debate and analysis among legal scholars. In principle, human rights obligations do not extend further than the borders of the Member States in question, which is supported by the territorial and jurisdictional clauses found in relevant human rights treaties such as the European Convention on Human Rights (ECHR). This domestic application supports that the primary application of human rights treaties is within the territory of the Member State that has ratified the treaty in question. It can be implied that the EU has, in some way, circumvented these territorial obligations outlined in its Convention on Human Rights through its externalization measures. By relying on intermediaries, “the EU as orchestrator is able to address its governance priorities without becoming directly involved,” which is important, as “direct engagement often has consequences in terms of liability and legal responsibility.”[31] However, this territorial assumption has also been countered, as “all states have human rights obligations and these obligations apply both at home and abroad,”[32] and, indeed, states and international organizations can violate human rights outside of their territorial jurisdiction—or, in other words, outside of their borders. This can be done in two ways: through extraterritorial conduct or through domestic conduct with policies that have an extraterritorial effect.[33]
Despite these clear frameworks, the role and degree of control over policy areas and operational activities carried out abroad is necessary to consider in order to claim “the responsibilities associated with the violations of human rights occurring in the context of externalisation practices, such as pullback or interstate arrangements, such as those between Italy and Libya.”[34] It remains controversial in legal scholarship whether the “fundamentally territorial” aspect of human rights obligations persist.[35] Unlike in safe third country arrangements where asylum-seekers are transferred following an individual assessment, migrants intercepted by third country authorities during their journey never come into physical contact with the authorities of their intended destination, making it especially difficult to attribute responsibility to those destination states.[36] Additionally, due to the financial support underpinning the EU’s migration control externalization strategies, the EU and its Member States could “only be held responsible for the violations of human rights taking place as a consequence of their interception and return … if the provision of technical and financial support … could be considered an exercise of jurisdiction triggering human rights obligations.”[37]
Conclusions
The European Union’s (EU) externalization of migration control has led to its own complicity in the human rights violations perpetrated by its partner countries. Libyan and Mauritanian forces have committed numerous breaches of migrant rights, including violations of the principle of non-refoulement, arbitrary detention without access to legal remedies, confiscation of personal identification, detention in centers with inadequate living conditions, and physical and sexual abuse. By entering into agreements with these countries and supporting operational measures, the EU has reinforced these abusive practices. The lack of formality and transparency in these agreements has further delegitimized the EU as an actor upholding human rights. EU responsibility for these violations remains blurred, as the EU is neither directly involved in the abuses nor are they occurring within its territorial jurisdiction.
Despite this ambiguity, legal scholarship offers several pathways for holding the EU accountable. Arguments have been made for reinterpreting control to establish jurisdiction under European and International Human Rights Law,[38] demonstrating ancillary responsibility for aid and assistance under Public International Law,[39] characterizing the conduct of EU officials as aiding and abetting the commission of a crime under International Criminal Law,[40] and recognizing derived responsibility emerging from internationally wrongful acts committed by a third country.[41] These arguments provide a basis for accountability to hold the EU and its Member States responsible for human rights violations arising from their externalization of migration control.
Given these possibilities, legal frameworks should be clarified or expanded to allow for the attribution of responsibility when human rights violations occur outside EU territory, including through reinterpretation of “control” under European and International Human Rights Law.
Glossary
Acute Malnutrition: A condition where a person does not receive enough nutrients for a short period, leading to significant health problems.
Ancillary Responsibility: A duty that is secondary, supportive, or closely related to a primary responsibility or activity, rather than being the main focus.
Arbitrary Detention: The deprivation of a person's liberty without legal justification or in violation of fundamental human rights, including the absence of due process, legal basis, or the presence of discriminatory grounds.
Beneficiaries: A person or thing that receives help or an advantage from something. (Merriam-Webster).
Bolster: To give a boost to. (Merriam-Webster).
Circumvent: To manage to get around.
Collective Expulsion: Any measure compelling aliens, as a group, to leave a country,
except where such a measure is taken on the basis of a reasonable and objective
examination of the particular case of each individual alien of the group.[42]
Compliance: Conformity in fulfilling official requirements. (Merriam-Webster).
Complicity: Association or participation in or as if in a wrongful act. (Merriam-Webster).
Confiscate: To take or seize with authority.
Delegitimize: To diminish or destroy the legitimacy, prestige, or authority of. (Merriam-Webster).
Derived Responsibility: Where an actor or entity is held accountable for an act performed by another, based on a specific relationship or assistance provided.
Detain: To hold or keep in or as if in custody. (Merriam-Webster).
Disembarkation: To remove to shore from a ship. (Merriam-Webster).
Enabling: To provide with the means or opportunity. (Merriam-Webster).
European Convention on Human Rights (ECHR): A treaty that protects human rights and fundamental freedoms in Europe.
Exacerbate: To make (something) more severe.
Exploitation: To make use of meanly or unfairly for one's own advantage. (Merriam-Webster).
Extortion: To obtain from a person by force, intimidation, or undue or illegal power. (Merriam-Webster).
Extraterritorial: Existing or taking place beyond a country's territory.
Extraterritorial Conduct: The actions or behaviors of a state that occur outside the territorial boundaries of a state.
Facilitating: To make (something) easier. (Merriam-Webster).
Gender-based Violence: “Harm, or threats to harm, committed against a person(s) based on actual or perceived sex, gender, sexual orientation, gender identity or expression or other such sex/gender related characteristics.”[43]
Human Rights Abuse: A violation of the basic rights of people by treating them wrongly. (Merriam-Webster).
Human Rights Treaties: “Formal agreements between states designed to protect and promote fundamental human rights globally. They serve as essential instruments in shaping international norms and enhancing accountability for violations of human rights. Through these treaties, various rights are codified, setting legal standards that guide national and international actions.”[44]
Imminent: Ready to take place: happening soon. (Merriam-Webster).
Impunity: Exemption or freedom from punishment, harm, or loss. (Merriam-Webster).
Incentivize: Something that incites or has a tendency to incite to determination or action. (Merriam-Webster).
Intermediary: Acting as a mediator—one that acts as a neutral third party to resolve an issue or bring about an agreement.
Interstate Arrangement: Agreement between two or more states.
Irregular Migration: “Movement that takes place outside the regulatory norms of the sending, transit and receiving country.”[45]
Member State (EU): A European country that has joined the European Union (EU), thereby agreeing to abide by the EU's founding treaties and share sovereignty in certain areas to pursue common goals, such as economic cooperation and political integration.
Non-Refoulement: “Prohibition for States to extradite, deport, expel or otherwise return a person to a country where his or her life or freedom would be threatened, or where there are substantial grounds for believing that he or she would risk being subjected to torture or other cruel, inhuman and degrading treatment or punishment, or would be in danger of being subjected to enforced disappearance, or of suffering another irreparable harm.” (IOM, Glossary on Migration, International Migration Law Series No. 34, 2019, p. 1498).
Notorious: Widely and unfavorably known. (Merriam-Webster).
Office for the High Commissioner of Human Rights (OHCHR): The leading UN entity responsible for promoting and protecting human rights worldwide.
Pullback Arrangements: Operations designed “to physically prevent migrants from leaving the territory of their State of origin or a transit State (retaining State), or to forcibly return them to that territory, before they can reach the jurisdiction of their destination State.”[46]
Ratify: To approve formally. (Merriam-Webster).
Refoulement: The act of forcing a refugee or asylum-seeker to return to a country or territory where he or she is likely to face persecution. (Merriam-Webster).
Repression: Putting down by force.
Safe Third Country: “According to the concept, certain migrants should not be granted protection in the country where they have applied for it. Instead, they may be returned, or transferred, to a country where they could have found, or can find, international protection.”[47]
Scrutinized: To examine closely and minutely. (Merriam-Webster).
Smuggling: To import or export something in violation of the customs laws. (Merriam-Webster).
Territorial Jurisdiction: The application of laws or legal procedures within a specific geographic area.
Undocumented Migration: Lacking documents required for legal immigration or residence. (Merriam-Webster).
Footnotes/References
[1] Arne Niemann and Natascha Zaun, “Introduction: EU External Migration Policy and EU Migration Governance: Introduction,” Journal of Ethnic and Migration Studies 49, no. 12 (2023): 2965–2985, https://doi.org/10.1080/1369183X.2023.2193710
[2] Ruben Zaiotti, Externalizing Migration Management: Europe, North America and the Spread of “Remote Control” Practices (London: Routledge, 2016).
[3] European Commission, Migration and Home Affairs, “Global Approach to Migration and Mobility (GAMM),” https://home-affairs.ec.europa.eu/networks/european-migration-network-emn/emn-asylum-and-migration-glossary/glossary/global-approach-migration-and-mobility-gamm_en
[4] Ibid.
[5] Natalino Ronzitti, “The Treaty on Friendship, Partnership and Cooperation between Italy and Libya,” IAI Istituto Affari Internazionali, January 17, 2025, https://www.iai.it/en/pubblicazioni/c04/treaty-friendship-partnership-and-cooperation-between-italy-and-libya.
[6] Amnesty International, Libya/Italy: Bilateral Cooperation Should Not Be at the Price of Human Rights, Public Statement, AI Index: MDE 19/017/2010 (August 27, 2010), https://www.amnesty.org/en/wp-content/uploads/2021/07/mde190172010en.pdf#:~:text=As%20part%20of%20the%20Treaty%20of%20Friendship%2C,over%201%2C000%20individuals%20were%20returned%20to%20Libya.
[7] “Commissioner Olivér Várhelyi Attends the Handover Ceremony of EU-Financed Search and Rescue Vessels to Libya.” Enlargement and Eastern Neighbourhood, European Commission, 6 Feb. 2023, enlargement.ec.europa.eu/news/commissioner-oliver-varhelyi-attends-handover-ceremony-eu-financed-search-and-rescue-vessels-libya-2023-02-06_en. | “EU: Frontex Complicit in Abuse in Libya.” Human Rights Watch, December 12, 2022. https://www.hrw.org/news/2022/12/12/eu-frontex-complicit-abuse-libya.
[8] European Commission, EU Cooperation on Migration in Libya: EU Trust Fund for Africa – North of Africa Window, December 2018, https://north-africa-middle-east-gulf.ec.europa.eu/document/download/88603205-a617-4421-a986-832c3c8853bd_en?filename=eutf-noa-libya.pdf
[9] Global Detention Project, Immigration Detention in Libya: “A Human Rights Crisis” (August 30, 2018), Country Reports, Publications & Events, https://www.globaldetentionproject.org/immigration-detention-in-libya-a-human-rights-crisis
[10] OHCHR. “Lethal disregard” search and rescue and the protection of migrants in the central Mediterranean sea, 14. https://www.ohchr.org/sites/default/files/Documents/Issues/Migration/OHCHR-thematic-report-SAR-protection-at-sea.pdf.
[11] Ibid.
[12] United Nations, Implementation of Resolution 2491 (2019): Report of the Secretary-General, S/2020/876 (September 2, 2020), https://docs.un.org/en/S/2020/876
[13] Ibid.
[14] United Nations Support Mission in Libya and Office of the United Nations High Commissioner for Human Rights, Detained and Dehumanised: Report on Human Rights Abuses against Migrants in Libya (December 13, 2016), https://www.ohchr.org/sites/default/files/Documents/Countries/LY/DetainedAndDehumanised_en.pdf
[15] Ibid.
[16] “Human Rights in Libya,” Amnesty International, https://www.amnesty.org/en/location/middle-east-and-north-africa/north-africa/libya/report-libya/.
[17] “Libya’s Dark Web of Collusion: Abuses against Europe-Bound Refugees and Migrants,” Amnesty International, June 1, 2021, https://www.amnesty.org/en/documents/mde19/7561/2017/en/.
[18] Lethal disregard, 14.
[19] “Libya: European Governments Complicit in Horrific Abuse of Refugees and Migrants,” Amnesty International, August 8, 2022, https://www.amnesty.org/en/latest/press-release/2017/12/libya-european-governments-complicit-in-horrific-abuse-of-refugees-and-migrants/.
[20] Human Rights Watch, “They Accused Me of Trying to Go to Europe”: Migration Control Abuses and EU Externalization in Mauritania (New York: Human Rights Watch, 2025), https://www.hrw.org/sites/default/files/media_2025/08/mauritania0825%20web.pdf
[21] European Union, Joint Declaration Establishing a Migration Partnership between the Islamic Republic of Mauritania and the European Union, EU Migration and Home Affairs, https://home-affairs.ec.europa.eu/document/download/24425c1c-dd34-4c71-8f9e-77ecbac22305_en?filename=De%CC%81claration-conjointe-Mauritanie-EU_en.pdf
[22] “Frontex Failing to Protect People at Eu Borders,” Human Rights Watch, May 19, 2024, https://www.hrw.org/news/2021/06/23/frontex-failing-protect-people-eu-borders.
[23] Vera Wriedt and Darius Reinhardt, Opaque and Unaccountable: Frontex Operation Hera (European Center for Constitutional and Human Rights, February 2017), https://www.statewatch.org/media/documents/analyses/no-307-frontex-operation-hera.pdf
[24] United Nations Human Rights Council, Preliminary Findings and Observations of the United Nations Special Rapporteur on the Human Rights of Migrants on His Visit to Mauritania from 2 to 12 September 2025, Special Procedures, https://www.ohchr.org/sites/default/files/statements/20250912-eom-stm-sr-migrants-en.pdf
[25] Ibid.
[26] They Accused Me of Trying to Go to Europe, 3.
[27] European Parliament, Report on a Recommendation Concerning Negotiations on a Status Agreement between the EU and Mauritania on Frontex Operations in Mauritania, 2023/2087(INI), 14 November 2023, https://www.europarl.europa.eu/doceo/document/A-9-2023-0358_EN.html
[28] They Accused Me of Trying to Go to Europe, 124.
[29] Amnesty International, Externalization of Migration and the Impact on the Human Rights of Migrants: Submission to the UN Special Rapporteur on the Human Rights of Migrants (June 2025), https://www.amnesty.org/en/wp-content/uploads/2025/06/EUR0194852025ENGLISH.pdf
[30] Ibid.
[31] Müller, Patrick, and Peter Slominski. 2020. “Breaking the Legal Link but Not the Law? The Externalization of EU Migration Control through Orchestration in the Central Mediterranean.” Journal of European Public Policy 28 (6): 801–20. doi:10.1080/13501763.2020.1751243.
[32] Wouter Vandenhole, Gamze Erdem Türkelli, Mark Gibney, and Markus Krajewski, “Introduction,” in The Routledge Handbook on Extraterritorial Human Rights Obligations, 1st ed. (Abingdon: Routledge, 2021), 9, e-Reader | Introduction | Wouter Vandenhole, Gamze Erdem Türkelli, Mar
[33] Lorand Bartels, The EU’s Human Rights Obligations in Relation to Policies with Extraterritorial Effects, European Journal of International Law, Volume 25, Issue 4, November 2014, Pages 1071–1091, https://doi.org/10.1093/ejil/chu071
[34] “Externalisation of Migration Controls: A Taxonomy of Practices and Their Implications in International and European Law,” Netherlands International Law Review 71 (2024): 1–20, published May 13, 2024, https://doi.org/10.1007/s40802-024-00253-9
[35] Ibid.
[36] De Leo, “Fostering Accountability for Human Rights Violations in EU Border Externalization Through the European Ombudsman: The Case of Contesting Financial Support to the Libyan Coast Guard,” Journal of Immigrant & Refugee Studies 23, no. 1 (2025): 104, paraphrasing De Leo and Milazzo, “Funding the EU’s External Migration Policy: ‘Same Old’ or Potential for Sustainable Collaboration?” (European Policy Centre, April 3, 2024) https://www.tandfonline.com/doi/pdf/10.1080/15562948.2024.2382465
[37] Andreina De Leo, “Fostering Accountability for Human Rights Violations in EU Border Externalization Through the European Ombudsman: The Case of Contesting Financial Support to the Libyan Coast Guard,” Journal of Immigrant & Refugee Studies 23, no. 1 (2025): 109.
[38] Ibid.
[39] Ibid.
[40] Ibid.
[41] Tamás Molnár, EU Member States’ Responsibility Under International Law for Breaching Human Rights When Cooperating with Third Countries on Migration: Grey Zones of Law in Selected Scenarios, https://www.europeanpapers.eu/e-journal/eu-member-states-responsibility-under-international-law-cooperating-third-countries-migration.
[42] European Court of Human Rights, Press Unit, Factsheet – Collective Expulsions of Aliens (October 2024), https://www.echr.coe.int/documents/d/echr/FS_Collective_expulsions_ENG
[43] “About Gender-Based Violence,” Office for the Prevention of Domestic Violence, https://opdv.ny.gov/about-gender-based-violence.
[44] Law Librarianship Editorial, “Understanding Human Rights Treaties: A Comprehensive Overview - Law Librarianship,” The Insurance Universe, November 19, 2024, https://lawlibrarianship.com/human-rights-treaties/#Significance_of_Human_Rights_Treaties.
[45] International Organization for Migration, Key migration terms, accessed October 8, 2025, https://www.iom.int/key-migration-terms.
[46] Lethal disregard, 21.
[47] “Safe Third Country Concept in the EU Pact on Migration and Asylum: Think Tank: European Parliament,” Think Tank | European Parliament, accessed October 8, 2025, https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2024)767148.
