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On March 4, the U.S. Department of Justice charged ten Chinese nationals with carrying out massive hacks against government agencies, media outlets, and dissidents in the United States and around the world. They allegedly acted on behalf of the Chinese company i-Soon, under contract from the Beijing government. Two officials from China’s Ministry of Public Security (MPS) were also indicted, identified as the ones “directing the attacks.” According to documents held by the U.S. justice system, China’s domestic intelligence services (MPS) and foreign intelligence (Ministry of State Security, MSS) relied on a vast network of private companies and domestic contractors to hack and steal information, thereby masking the Chinese government’s direct involvement. In some cases, the MPS and MSS paid private hackers to target specific victims. In many others, the attacks were speculative: hackers identified vulnerable computers, breached them, and extracted information that was later sold — either directly or indirectly — to the Chinese government. The Growth of Chinese Cyberespionage and Its Main Areas of Operation This is not an isolated case. Over the past decade, the People’s Republic of China’s (PRC) hacking program has expanded rapidly. In 2023, then-FBI Director Christopher Wray stated that it was larger than that of all other world powers combined. This increase in power and sophistication has led to success in three key areas: political interference, sabotage of critical infrastructure, and large-scale intellectual property theft. Beijing integrates computer networks, electronic warfare, economic, diplomatic, legal, military, intelligence, psychological, and military deception resources, along with security operations, to weaken states, make them economically dependent on China, and more receptive to a “new authoritarian world order with Chinese characteristics.” For this reason, unlike traditional interpretations, Chinese state-sponsored hacking should be understood within a broader context — where control over technology, strategic infrastructure, and global supply chains is part of “trans-military” and “non-military” warfare operations, as described by two People’s Liberation Army (PLA) colonels in the 1999 book “Unrestricted Warfare”. This approach is known as liminal warfare — an escalating conflict in which the spectrum of competition and confrontation with the West is so wide that the battlefield is, quite literally, everywhere. Cyberespionage as a Tool of Electronic Warfare In electronic warfare, hacking is used for sabotage during times of crisis or conflict. These actions are led by the People’s Liberation Army (PLA), the armed wing of the Chinese Communist Party. In 2023, it was discovered that a hacker group linked to the PLA, known as “Volt Typhoon”, had infiltrated a wide range of critical infrastructure in the U.S. for years, including ports, factories, and water treatment plants — both on the mainland and in strategic locations like Guam. “Volt Typhoon is a military operation with political and potentially military strategic purposes,” explained Ciaran Martin, former director of the UK’s cybersecurity agency. Led by the PLA’s cyber unit, the operation involved installing readiness capabilities — “digital traps,” as some call them — within critical U.S. infrastructure. In addition to a sustained attack in 2023 on a power company in Massachusetts, which aimed to extract sensitive data about its operational technology (OT) infrastructure, “Volt Typhoon” gained notoriety for multiple attacks on telecommunications systems in the U.S. and other critical infrastructures globally. One of its subunits, “Voltzite”, targeted the Littleton Electric and Water Departments, prompting the FBI and cybersecurity firm Dragos to respond jointly and publish a detailed report on the attack and its mitigation. Intellectual Property Theft Through Cyberespionage The most damaging channel for intellectual property theft is cyberespionage. These intrusions allow Chinese companies — sometimes with direct support from the Communist Party or the state — to access information on operations, projects, and technology from foreign firms. China has used state-backed and coordinated cyberespionage campaigns to steal information from companies in strategic sectors such as oil, energy, steel, and aviation. These actions serve both to acquire science and technology and to gather intelligence useful for future attacks on military, government, or technical systems. In the United States, there have been numerous precedents: • In 2014, five PLA hackers were indicted for economic espionage.• In 2017, three hackers linked to the Chinese firm Boyusec were charged with stealing confidential business information.• In 2018, two Chinese nationals were indicted for intellectual property theft.• In 2020, two hackers connected to the MSS were charged with targeting COVID-19 research. Among these, the 2018 indictment stands out as part of a broader U.S. effort to raise awareness about Chinese cyberespionage. On that occasion, Chinese hackers carried out a campaign known as “Cloud Hopper”, which involved a supply chain attack on service providers like Hewlett Packard and IBM. The defendants worked for Huaying Haitai and collaborated with the Tianjin State Security Bureau of the MSS. In 2017, the U.S. Commission on the Theft of American Intellectual Property estimated that such crimes cost the U.S. economy up to $600 billion annually — a figure comparable to the Pentagon’s defense budget and greater than the combined profits of the 50 largest companies in the Fortune 500. Beyond the United States: The Global Impact of Chinese Cyberespionage In June 2024, Dutch military intelligence (MIVD) warned that Chinese cyberespionage was broader than previously believed, affecting Western governments and defense companies. A 2023 cyberattack on the Dutch Ministry of Defense reportedly affected at least 20,000 people within a few months. In 2018, the Czech Republic’s National Cyber and Information Security Agency (NUKIB) issued a warning about risks linked to China. Since then, the country has strengthened its capabilities and controls against Beijing and has worked on mechanisms to counter foreign information manipulation. According to U.S. prosecutors, dozens of European parliamentarians have been targeted by Chinese attacks. In March 2024, the U.S. Department of Justice indicted hackers linked to the MSS for attacking “all EU members” of the Inter-Parliamentary Alliance on China (IPAC), a coalition critical of Beijing. In 2021, the hackers sent over a thousand emails to around 400 accounts linked to IPAC, attempting to spy on their internet activity and devices. In addition, ASML, the Dutch leader in semiconductor lithography, suffers “thousands of security incidents per year,” including several successful infiltration attempts by Chinese actors. Research centers like Imec (Belgium) are also frequent targets. Belgium has expelled Chinese researchers suspected of espionage. The European Union has reinforced security and identified advanced semiconductors as one of four critical technologies requiring risk assessments and enhanced protection. Notably, APT41 is one of the most active and sophisticated Chinese cyberespionage groups, based in the PRC and linked to the MSS. According to Google’s Threat Intelligence Group, APT41 combines state espionage with ransomware attacks — malicious programs that encrypt files and demand financial ransom to restore them — making attribution more difficult. Unlike other PLA-aligned groups whose operations are region-specific, APT41 acts globally, attacking strategic sectors in the U.S., Europe, Latin America, and the Caribbean. It also carries out financially motivated operations, particularly in the gaming industry. Mandiant, a global cybersecurity leader, highlights APT41’s technical capabilities: it frequently exploits zero-day and n-day vulnerabilities and uses techniques like phishing, social engineering, and SQL injections. Since 2020, APT41 has conducted large-scale campaigns against over 75 companies in more than 20 countries. It is responsible for compromising supply chains, such as in the “ShadowHammer” campaign targeting ASUS, which affected over 50,000 systems in 2018. APT41 is also linked to the use of “MESSAGETAP” malware in telecommunications networks. The Role of Chinese Universities in Cyberespionage Chinese universities also collaborate with the PLA and MSS in state-sponsored cyberespionage operations. Shanghai Jiao Tong University works directly with the Chinese military on such operations. Zhejiang University and the Harbin Institute of Technology are key centers for recruiting hackers. Xidian University offers students hands-on experience at provincial MSS offices and previously maintained ties with the Third Department of the PLA’s General Staff before its reorganization in 2015 into the Network Systems Department. One of its graduate programs is co-directed with the Guangdong Office of the Chinese Information Technology Security Evaluation Center (ITSEC), an MSS-run office that leads an active team of contractor hackers. Southeast University also maintains links with security services and co-manages the “Purple Mountain Lab” with the PLA’s Strategic Support Force. There, researchers collaborate on “critical strategic requirements,” operating systems, and interdisciplinary cybersecurity studies. The university also receives funding from the PLA and MSS to develop China’s cyber capabilities. The Cybersecurity undergraduate program at Shanghai Jiao Tong University (SJTU) is taught at a PLA information engineering base. Within this program, SJTU claims to work on “network and information systems testing and evaluation, security testing for connected smart networks, APT attack and defense testing, and key technologies for cyber ranges.” Universities associated with the MSS for talent recruitment include the University of Science and Technology of China, Shanghai Jiao Tong University, Xi’an Jiao Tong University, Beijing Institute of Technology, Nanjing University, and the Harbin Institute of Technology. In addition, some cybersecurity firms — such as Beijing TopSec — collaborate with the PLA in hacking campaigns, operator training, and developing future hackers. This article was originally published by Agenda Digitale and later by Expediente Abierto, who granted us permission for its translation and republication.

AbstractThe increasing presence of foreign fighters in the armed conflict in Ukraine has posed significant challenges to the application of International Humanitarian Law (IHL). These foreign fighters, often motivated by political, ideological, or religious reasons, do not neatly fit into traditional legal categories such as lawful combatants, civilians, or mercenaries. Their involvement on both sides of the conflict between those supporting either Ukrainian forces or Russian-backed groups, presents a complex issue that requires careful consideration within the context of IHL, which currently lacks clear provisions for addressing their legal status. This study focuses on the research question: Does the involvement of foreign fighters in the armed conflict in Ukraine comply with the principles of International Humanitarian Law? This issue is particularly important as it exposes significant gaps in IHL, revealing its inability to adequately address the complexities of modern armed conflicts involving non-state actors. Employing a juridical-normative approach, this study examines the application of IHL to foreign fighters in the Russia-Ukraine conflict, focusing on their rights, responsibilities, and accountability. The findings show that IHL lacks specific provisions to regulate the legal status of foreign fighters, relying instead on general human rights principles that fail to address their unique circumstances. This creates a legal vacuum, undermining both their protection and the enforcement of accountability for violations. The study concludes that targeted reforms in IHL are urgently needed to establish clear legal standards for the classification, protection, and prosecution of foreign fighters, thereby strengthening the overall humanitarian framework for contemporary armed conflicts.KeywordsForeign fighters, Russia, Armed conflict, Humanitarian law, Ukraine 1. Introduction The Russia-Ukraine conflict, which has been ongoing since Russia's annexation of Crimea in 2014, has escalated into a complex and devastating war. This conflict, deeply rooted in geopolitical tensions, has drawn the attention of the international community, not only due to the implications for regional stability but also for the growing role of foreign fighters. The involvement of foreign fighters in the conflict adds a new layer of complexity to the already volatile situation. These individuals, who join armed conflicts in foreign territories, are often motivated by political, ideological, religious, or financial reasons, and their presence in Ukraine raises serious legal, political, and humanitarian questions (Asya et al., 2024). The role of foreign fighters has become increasingly significant in modern warfare, with their participation often blurring the lines between combatants, civilians, and mercenaries (Anjelika et al., 2024)The primary challenge posed by the involvement of foreign fighters in Ukraine lies in the legal uncertainty surrounding their status under International Humanitarian Law (IHL). IHL, which governs the conduct of armed conflicts and seeks to protect individuals who are not actively participating in hostilities, does not provide clear guidelines for foreign fighters. These fighters, who do not represent a state or recognized party to the conflict, do not neatly fall into categories such as lawful combatants or civilians, making their legal status ambiguous. This creates a gap in the legal framework, complicating the application of IHL to their actions and raising critical questions about accountability, rights, and protections under international law (Alexander, 2023) (see Table 1, Table 2).   The significance of this study stems from the need to address these legal uncertainties and to understand how IHL can be adapted to regulate the involvement of foreign fighters in modern conflicts. Despite the growing prevalence of foreign fighters in conflicts around the world, the existing body of IHL has not sufficiently addressed their status or the challenges they pose to the protection of human rights and the enforcement of accountability (Paulussen, 2021). By focusing specifically on the Ukraine conflict, this study aims to fill a significant gap in current legal scholarship by analyzing the implications of foreign fighters' participation through the lens of IHL. The involvement of foreign fighters in the Ukraine conflict has profound implications not only for the legal treatment of these individuals but also for the broader geopolitical context (Idris & Mu'tashim, 2023). Their participation exacerbates tensions between Russia and Western countries, as foreign fighters supporting Ukraine often come from nations with opposing political interests to Russia. This dynamic further complicates diplomatic efforts aimed at resolving the conflict and maintaining international peace. Additionally, the presence of foreign fighters contributes to the growing trend of non-state actors engaging in warfare, challenging traditional notions of state sovereignty and complicating international efforts to regulate armed conflict (Lekatompessy et al., 2024). From a humanitarian perspective, the presence of foreign fighters increases the risks of violations of IHL and human rights, as these individuals may not be subject to the same legal frameworks as state actors. The lack of clear legal provisions for foreign fighters leaves them vulnerable to exploitation, abuse, and violations of their rights, while also creating a situation in which accountability for violations becomes difficult to enforce (Akbar & Sadiawati, 2023). This not only undermines the protection of civilians but also weakens the enforcement of humanitarian norms, further complicating the efforts of international organizations and states to address violations of IHL. This study is particularly important because it seeks to address the legal vacuum that exists concerning foreign fighters in the Ukraine conflict. By examining the application of IHL to foreign fighters, this research contributes to the broader field of international law by proposing a more comprehensive framework for regulating their involvement. Through this examination, the study aims to provide concrete recommendations for legal reforms within IHL that would better address the challenges posed by foreign fighters in modern armed conflicts. The rationale for this study lies in the growing recognition that IHL, as it currently stands, is insufficient to address the complexities of modern warfare, particularly when it comes to the participation of non-state actors like foreign fighters. As the world witnesses an increasing number of foreign fighters engaging in conflicts worldwide, it is essential to adapt international legal frameworks to these new realities. This study not only contributes to the understanding of IHL's limitations but also proposes practical legal reforms that could enhance its effectiveness in protecting human rights and ensuring accountability in future conflicts. The involvement of foreign fighters in Ukraine represents a critical point at which the gaps in IHL are laid bare. As such, this study holds significant relevance for policymakers, international legal scholars, and human rights advocates, as it highlights the urgent need for reform and provides insights into how IHL can evolve to better respond to contemporary challenges. By addressing the legal status and accountability of foreign fighters, this study aims to contribute to the development of a more robust and responsive international legal system that can effectively address the complexities of modern warfare and uphold humanitarian principles in the face of emerging threats. 1.1. Literature review Previous research by Akbar and Sadiawati (2023), titled "Analysis of the Russian Invasion of Ukraine in Terms of Humanitarian Law", focuses on examining violations of the 1949 Geneva Conventions during the invasion and emphasizes the role of the United Nations in promoting global peace. The study provides a comprehensive analysis of the international legal framework, particularly humanitarian law, in addressing war crimes and violations committed during the conflict. Similarly, Nasution and Raudia (2022, pp. 361–374), in their article "Analysis of Russian War Violations in the 2022 Ukrainian Conflict Based on the Perspective of International Humanitarian Law", discusses the breaches of humanitarian law committed by Russia during the conflict. Their study highlights key violations under international legal standards and emphasizes the need for accountability based on humanitarian law principles. Masri et al. (2024), in their study titled "Implementation of International Humanitarian Law in the Russia-Ukraine Conflict", explore the application of international humanitarian law (IHL) within the context of the Russia-Ukraine war. Their research delves into how IHL has been enforced and its effectiveness in mitigating harm during the conflict. While these studies extensively analyze IHL violations in the Russia-Ukraine war, they focus primarily on state actors, with limited attention to the role of foreign fighters. This paper fills this gap by analyzing the participation of foreign fighters, their classification under IHL, and the legal protections afforded to them. 1.2. Theoretical framework1.2.1. Theories of state sovereignty and territorial integrity The theory of state sovereignty and territorial integrity originates from classical thinkers like Bodin (2009), Hugo Grotius (1964), and Kant (1991). Bodin defined sovereignty as supreme authority free from external interference, while Grotius emphasized its role as a cornerstone of international law. Kant argued that territorial integrity was vital for peaceful inter-state relations. These principles were codified in Article 2(4) of the UN Charter (1945), prohibiting threats or force against a state's territorial integrity or political independence. In the Russia-Ukraine conflict, these principles are acutely relevant. Russia's annexation of Crimea (2014), support for separatists in Donetsk and Luhansk, and the 2022 invasion breach sovereignty and international law. Moerdijat (2022) highlights these violations' severity, while Pisano (2022) examines their destabilizing effects on regional geopolitics. Thus, this theory offers a legal and analytical lens to assess the conflict's ramifications for the global order. 1.2.2. Theories of international humanitarian law (IHL) The development of IHL stems from contributions by scholars like Jean Pictet, who stressed protecting individuals in conflicts, and Hugo Grotius, whose De Jure Belli ac Pacis advocated for war regulation through moral and legal principles. J.F. Murphy (1982) linked IHL with human rights, Antonio Cassese (2013) explored IHL's role in mitigating human rights violations during war, and Theodor Meron (2006) advanced civilian protections and war crime regulations. These foundations emphasize protecting non-combatants, limiting warfare methods, and clarifying states' obligations. In Ukraine, IHL faces challenges like the ambiguous legal status of foreign fighters. Akbar and Sadiawati (2023) highlight gaps in their protections, while the BBC (2023) reports on the Wagner Group's role in exacerbating violations, such as civilian attacks and disproportionate force. These challenges underscore the need for stricter adherence to IHL to mitigate humanitarian crises and uphold legal standards. 1.2.3. Theories of globalization in modern warfare Theories on globalization's impact on warfare are shaped by thinkers like Mary Kaldor (2013), who contrasts traditional "old wars" with "new wars" involving non-state actors, and Zygmunt Bauman (1998), who links globalization to interconnected dynamics reshaping warfare. Robert D. Kaplan (1994) connects globalization to growing socio-economic inequalities and asymmetric conflicts. These theories argue that globalization's technological, economic, and communicative aspects have transformed war by introducing non-state actors and advanced technologies. The Russia-Ukraine conflict illustrates globalization's role in modern warfare. The participation of foreign fighters, whether aiding Ukraine's International Territorial Defense Legion or Russia's Wagner Group, reflects globalization's influence. Mehra and Thorley (2022) note motivations like ideology and economics, while Chakyan Tang (2022) highlights both solidarity and challenges introduced by non-state actors. Globalization expands conflicts' scope and complexity, complicating regulation while reshaping modern warfare's nature. 2. Methodology This research employs a juridical-normative method using a legal approach to examine the Ukraine-Russia conflict within the framework of International Humanitarian Law (IHL) (Gunawan et al., 2023). The primary objective is to explore how the actions of the parties involved align with the established principles and norms of international law. A juridical-normative approach is used to systematically analyze laws, regulations, and legal principles applicable to the conflict, particularly focusing on how these norms are implemented or potentially violated by the involved actors. The study relies on qualitative normative research methods, which involve document analysis of legal texts and secondary sources to gain a comprehensive understanding of the legal framework governing the conflict. This includes examining court decisions, legal doctrines, international treaties (such as the 1949 Geneva Conventions), and other relevant international instruments. Secondary sources, such as legal theories and expert opinions, also form a key part of the analysis. Through this approach, the research offers a comprehensive analysis of compliance with, or violations of, the principles of International Humanitarian Law (IHL) in the conflict. The document analysis process, as the primary data collection method, incorporates legal hermeneutics to interpret and clarify the meaning of legal texts, ensuring an accurate understanding of their application in the context of the Ukraine conflict. Comparative analysis is also employed to examine how IHL principles have been applied in similar conflicts, providing a benchmark for evaluating their implementation or breach in this case. The analysis focuses on primary legal materials, including treaties, conventions, official communications, and resolutions from international organizations, to establish a foundational understanding of the legal framework. These are complemented by secondary legal materials, such as academic literature, legal commentaries, and expert opinions, which provide critical insights and context. This methodological combination ensures a robust and nuanced evaluation of how IHL principles are being upheld or violated, strengthening the validity and reliability of the findings. 3. Results and discussion3.1. Legal framework for foreign fighters The status of foreign fighters under International Humanitarian Law (IHL) remains contentious and ambiguous. While the Geneva Conventions and their Additional Protocols primarily regulate the conduct of state actors and recognized combatants, they offer limited guidance for non-state participants, such as foreign fighters. These individuals find themselves in a legal gray area, as the Geneva Conventions focus mainly on the protection of civilians and combatants who are part of a state's armed forces or organized resistance groups. Common Article 3 of the Geneva Conventions and Additional Protocol II extend limited protections to non-state actors involved in non-international armed conflicts, emphasizing humane treatment and prohibiting acts like torture or degrading treatment (M, 2001). However, these provisions do not explicitly address the legal status, rights, or obligations of foreign fighters who may not be formally part of an organized state or non-state armed force. Additional Protocol I further complicates this issue. For example, Article 47 of Protocol I explicitly excludes mercenaries from the status of combatants or prisoners of war (POWs), effectively denying them the legal protections afforded to lawful combatants (Geraldy Diandra Aditya, Soekotjo Hardiwinoto, 2017). This exclusion raises questions regarding the legal status of foreign fighters who may not fit neatly into the categories of lawful combatant, civilian, or unlawful belligerent. As a result, the legal position of foreign fighters in modern armed conflicts, such as the Ukraine-Russia conflict, remains unclear and potentially subject to exploitation or abuse. A table listing key international treaties, conventions, and resolutions relevant to foreign fighters could illustrate the legal tools available for regulating their conduct and holding them accountable. The table could include categories such as. 3.1.1. Legal status and responsibilities of foreign fighters Foreign fighters have become a notable element of modern conflicts, including in Ukraine, where individuals from various countries have joined both sides of the conflict. Their participation raises significant legal and ethical questions, particularly regarding their status under International Humanitarian Law (IHL) and the accountability for their actions. IHL, as defined by the Geneva Conventions and the Hague Conventions, does not explicitly mention "foreign fighters" but provides a legal framework for determining their status based on their activities and allegiance. Foreign fighters are typically categorized as either lawful combatants, unlawful combatants, or civilians, and their rights and responsibilities are governed by the laws of war (Hasan & Haque, 2023). a. Lawful Combatants, foreign fighters who join the armed forces of a state party to the conflict (e.g., Ukraine in the context of the Russian invasion) may be considered lawful combatants. As lawful combatants, they are entitled to the protections of IHL, including protection from being targeted and humane treatment if captured. They are subject to the laws of armed conflict, particularly the Geneva Conventions, and must adhere to principles such as distinction, proportionality, and the prohibition of unnecessary suffering. However, this status is contingent upon them being members of an organized military force that follows IHL regulations.b. Unlawful Combatans, foreign fighters who join non-state armed groups, such as mercenaries or irregular militias not recognized under IHL, are considered unlawful combatants. They are not entitled to the same protections as lawful combatants and may be prosecuted for violations of IHL, including acts that could constitute war crimes. The status of unlawful combatants often leads to challenges in terms of legal accountability, as their actions may not be adequately covered by state-based military tribunals or national courts. International efforts to hold foreign fighters accountable for violations such as the targeting of civilians or the use of prohibited weapons can be complicated by the lack of a clear framework for prosecuting non-state actors.c. Civilians, foreign nationals who participate in the conflict but do not take a direct part in hostilities are considered civilians and are protected by IHL. Their involvement in combat can alter their status, and they may lose their protection from direct targeting once they engage in hostilities. This creates a complex dynamic for the prosecution and accountability of foreign fighters, as their status may change based on their activities in the field. A table that compares the legal status of foreign fighters in different contexts could help clarify the varying rights and responsibilities under International Humanitarian Law (IHL). The table could include categories such as: Here is the map illustrating the geographical origins of foreign fighters in the Ukraine conflict, showing their involvement with either the Ukrainian or Russian side. This visual provides a global context to their participation. 3.2. Ukraine's historical struggle: Russia's colonialism and imperialistic attitudes The relationship between Russia and Ukraine stretches back for centuries, characterized by a complex and often turbulent history. From the medieval period to modern times, Ukraine has faced numerous instances of Russian dominance and interference, which has shaped its national identity and its ongoing struggle for independence. This historical context is essential to understanding Ukraine's motivations to fight, as it reflects a long-standing resistance to Russian colonialism and imperialism. In the 17th and 18th centuries, Russia began consolidating its control over Ukrainian territories, particularly after the Treaty of Pereyaslav in 1654, which marked the beginning of Ukrainian subordination to the Tsarist empire (Britannica, 2025). Over the centuries, Ukraine's autonomy was eroded, and it became an integral part of the Russian Empire, with many Ukrainians subjected to harsh policies of Russification. The suppression of Ukrainian culture, language, and national identity under Tsarist rule set the stage for future tensions. The most devastating chapter of this colonial history came under Soviet rule, which exacerbated the sense of Russian imperialism. The Holodomor, a man-made famine in the early 1930s, is one of the darkest episodes in Ukrainian history. Millions of Ukrainians perished as a result of Stalin's policies, which sought to enforce collectivization at the cost of the Ukrainian people. This tragedy has left a lasting scar on the collective memory of Ukraine, fueling a deep-seated distrust of Russia and reinforcing the narrative of Ukrainian victimhood under Russian imperialism. Even after the collapse of the Soviet Union in 1991 and Ukraine's declaration of independence, Russia has continually sought to exert influence over Ukraine, often invoking its imperial past to justify intervention. Russia's annexation of Crimea in 2014 and its ongoing military actions in eastern Ukraine are seen by many as a continuation of the imperialistic attitude that has defined Russia's relationship with Ukraine for centuries. Ukraine's motivation to fight in the current conflict is deeply rooted in its desire to protect its sovereignty and preserve its cultural and political independence from Russian influence. This struggle is not just a response to Russia's aggression but a continuation of a centuries-long fight for self-determination, dating back to the period of Tsarist colonialism and reinforced by the Soviet era. The ongoing war represents Ukraine's determination to break free from the chains of Russian imperialism and secure its future as an independent, sovereign nation. 3.3. International humanitarian law review of Russia's armed attack in Ukraine After the Russian annexation of Crimea, tensions in relations between Russia and Ukraine continued until February 2022. These tensions began when NATO sought to expand its membership into Eastern Europe by inviting Ukraine to join as a member (Andi Antara Putra & Dantes, 2022). NATO has expressed its commitment to Ukraine's future membership, stating: "We reaffirm that we will be in a position to extend an invitation to Ukraine to join the Alliance when Allies agree and conditions are met (NATO, 2024b)." This position underscores NATO's openness to Ukraine's membership, contingent upon unanimous agreement among current member states and Ukraine's fulfillment of specified criteria. While NATO has not issued a formal invitation to Ukraine, it acknowledges Ukraine's aspirations and is actively supporting its progress toward potential membership. This support includes enhancing interoperability and implementing democratic and security sector reforms (NATO, 2024a). This represents an escalation of tensions between Russia and Western countries, especially NATO, as Eastern Europe has become a critical arena for competing geopolitical interests. NATO's post-Cold War expansion, which saw the inclusion of former Eastern Bloc countries such as Poland, Hungary, and the Baltic states, has been interpreted by Russia as a direct encroachment on its sphere of influence and a threat to its security. This tension was further amplified by NATO's 2008 declaration that Ukraine and Georgia would eventually become members, which Russia perceived as a red line. The strategic importance of Eastern Europe, both as a buffer zone and as a transit corridor for energy resources, adds to the stakes for both NATO and Russia. Russia's aggressive actions, including the 2014 annexation of Crimea and its ongoing involvement in Eastern Ukraine, can be seen as attempts to counterbalance NATO's growing presence in the region. Conversely, NATO's military support to Eastern European nations underscores its commitment to collective defense and the deterrence of Russian aggression, further fueling the geopolitical rivalry. Geopolitical influence and efforts to strengthen military presence in the region are important factors in the dynamics of the ongoing conflict between Russia and Ukraine. Russia's insistence that it will not allow Ukraine to "break away," viewing it as a threat to its interests and security (Mamfaluthy, 2014), raises significant tensions with international law principles, particularly the respect for national sovereignty. The United Nations Charter guarantees every state the right to sovereignty, territorial integrity, and political independence, which includes Ukraine's right to determine its domestic and foreign policies without external interference. While Russia argues that Ukraine's potential NATO membership or Western alignment threatens its security, such concerns do not justify actions that violate Ukraine's sovereignty, such as the annexation of Crimea or support for separatist movements in Eastern Ukraine. Although international law permits states to take measures to protect legitimate security interests, these must align with legal norms and avoid infringing on the sovereignty of other states. Russia's actions contravene these principles, as reaffirmed by UN General Assembly resolutions recognizing Ukraine's territorial integrity. This tension highlights a clash between Russia's realpolitik approach to securing its strategic interests and the international legal obligation to respect the sovereignty and independence of other nations. In Putin's view, all countries that are members of NATO have the full right to organize and protect their territories from all threats, both from within and outside the country (Pradana & Ramadhoan, 2022). Putin's opinion reflects the view that NATO membership by countries surrounding Russia, including Ukraine, is perceived as a threat to Russia's security. This is reflected in concerns over the deployment of NATO military infrastructure near Russia's borders, which could be perceived as a direct threat to Russia's strategic interests. Putin has therefore insisted on taking measures he deems necessary to protect Russia's interests and sovereignty. This has led to increased tensions between Russia and Western countries that support Ukraine's membership in NATO. Russia's response to Finland's NATO membership contrasts sharply with its actions toward Ukraine, mainly due to the differing historical and cultural ties with each country. Finland views its NATO membership primarily as a defensive strategy, while Ukraine's relationship with Russia has deep historical and cultural roots. Finland's strong military, combined with NATO's collective defense principles, serves as a deterrent to Russian aggression, whereas Russia, already heavily engaged in Ukraine, avoids provoking NATO. This difference highlights that Russia's actions toward Ukraine are driven by regional dominance ambitions, rather than NATO expansion. Russia's intervention in Ukraine violates the principle of non-intervention, which is a fundamental tenet of international law. Non-intervention asserts that each state has the right to manage its internal affairs without external interference (Octavia & Husniyah, 2023). Article 2, paragraph 4 of the UN Charter emphasizes the importance of peaceful dispute resolution and the avoidance of armed conflict. Russia's actions also contravene the Declaration on Principles of International Law (A/RES/25/2625, 1970), which upholds the national sovereignty, territorial integrity, and political independence of states, emphasizing that disputes should be resolved peacefully and without violence (Mahfud, 2015; Rudy, 2011). Furthermore, Article 38 of the Statute of the International Court of Justice broadens the sources of international humanitarian law (IHL), allowing for inclusion of legal principles recognized by civilized nations, international organizations, and expert opinions, not limited to international treaties (Budisantosa, 2021). This further underscores the importance of respecting IHL and the sovereignty of states in the global legal framework. While the international treaties that are the main foundation of IHL are the Hague Conventionand the Geneva Convention (Pasorong et al., 2023). The Hague Convention regulates the laws of war governing the treatment of individuals and property in armed conflicts, while the Geneva Convention sets minimum standards for the treatment of war victims, including the protection of civilians, prisoners of war, and medical personnel. These two conventions form an important legal framework for safeguarding humanity during armed conflicts and have been the main basis for the formation of further IHL rules. IHL cannot cover all actions in international wars, but parties to armed conflicts are obliged to respect and uphold the basic principles of IHL these include (Danial, 2017). a. The Humanitarian Principle: Demands that actions in armed conflict should take into account the interests of humanity and avoid unnecessary suffering of individuals not involved in the conflict.b. Military Interests: Recognizes that military actions taken should be proportionate to the military objectives to be achieved and should minimize unnecessary losses.c. Proportionality: States that military actions must be in accordance with legitimate military interests and must be proportionate to the threat faced.d. Distinction: Stipulates that parties to a conflict must distinguish between individuals participating in the conflict (military) and those not participating (civilians), as well as between military and non-military objects.e. Prohibition of Unnecessary Suffering: Prohibits acts that cause unnecessary suffering or that are incompatible with legitimate military objectives.f. Separation of Ius ad Bellum and Ius in Bello: Distinguishes between the law governing the authority to use military force (Ius ad Bellum) and the law governing the behavior of the parties to the conflict (Ius in Bello). Russia's armed attack on Ukraine violated several fundamental principles of international humanitarian law (IHL). First, it breached the principle of state sovereignty by violating Ukraine's territorial integrity and political independence, contravening Article 2, paragraph 4 of the UN Charter, which prohibits the use of force against another state's territorial integrity. Second, the attack violated the principle of distinction, as there have been reports of civilian casualties from Russian military strikes, which should have been targeted at combatants and military objectives. Third, the strikes caused unnecessary suffering to the civilian population and infrastructure, violating the prohibition against unnecessary suffering in IHL. Overall, Russia's actions are considered serious violations of IHL and universally recognized humanitarian principles. 3.4. Foreign fighters in the context of international humanitarian law The conflict in Ukraine has brought attention to the complexities of international law, particularly regarding foreign fighters in armed conflicts. According to Common Article 3 of the Geneva Conventions, the conflict qualifies as a Non-International Armed Conflict (NIAC), which involves non-state armed groups like insurgents or separatists against state forces (Brits, 2017; Mehra & Thorley, 2017; Mehra & Thorley, 2022). However, the involvement of Russia complicates this classification, leading some to argue the conflict may be an International Armed Conflict (IAC) governed by the Geneva Conventions and the First Additional Protocol, which set standards for the protection of civilians and prisoners of war (Susetio & Muliawan, 2023). The Second Additional Protocol (APII) further outlines protections for civilians and individuals not directly participating in hostilities, providing essential legal instruments for the Ukraine conflict (Ismail, 2018). Despite the ongoing debate over the conflict's classification, IHL standards, including protections against torture and inhumane treatment, apply. These standards include principles such as proportionality and distinction, aiming to safeguard civilians and regulate military conduct (Gisel et al., 2020; Murray, 2019). The classification of the conflict is crucial in determining the application of IHL, especially regarding civilian protection, and distinguishing between military targets and non-combatants (Diakonia, 2022). The influx of foreign fighters, particularly through the International Territorial Defense Legion initiated by Ukrainian President Volodymyr Zelensky, has further complicated the conflict. Since 2014, thousands of foreign fighters from 55 nations have joined the conflict, which could escalate tensions and potentially violate IHL if human rights abuses occur (Egle E. Murauskaite, 2022; Nigel Walker, 2023). The presence of foreign fighters raises significant questions regarding their legal status and responsibilities within the conflict. The term "Foreign Fighters" lacks a universally accepted definition in international law. The most authoritative definition originates from UN Security Council Resolution 2178, which references "foreign terrorist fighters." A foreign terrorist fighter is defined as an individual who travels to a country other than their own to engage in activities that support terrorism, including (Bramantyo, 2023). a. Committing acts of terrorism, characterized by violence or threats aimed at instilling fear or causing harm to civilians for political objectives.b. Planning or preparing acts of terrorism, such as target surveillance, recruitment, or weapon acquisition.c. Participating directly in acts of terrorism, providing logistical support, or harboring perpetrators.d. Receiving or providing terrorism-related training, which includes the use of weapons, explosives, or guerrilla tactics. The UN Security Council's approach to foreign fighters emphasizes counterterrorism, evident in the focus of Resolution 2178 on their roles in terrorism. However, this counterterrorism perspective has been adopted at the national level by various member states, shaping their responses to foreign fighters. Various definitions of "foreign combatants" have emerged in academic literature, with one prevalent definition describing individuals motivated by ideology, religion, or kinship to leave their country to join an armed conflict abroad (Van Poecke & Cuyckens, 2023). Key aspects of this definition include. 1) Motivation, foreign combatants are driven by ideological, religious, or familial factors rather than personal gain.2) Movement, they travel from their home country to engage in conflict in another nation.3) Active involvement, their participation extends to combat or related activities. The classification of "foreign combatants" specifically refers to individuals joining non-state armed groups in conflicts abroad, often motivated by ideological, religious, or kinship ties (Baker-Beall, 2023). This classification excludes mercenaries or volunteers driven by other factors. While national security and counterterrorism are frequently the focus of discussions about foreign fighters, categorizing them as terrorists does not negate the application of International Humanitarian Law (IHL), which applies equally to all belligerents, including foreign fighters. Their actions in armed conflicts should be evaluated according to IHL principles (Ho, 2019). The term "foreign terrorist fighters" may complicate legal proceedings by focusing primarily on counterterrorism rather than recognizing the nuances of foreign fighter involvement in armed conflicts. These individuals often participate in both non-state armed conflicts and terrorist activities (Karska & Karski, 2016). The distinction between "foreign fighters" and "mercenaries" is also important, as foreign fighters typically join armed groups for ideological reasons, whereas mercenaries are financially motivated (Floress, 2016; Dano, 2022). Russia's use of the term "mercenaries" may be intended to influence public perception and emphasize the economic aspects of their participation.  Article 47 of the 1977 First Additional Protocol (API) to the Geneva Conventions outlines the legal status of foreign fighters and the limitations on applying the Convention's provisions to individuals from non-signatory states. However, Article 47(2) reinforces that human rights protections remain in effect for foreign fighters, and the responsibilities of conflict parties under IHL are unaffected (Gregorious, 2023). As foreign fighter involvement in conflicts like Ukraine increases, challenges arise regarding their legal status and protections under IHL, necessitating careful consideration of both legal and humanitarian aspects in addressing these issues. 3.5. Human rights of foreign fighters in the context of international humanitarian law The ongoing conflict between Ukraine and Russia has resulted in severe material and psychological consequences for both the civilian population and combatants. Amidst this turmoil, the participation of foreign fighters has garnered significant attention, raising questions about their status and human rights within the framework of International Humanitarian Law (IHL). Despite their involvement in armed conflict, foreign fighters retain certain rights and protections under IHL, necessitating a thorough assessment of their legal status, actions during the conflict, and involvement in armed groups. Thus, the protection of their human rights must be carefully considered in accordance with the principles of IHL, which guarantee fair and humane treatment for all parties involved. 3.5.1. Concerns regarding due process and human rights violations The recent sentencing of three foreign fighters to death by the Supreme Court of the Donetsk Republic has raised serious concerns about adherence to international legal standards. These sentences were issued after proceedings criticized for being swift and unfair, raising alarms about violations of the right to a fair trial, including access to legal counsel and the right to present a defense. The United Nations Commission on Human Rights has previously reported violations in the region, indicating a troubling disregard for internationally recognized human rights norms. In response, the European Court of Human Rights (ECHR) intervened, directing Russia to halt the use of the death penalty and to respect the rights of foreign fighters. This underscores the critical need to uphold fundamental human rights, even amidst armed conflict, and to ensure that individuals engaged in hostilities receive basic protections recognized by international law. 3.5.2. The issue of citizenship and nationality The citizenship status of foreign fighters in the Ukraine conflict is complex due to varying national legal frameworks and policies regarding participation in foreign armed conflicts. Some countries have enacted laws revoking citizenship for involvement in terrorist activities or foreign conflicts, citing national security concerns, though critics argue these measures often lack transparency and due process, risking arbitrary deprivation of nationality. The revocation of citizenship leaves individuals in a legal limbo, vulnerable to prosecution or ill-treatment in other states. Statelessness, a common outcome of citizenship loss, exacerbates vulnerability by denying individuals access to basic rights like education, healthcare, and employment. This issue has significant implications for international human rights. The UN plays a key role in addressing these challenges by facilitating dialogue, monitoring compliance with international law, and advocating for human rights protections. Regional organizations, such as the EU, are also critical in promoting unified approaches and adherence to human rights standards in the treatment of foreign fighters. 3.5.3. Human rights protections under IHL The Geneva Conventions, particularly the Fourth Geneva Convention, emphasize the humane treatment of all individuals in conflict, including civilians and those detained. Article 3 requires non-participants in hostilities, such as civilians and prisoners, to be treated humanely, ensuring respect for basic human rights regardless of nationality or political affiliation. In light of citizenship revocation, states involved in armed conflict must assess their obligations under International Humanitarian Law (IHL) to avoid human rights violations. Revoking citizenship can undermine protections for prisoners of war (POWs), who are entitled to humane treatment, a fair trial, and protection from torture. Arbitrary revocation of nationality risks violating due process, leaving individuals stateless and vulnerable to ill-treatment. States must ensure that national security policies do not compromise fundamental rights. Upholding human rights is not just a legal requirement but a reflection of a state's commitment to justice. International organizations, such as the United Nations and regional bodies, have a crucial role in monitoring compliance and advocating for the rights of those affected by armed conflict. 3.5.4. Obligations of states and international accountability The right to return is a fundamental principle in international law, safeguarding individuals from arbitrary state actions that could lead to statelessness or human rights violations. This right is especially relevant for foreign fighters, who may face citizenship revocation upon returning from conflict zones, further exacerbating their vulnerabilities. The International Committee of the Red Cross (ICRC) stresses that states are obligated to investigate war crimes committed by their nationals and ensure accountability. Revoking citizenship and transferring legal responsibility to other states can create a culture of impunity and hinder accountability for war crimes. Denying the right to return can lead to further human rights abuses, including inhumane detention or exposure to violence in conflict zones. Article 12 of the ICCPR affirms that all individuals have the right to return to their own country, emphasizing that this right is not contingent on actions or affiliations. States must avoid arbitrary deprivation of nationality, particularly in conflict contexts, to preserve these rights. Adhering to International Humanitarian Law (IHL) and human rights standards is crucial to maintaining trust and accountability within the international community. A balanced approach that considers both security and humanitarian principles is necessary in addressing modern conflicts. 4. Research limitations While this study provides valuable insights into the legal frameworks surrounding foreign fighters in the context of the Russia-Ukraine conflict, it is important to acknowledge several limitations. First, the study is limited to a normative analysis of IHL, focusing primarily on the legal aspects of Russia's military aggression against Ukraine, without delving deeply into the political and social dynamics that also play a significant role in shaping the conflict. Second, the sources of data utilized are predominantly drawn from international legal documents and reports issued by international organizations, which may not fully capture the perspectives of all parties involved, particularly those who are underrepresented in global discourse. Third, while the study adheres to established international legal approaches, it faces challenges in assessing the practical application of IHL in the field, due to difficulties in obtaining sensitive or potentially biased information from diverse sources. Fourth, the research does not specifically address the role of third-party states supporting one of the conflicting parties, a dimension that could significantly complicate the interpretation of IHL. In light of these constraints, it is recommended that future research adopt a more holistic and inclusive approach to explore these complexities in greater depth. 5. Conclusion The ongoing conflict between Russia and Ukraine involves direct military engagements between Russian and Ukrainian forces, along with the participation of pro-Russian separatist groups in eastern Ukraine. Foreign combatants have also become a significant factor on both sides of the conflict. Individuals from various countries have joined the Ukrainian side, either as volunteers or part of organized military units, while Russia has provided support to pro-Russian factions, including involvement of Russian foreign combatants. The legal status of foreign combatants is unclear under International Humanitarian Law (IHL), which primarily addresses the rights and obligations of states, military forces, and civilians, leaving ambiguous the status of foreign combatants, whether they act on behalf of non-state armed groups or as independent volunteers. There is a need to avoid misusing terrorism laws that do not differentiate between foreign volunteers, combatants, and mercenaries, as this could undermine the core objectives of IHL, which include ensuring humane conduct in war. IHL's primary goal is to mitigate human suffering during war, not to prevent conflict. It aims to make warfare more humane, ensuring that all combatants, including foreign ones, enjoy the same human rights as nationals. Violations of these rights, such as deprivation of citizenship or the right to life, cannot be justified under any circumstances. As the conflict persists, all parties must respect IHL to safeguard the dignity of individuals and ensure justice and accountability in the conflict. CRediT authorship contribution statementKhoirunnisa Khoirunnisa: Conceptualization. Brian Matthew: Resources. Didi Jubaidi: Conceptualization. Agung Yudhistira Nugroho: Conceptualization.Data availability statementThe data used in this study were obtained from publicly available sources such as the Open Access Library, DOAJ (Directory of Open Access Journals) and , as indicated in the Data section of the article.Funding statementThis research was supported by a grant from xxxxxxxx which had no role in study design, data collection, analysis, interpretation of results, or writing of this article.Declaration of competing interestThe authors declare that there are no conflicts of interest associated with this publication. No financial, personal, or professional relationships with other individuals or organizations have influenced or could potentially influence the work presented in this manuscript.AcknowledgementsThe authors would like to thank all those who have provided technical support and valuable input during this research process.Khoirunnisa Khoirunnisa, Brian Matthew, Didi Jubaidi, Agung Yudhistira Nugroho, The Ukraine-Russia conflict: An international humanitarian law review of the involvement of foreign fighters, Social Sciences & Humanities Open, Volume 11, 2025, 101340, ISSN 2590-2911, https://doi.org/10.1016/j.ssaho.2025.101340.ReferencesAkbar and Sadiawati, 2023, M.N. Akbar, D. Sadiawati, Analysis of the Russian invasion of Ukraine in terms of humanitarian law, Jurnal Ilmiah Mizani: Wacana Hukum, Ekonomi, Dan Keagamaan, 10 (1) (2023), p. 160, 10.29300/mzn.v10i1.10760Alexander, 2023, A. 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ABSTRACT  This paper examines de-dollarization as a geopolitical industrial policy within the BRICS framework and its implications for Cuba, Venezuela, and Argentina. De-dollarization, a process aimed at reducing reliance on the US dollar, has gained momentum among BRICS nations as a response to economic sanctions, monetary sovereignty concerns, and external financial shocks, particularly following the 2008 global financial crisis. For Cuba and Venezuela, de-dollarization is necessary due to US sanctions, pushing them toward alternative  financial  mechanisms  through  BRICS  partnerships. Cuba’s  possible  de-dollarization  follows  increased ties with Russia, China, and Iran. Regarding Venezuela, despite its partial dollarization, Caracas seeks  to  strengthen  non-dollar  transactions  through  oil  trade. In  contrast,  under  President  Javier  Milei,  Argentina  has  rejected  BRICS  and  continues  to  debate  dollarization,  reflecting  the  country’s  historical  and economic ties to the US dollar. The study highlights that de-dollarization is a State-led, multilateral process influenced by external economic conditions and geopolitical alignments. While Cuba and Venezuela actively integrate with BRICS to reduce dollar dependence, Argentina’s approach remains uncertain, shaped by ideological and financial considerations. Keywords: De-dollarization, BRICS, Cuba, Venezuela, Argentina INTRODUCTION De-dollarization is almost a synonym of BRICS. The reduction  of  US  dollar  dominance  and  the  consequential dependence on it represent critical stakes for BRICS countries. Nonetheless, there are nuances and differences amongst BRICS members on monetary policies. Since the first summits (2009–2010), BRICS  asserted  the  Global  South’s  need  to  prioritize  trade  in  domestic  currency  and  refrain  from  US  dollar  pegging. For  initial  members  like  China  and  Russia,  as  well  as  newly  associated  countries  such  as  Iran  and  Cuba,  Western  sanctions  are  the  main  driver  for  de-dollarization. Instead,  for  Brazil,  India, and the majority of most recent BRICS partners  (primarily  from  Africa  and  Southeast  Asia),  de-dollarization  means  enhancing  their  monetary sovereignty,  fostering  domestic  currencies’  value,  and  avoiding  depending  on  US  institutions:  Treasury and Federal Reserve. De-dollarization pertains to  monetary  and  public  policies. Therefore,  it  is  a  state-led process. For this reason, it might be considered an industrial policy. It is necessary to outline that this article adopts the term geopolitical industrial  policy  for  a  State-led  economic  strategy  that,  unlike  inward-oriented  monetary  or  financial  policies, is deeply intertwined with the outward-looking dimension of foreign policy. Hence,  this  work  examines  de-dollarization  as  a  geopolitical  industrial  policy  within  the  BRICS  framework  and  its  implications  for  Cuba,  Venezuela,  and  Argentina. De-dollarization,  a  process  aimed  at  reducing  reliance  on  the  US  dollar,  has  gained momentum  among  BRICS  nations  as  a  response  to economic sanctions, monetary sovereignty concerns,  and  external  financial  shocks,  particularly  following the 2008 global financial crisis. For Cuba and  Venezuela,  de-dollarization  is  necessary  due  to  US  sanctions,  pushing  them  toward  alternative  financial  mechanisms  through  BRICS  partnerships. Cuba’s  possible  de-dollarization  follows  increased  ties  with  Russia,  China,  and  Iran. Regarding  Venezuela, despite its partial dollarization, Caracas seeks to  strengthen  non-dollar  transactions  through  oil  trade. In  contrast,  under  President  Javier  Milei,  Argentina has rejected BRICS and continues to debate dollarization, reflecting the country’s historical and economic ties to the US dollar. The study highlights that de-dollarization is a State-led, multilateral process  influenced  by  external  economic  conditions  and geopolitical alignments. While Cuba and Venezuela actively integrate with BRICS to reduce dollar dependence,  Argentina’s  approach  remains  uncertain,  shaped  by  ideological  and  financial  considerations. It is undebatable that there are differences between usual industrial policies and de-dollarization. Indus-trial policies look inward, are fashioned upon domes-tic  matters,  and  contradict, court,  multilateral  efforts. De-dollarization  is  a  geopolitical  industrial  policy that looks outward, focusing on the role of a given country in the world economy. Without multilateralism, a State pursuing de-dollarization would quickly become a pariah. As a geopolitical industrial policy,  de-dollarization  owes  its  rationale  to  external  shocks. It  is  safe  to  define  de-dollarization  as  exogenously  motivated. The  2008  global  financial  crisis (GFC) represented the critical external shock for  BRICS  members  to  escalate  their  de-dollarization objectives: “[E]specially  since  the  2008  global  financial  crisis,  central banks of many countries have been trying to diversify their portfolios to shift away from the US dollar through liquidating holdings of US Treasuries and increasing other assets including the euro, yen, renminbi and gold.” (Li, 2023, p. 9).  The 21st century wrought incentives to de-dollarization that finally sparked because of the GFC. However,  the  mainstream  doubts  surrounding  de-dollarization involve its feasibility. There are no tools to objectively  measure  the  status  of  de-dollarization  or its future outcomes. Notwithstanding limitations, de-dollarization  is  increasingly  attracting  Global  South economies. Specifically looking at Latin America,  this  work  outlines  how  de-dollarization  becomes  an  obligation  for  sanctioned  countries:  Cuba  and  Venezuela. The  two  ALBA  governments  mingled  with  BRICS  for  a  long  time,1  with  Havana  joining the forum in association and Venezuela almost on the same route, stopped by the Brazilian veto in the  Kazan  summit. Cuban  and  Venezuelan  de-dollarization finds in BRICS a multilateral opportunity.  The third country examined is Argentina since the government  of  Javier  Milei  refused  to  enter  BRICS  and  continuously  flirted  with  dollarizing  the  economy. From President Menem’s pegging to the US dollar (uno a uno) to the 2001 Corralito, Argentina’s recent economic history inevitably rests on currency issues (IMF, 2003). Unlike Venezuela, and on the contrary of Cuba (which is not part of the IMF), Argentina’s economic policies intertwine with Bretton Woods  institutions. That  might  be  the  reason  why  neoliberal Argentinian economists found in dollarization  a  solution  for  Buenos  Aires  (Cachanosky  et  al., 2023).  1. Force Majeure De-Dollarization for Cuba and Venezuela  Since  1999,  when  Fidel  Castro  and  Hugo  Chávez  coincided, de-dollarization meant an industrial foreign policy to antagonize US hegemony. In Cuba, de-dollarization  is  a  more  difficult  process  than  usual  assumptions  and  certainly  more  challenging  than  in  Venezuela. 2004  marked  the  year  when  the  US  dollar  was  officially  prohibited  on  the Caribbean Island, to reverse the dual currency  system  implemented  since  the  Special  Period  (Herrera  &  Nakatani,  2004). The  extra-territoriality  of  US  sanctions,  affecting  in  their  secondary effect  Cuba’s  trade,  led  Havana  to  a  de-dollarization fashioned upon the path that Deligöz (2024) identified  for  China  and  Russia. Besides  realpolitik  and  geopolitical  strategies,  Cuba’s  association  with  BRICS,  occurred  in  October  2024,  is  the  la-test  effort  to  de-dollarize. Venezuela’s  economic  crises and COVID-19 pushed Cuba into continuous indebtedness to survive, with US dollars reallowed but  still  at  limited  provision  due  to  Washington’s  restrictions  (Luis,  2020). To  give  account  of  its  urgencies,  in  a  few  months,  Havana  moved  from  apparent dollarization to initiatives for de-dollarization, thanks to BRICS. Over the summer, Primer Minister Manuel Marrero enabled USD payments in the  tourist  sector  (Gámez  Torres,  2024)  to  tackle  the balance of payments deficit with liquidity. For  a  country  obliged  to  rapidly  change  industrial  policies,  the  BRICS  opportunity  could  not  be  mis-sed. Cuba’s  reliance  on  Russia,  China,  and  Iran  may  materialize   a   complete   de-dollarization   that   can   favor  BRICS  projects  and  escape  US  sanctions. Of  course, the evident permanence of the bloqueo, regardless  of  who  runs  the  White  House,  is  the  main  driver for Cuba’s de-dollarization. A similar but quite nuanced situation applies to Venezuela as well. From the Bolivarian era inaugurated by President Chávez, de-dollarization  entangled  foreign  policy  objectives  even before US sanctions. The Sucre digital currency was  created  by  the  governments  of  Venezuela  and  Ecuador  as  the  main  ALBA  initiative  to  de-dollarize  commercial  transactions  among  Bolivarian  nations  (Benzi et al., 2016). ALBA-promoted Sucre was analogous to BRICS’ favoring of blockchains and digital currencies, limiting the USD to a reference value for the  bloc’s  transactions  (Mayer,  2024). US  sanctions  on Venezuela’s oil production, sparked under the first Trump Administration, meant a significant remotion of USD-denominated transactions for Caracas. Considering  ALBA’s  slow  progress  and  the  infeasibility  of fully adopting the Sucre, President Maduro had to look at BRICS for solutions. Despite  not  having  diplomatic  relations  with  Washington,  Venezuela  is  still  an  IMF  member. Ladasic points  out  that  “[a]s  Venezuela  joined  the  pack  of  countries  trading  oil  outside  of  USD  and  has  instead priced it in Chinese yuan, BRICS together with Venezuela  already  have  16%  needed  for  IMF  veto  power to use in a crisis” (2017, p. 100). The rentier characterization of the Venezuelan economy and its dependency  on  oil  exports  make  de-dollarization  a necessity. As per Cuba, unilateral policies are not enough. Venezuela’s  outcry  merged  with  inflation,  the  devaluation  of  the  bolívar,  and  a  paralysis  of  the  Venezuelan  Central  Bank  (BCV)  that  put  total  dollarization on the industrial-public policies’ table (Briceño  et  al.,  2019). Although  the  country  is  still  under  a  sort  of  de  facto  dollarization,  Venezuela’s  economic  resurrection  should  occur  together  with  a  de-dollarization  strategy. Failure  to  enter  BRICS  in the Kazan summit provides a temporary brake to Venezuela’s  de-dollarization,  but  the  prolific  trade  with China, Russia, Iran, and Türkiye will, in all cases, align Venezuela with BRICS policies. 3. Argentina: De-Dollarizing a Passion Economists  were  surely  interested  in  Javier  Milei’s  dollarization  claims. Less  than  a  year  into  his  government,  dollarization  seems  impossible  to  the  libertarian  president. Milei’s  negative  to  BRICS  demonstrates  that  de-dollarization  is  currently  not  considerable  for  Casa  Rosada. Nevertheless,  it  is  relevant to outline that Argentinian academia questioned  the  role  of  the  USD  and  studied  economic  policies  involving  de-dollarization. Corso  and  Sangiácomo (2023), in affiliation with the Central Bank of  Argentina  (BCRA),  argued  that  de-dollarization  might  help  in  relieving  the  extreme  inflation  saw  under  Alberto  Fernández’s  ruling. Other  authors  implied  that  the  Kirchners’  limitations  on  USD  access would lead to a gradual de-dollarization of the economy,  but  with  constraints  particularly  from  a  USD dominated housing market across Latin America  (Luzzi,  2013). If  under  the  Kirchners,  and  with  support of South American left-leaning geopolitics, de-dollarization  could  really  offer  a  pathway  for  the Argentine economy, with Milei that is barely an option. The  Argentine  relation  with  the  USD  does not hold a clear ideological cleavage. Argentinians’ passion for the dollar, as stressed by Bercovich and Rebossio (2013), embraced diverse political figures such as Perón, Aníbal Fernández (a prominent Kirchnerist politician), and Martínez de Hoz. The peso’s continuous  instability  legitimized  the  widespread  informal adoption of the USD, with first insight fore-seeable in the currency devaluation subsequent to the Great Depression (Díaz Alejandro, 1970). There is also a nationalistic meaning behind the peso, whose  national  heroes  imprinted,  from  Belgrano  to  Evita (Moreno Barreneche, 2023), portray a sentimental attachment to the banknotes that Argentinians do not want to erase. In sum, Argentina’s de-dollarization is as difficult as dollarization. Milei’s obsession for US hegemony inserts de-dollarization in a faraway scenario. Moreover,  Donald  Trump’s  victory,  who  promised  high tariffs to countries that unpeg from the USD (Butts,  2024),  constitutes  a  natural  barrier  to  de-dollarization. Its political viability might depend on an eventual Peronist succession to Milei. Argentina’s financial closeness  to  China,  and  a  possible  resume  of  BRICS  talks,  could  indicate  de-dollarization  as  a  future  last  resort. In this sense, de-dollarization within the BRICS framework might help Argentina in solving structural issues: Chronic external debt and dependency on Bretton Woods institutions. CONCLUSIONS De-dollarization is State-led and can be considered a  geopolitical  industrial  policy. Cuba,  Venezuela,  and  Argentina  show  that  de-dollarization  depends  on  geopolitical  calculus  and  economic  considerations. The incentives may be different, ranging from US sanctions to devaluation of the national currency. However,  unlike  dollarization,  de-dollarization  cannot  be  pursued  unilaterally. The  rise  of  BRICS  motivates  Global  South  countries  to  de-dollarize  under its guarantees. For Cuba and Venezuela, the association  with  BRICS  and  the  interdependence  with other sanctioned economies like Russia, China, and Iran, make de-dollarization an opportunity. Argentina’s  relation  with  the  USD  follows  its  turbulent  economic  history. Simultaneously,  there  is  passion  for  dollars and nationalism toward the peso banknotes. In this  context,  even  Milei  showed  that  dollarization  is  in  no way easier that de-dollarization. The currency issues affecting Argentina might not be resolved by neither of the two policies, but a future BRICS collaboration could bring de-dollarization again into the political debate. NOTES1  ALBA  references  the  Alianza  Bolivariana  para  los  Pueblos  de  Nuestra  América,  a  regional  organization  founded  by  Cuba  and  Venezuela,  including Bolivia, Honduras, Nicaragua, and several Caribbean islands. It was created in 2004 under the auspices of Hugo Chávez.REFERENCESBenzi,  D.,  Guayasamín,  T.,  &  Vergara,  M.  (2016). ¿Hacia  una  Nueva   Arquitectura   Financiera   Regional?   Problemas   y  perspectivas  de  la  cooperación  monetaria  en  el  AL-BA-TCP. Revista Iberoamericana de Estudios de Desarrollo, 5(1), 32–61. https://doi.org/10.26754/ojs_ried/ijds.193. Bercovich, A., & Rebossio, A. (2013). Estoy verde: Dólar, una pasión argentina. Aguilar.Butts, D. (2024, September 9). Trump’s vow of 100% tariffs on nations that snub the dollar is a lose-lose for China and U.S., economist says. CNBC. https://www.cnbc.com/2024/09/09/economist-calls-trumps-threat-to-tariff-countries-that-shun-the-dollar-a-lose-lose.html. Cachanosky, N., Ocampo, E., & Salter, A. W. (2023). Les-sons from Dollarization in Latin America. Free Market Institute  Research  Paper  No.  4318258,  AIER  Sound  Money  Project  Working  Paper  No.  2024-01.  https://doi.org/10.2139/ssrn.4318258. Corso, E. A., & Sangiácomo, M. (2023). Financial De-dollarization in Argentina: When the wind always blows from the East. BCRA Economic Research Working Paper No. 106. https://www.econstor.eu/handle/10419/297801.Deligöz, H. (2024). The Exorbitant Privilege of US Extra-territorial  Sanctions.  İnsan  ve  Toplum,  14(3),  29–52.  https://dergipark.org.tr/en/pub/insanvetoplum/is-sue/86942/1543025. Díaz Alejandro, C. F. (1970). Essays on the Economic His-tory of the Argentine Republic. Yale University Press.Gámez  Torres,  N.  (2024,  July  18).  Cuba  moves  to  ‘partially’  dollarize  economy  as  government  struggles  to  make  payments.  Miami  Herald.  https://www.mia-miherald.com/news/nation-world/world/americas/cuba/article290210784.html. Herrera,  R.,  &  Nakatani,  P.  (2004).  De-Dollarizing  Cuba.  International  Journal  of  Political  Economy,  34(4),  84–95. https://www.jstor.org/stable/40470915. Hurtado  Briceño,  A.  J.,  Zerpa  de  Hurtado,  S.,  &  Mora  Mora,  J.  U.  (2019).  Dollarization  or  Monetary  Independence?  Evidence  from  Venezuela.  Asian  Journal  of  Latin  American  Studies,  32(4),  53–71.  https://doi.org/10.22945/ajlas.2019.32.4.53. IMF. (2003, October 8). 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In  A.  Kaufman  (Ed.),  Cultura  social  del  dólar  (pp.  11–19).  UBA  Sociales.  https://publicaciones.sociales.uba.ar/index.php/socialesendebate/article/view/3319.Mayer,  J.  (2024).  De-Dollarization:  The  Global  Payment  Infrastructure  and  Wholesale  Central  Bank  Digital  Currencies.  FMM  Working  Paper  No.  102.  https://www.econstor.eu/handle/10419/297865. Moreno  Barreneche,  S.  (2023).  El  dinero  como  soporte  material  de  la  disputa  por  el  sentido  de  la  nación:  Estudio  del  peso  argentino  desde  una  perspectiva  semiótica.  Estudios  Sociales:  Revista  Universitaria  Semestral,  64,  1–19.  https://doi.org/10.14409/es.2023.64.e0046. CONFLICT OF INTERESTThe  author  declares  that  there  are  no  conflicts  of  interest related to the article.ACKNOWLEDGMENTS Not applicable.FUNDING Not applicable.PREPRINT Not published.COPYRIGHT Copyright  is  held  by  the  authors,  who  grant  the  Revista  Política  Internacional  the  exclusive  rights  of  first  publication. Authors  may  enter  into  additional agreements for non-exclusive distribution of the  version  of  the  work  published  in  this  journal  (e.g.,  publication  in  an  institutional  repository,  on  a personal website, publication of a translation or as a book chapter), with the acknowledgment that it was first published in this journal. Regarding copyright, the journal does not charge any fee for the submission, processing, or publication of articles.

A new vision for Middle East peace emerged this week which proposes the withdrawal of Israel from Gaza and the West Bank, the disarming and disbanding of Hamas and the creation of a unified Palestinian state. The plan emerged from a “high-level conference” in New York on July 29, which assembled representatives of 17 states, the European Union and the Arab League. The resulting proposal is “a comprehensive and actionable framework for the implementation of the two-state solution and the achievement of peace and security for all”. Signatories include Turkey and the Middle Eastern states of Saudi Arabia, Qatar, Egypt and Jordan. Europe was represented by France, Ireland, Italy, Norway, Spain and the UK. Indonesia was there for Asia, Senegal for Africa, and Brazil, Canada and Mexico for the Americas. Neither the US nor Israel were present. Significantly, it is the first time the Arab states have called for Hamas to disarm and disband. But, while condemning Hamas’s attack on Israel of October 7 2023 and recalling that the taking of hostages is a violation of international law, the document is unsparing in its connection between a state of Palestine and an end to Israel’s assault on Gaza’s civilians. It says: “Absent decisive measures toward the two-state solution and robust international guarantees, the conflict will deepen and regional peace will remain elusive.” A plan for the reconstruction of Gaza will be developed by the Arab states and the Organisation of Islamic Cooperation – a Jeddah-based group which aims to be the collective voice of the Muslim world – supported by an international fund. The details will be hammered out at a Gaza Reconstruction and Recovery Conference, to be held in Cairo. It is a bold initiative. In theory, it could end the Israeli mass killing in Gaza, remove Hamas from power and begin the implementation of a process for a state of Palestine. The question is whether it has any chance of success. First, there appears to be growing momentum to press ahead with recognition of the state of Palestine as part of a comprehensive peace plan leading to a two-state solution. France, the UK and, most recently, Canada have announced they would take that step at the UN general assembly in September. The UK stated that it would do so unless Israel agreed to a ceasefire and the commencement of a substantive peace process. These announcements follow those made in May 2024 by Spain, Ireland and Norway, three of the other European signatories. By the end of September at least 150 of the UN’s 193 members will recognise Palestinian statehood. Recognition is largely symbolic without a ceasefire and Israeli withdrawal from both Gaza and the West Bank. But it is essential symbolism. For years, many European countries, Canada, Australia and the US have said that recognition could not be declared if there was the prospect of Israel-Palestine negotiations. Now the sequence is reversed: recognition is necessary as pressure for a ceasefire and the necessary talks to ensure the security of both Israelis and Palestinians. Israel accelerated that reversal at the start of March, when it rejected the scheduled move to phase two of the six-week ceasefire negotiated with the help of the US, and imposed a blockade on aid coming into the Strip. The Netanyahu government continues to hold out against the ceasefire. But its loud blame of Hamas is becoming harder to accept. The images of the starvation in Gaza and warnings by doctors, humanitarian organisations and the UN of an effective famine with the deaths of thousands can no longer be denied. Saudi Arabia and Qatar, behind the scenes and through their embassies, have been encouraging European countries to make the jump to recognition. Their efforts at the UN conference in New York this week are another front of that campaign. Israel and the Trump administration But in the short term, there is little prospect of the Netanyahu government giving way with its mass killing, let alone entering talks for two states. Notably neither Israel nor the US took part in the conference. Trump has criticised the scenes of starvation in Gaza. But his administration has joined Netanyahu in vitriolic denunciation of France and the UK over their intentions to recognise Palestine. And the US president has warned the Canadian prime minister, Mark Carney, that recognition of Palestinian statehood would threaten Canada’s trade deal with the US. In response to Trump’s concern over the images of starving children and his exhortation “We’ve got to get the kids fed,” Israel has airdropped a few pallets of aid – less than a truck’s worth. Yet this appears more of a public relations exercise directed at Washington than a genuine attempt to ease the terrible condition on the Strip. A small number of lorries with supplies from UN and humanitarian organisations have also crossed the border, but only after lengthy delays and with half still held up. There is no security for transport and delivery of the aid inside Gaza. A sacrifice for a state? So the conference declaration is not relief for Gaza. Instead, it is yet another marker of Israel’s increasing isolation. After France’s announcement, the Netanyahu government thundered: “Such a move rewards terror and risks creating another Iranian proxy … A Palestinian state in these conditions would be a launch pad to annihilate Israel.” But while recognising Hamas’s mass killing of October 7 2023, most governments and their populations do not perceive Israel as attacking Hamas and its fighters. They see the Netanyahu government and Israeli military slaying and starving civilians. Even in the US, where the Trump administration is trying to crush sympathy for Palestine and Gazans in universities, non-governmental organisations and the public sphere, opinion is shifting. In a Gallup poll taken in the US and released on July 29, only 32% of respondents supported Israel’s actions in Gaza – an all-time low – and 60% opposed them. Netanyahu was viewed unfavourably by 52% and favourably by only 29%. Israel has lost its moment of “normalisation” with Arab states. Its economic links are strained and its oft-repeated claim to being the “Middle East’s only democracy” is bloodstained beyond recognition. This will be of no comfort to the people of Gaza facing death. But in the longer term, there is the prospect that this sacrifice will be the catalyst to recognise Palestine that disappeared in 1948.

Abstract The paper considers the question of location in the development and governance of artificial intelligence in Africa. The discussion draws from ideas on locational advantage and the mix of factors that affect inequalities in AI development and how this influences the ability that countries have to shape AI norms, cultures and governance. It analyses policy documents and internet databases to highlight Africa’s place in AI development, the continent’s governance approach and the symbiotic relationship that explains the influence of advanced countries and tech corporations in the AI landscape. Based on this, it proposes the concept of the ‘politics of locationality’ to extend our understanding of how the power resident in AI systems is associated with their primary situatedness and how this reality, in turn, (re)produces imbalances and unequal opportunities for Africa in AI development and governance. It concludes with implications for Africa’s contribution to global AI cultures, design and governance at this time of pressing need for well-balanced AI policies. KeywordsAI governance, culture, ethics, inequality, locational advantage, politics of locationality Introduction The race for supremacy in AI development and governance has gathered pace among leading countries such as the US, European nations and China (Bradford, 2023). Many of the largest AI companies and models trace their origins to these countries and benefit from massive investments in computing, data and skills (Moorosi, 2024). By contrast, African countries mainly boast of AI startup ecosystems coordinated by technology hubs such as Kenya’s ‘Silicon Savannah’ (Eke et al., 2023) and African journalists have had to grapple with tools like ChatGPT, given the relevance of generative AI for media production (Gondwe, 2023). Although many of these experiences show Africa’s creative potential in the AI sector, as well as its growing market for AI technologies and tools (Okolo et al., 2023), there remain complex historical, cultural, political, legal, economic, labour and data factors that the continent faces in its drive towards AI development and governance. This mix of factors is a subject that scholars have considered to varying degrees (Muldoon and Wu, 2023; Png, 2022). I build on this by examining the question of locationality within that mix and how locationality helps to explain aspects of the symbiotic relationship between countries and platforms in shaping AI design and governance principles within a global context. My discussion sits at the intersection of critical media studies (Ott and Mack, 2014), digital geopolitics (Wong, 2021) and AI studies (Crawford, 2021), seeking to demonstrate why AI, understood as a political tool for constructing knowledge and generating maps of meaning, should be situated. This focus on situatedness further ties into studies on economic geography and locational advantage (Dunning, 1998; Iammarino and McCann, 2013), which explain why multinationals such as AI companies are more likely to choose certain locations as headquarters and how these locations are better placed to acquire greater leverage and power. It relates to the understanding that the location where a technology company is headquartered has considerable influence to shape that company’s decisions (Sargsyan, 2016), presupposing that advanced AI development confers locational advantage on the place where this development is primarily domiciled, making it a locus of power in shaping global AI ethics, norms and governance. This presupposition is what I interrogate by asking: How do issues around the location of AI development explain the impact that African countries have to shape AI design, cultures and governance in light of inequalities between advanced nations and the majority world? This question is crucial as it indicates which countries are better positioned as key definers of AI at a time when the design, norms, ethics, principles and governance of the technology are being concretised. It also leads to my argument on what I call the ‘politics of locationality’ as a concept to advance our understanding of how the primary situatedness of leading AI companies in advanced locations (such as the Global North) reveals inequalities in AI development and governance in the majority world. In this paper, advanced locations refer to the US, Europe and China – following Bradford’s (2023) description of them as the three digital empires, having the capacity not only to define the digital ecosystem in line with their cultures and priorities, but also shape the digital values of other countries that fall under their influence. The discussion that follows flows through a review of the literature, my methodology and findings, culminating in my argument on the politics of locationality. Locationality and the mix of factors in AI development Across the AI landscape, ethical principles are vital because they guide AI development, design and governance (Tidjon and Khomh, 2022). In Africa, some of the ethical and cultural values that researchers contend should guide AI development include ubuntu (communal humaneness), humanism and indigenous knowledge (Nayebare, 2019; Mhlambi and Tiribelli, 2023). Not enough of this has been realised, however, given that AI technologies on the continent remain a largely Western import (Eke et al., 2023). Nonetheless, home-grown African AI systems have been on the rise, evident in the creation of technology centres such as Kenya’s ‘Silicon Savannah’, Ethiopia’s ‘Sheba Valley’ and Nigeria’s ‘Yabacon Valley’ (Eke et al., 2023). The centres serve as ecosystems that provide leverage for AI startups that are supported by communities such as Data Science Nigeria and Deep Learning Indaba (Nuwer, 2024). Okolo et al. (2023) found that there are at least 102 of these startups in Africa. But they face challenges ranging from limited infrastructure for energy and computing-intensive technology and lack of expertise (Nuwer, 2024). These challenges presuppose that AI development on the continent is likely to lag behind global advancements – with implications for the influence that the continent has as a place from which AI norms, ethics and governance are shaped. The US remains a dominant player in shaping AI ethics and governance. Chan et al. (2021), for instance, observe that the US is predominant in the AI development space, in line with its economic and cultural dominance and China follows closely behind, pointing to a US-China tech war in digital geopolitics (Wong, 2021). China, in particular, has exported AI facial recognition and smart city technologies to Africa, serving as the continent’s largest foreign ICT investor (Lin, 2024), with increasing access to African datasets (Okolo et al., 2023) – a worrying trend. Also, investments in AI still concentrate in countries like the US and China, with only 1% of global venture capital flows into Africa (Moorosi, 2024). This means profits from AI development are typically reinvested in the leading countries, creating further disparities between them and the majority world (Chan et al., 2021). Although major tech companies (e.g. Google and Microsoft) have invested in Africa by establishing AI labs in African countries, Chan et al. (2021) note that it is common for staff working in these labs to be based in advanced countries. These major AI companies have also diversified their locational presence by outsourcing some operations through an international division of labour across Africa. But they tend to do so in exploitative ways such as hiring low-wage data annotators, highlighting the continent’s locational disadvantage (Ludec et al., 2023). What this points to is the relation of labour and capital, which further underscores Muldoon and Wu’s (2023) description of the global AI supply chain as colonial, since it is actualised through an international division of digital labour that extracts value from labour in the majority world for the benefit of Western technological companies. It also reinforces hegemonic knowledge production through Western values and knowledge that marginalise non-Western alternatives (Muldoon and Wu, 2023). This hegemonic knowledge production leads to questions on the role of the human in the machine, since AI is not based on abstract models, but is embedded in human agency and cultural values (Natale and Guzman, 2022). Additionally, this hegemonic knowledge production not only ties into discourses on power in critical media studies (Ott and Mack, 2014), but also on the relevance of AI for creative and cultural work (Lee, 2022) – as seen in the use of ChatGPT, which, African journalists say, is built on a poor and non-representative African corpus and perpetuates stereotypes of the continent (Gondwe, 2023). What the foregoing, therefore, indicates are the mix of historical, technological, economic, labour and cultural factors that underpin AI development and deployment in Africa’s locational context, with implications for governance outcomes. AI governance and digital regulation in Africa In terms of governance, state actors in Africa have drawn up policy and legal instruments at local levels and are only just taking part in global multistakeholder conversations. Examples of these multistakeholder fora include the AI Governance Alliance of the World Economic Forum (2025), where three African countries (Rwanda, South Africa and Kenya) are represented and the Global Partnership on Artificial Intelligence (2025), where Senegal is the only African country. It is unclear what influence African countries wield in multistakeholder bodies like these, but the indication is that inclusion is usually performative and exists for ‘virtue signalling and promotional purposes’ (Png, 2022: para. 17). At continental and regional levels, Plantinga et al. (2024) observe that African countries have increasingly turned towards AI strategies, but without considering how feasible these are to implement and their suitability to local contexts. There are also data localisation laws, which stipulate that data be stored and processed in the location where they are generated, with restrictions on data transfers across borders (Giovane et al., 2023). These laws, which point to the geographical relevance of data, have been introduced by at least 16 African countries, including Mauritius, Lesotho and Ivory Coast; they are also present in legal instruments on data protection, financial transactions, cybersecurity and telecommunications in several countries across the continent (CIPESA, 2022). Locationality is therefore the underlying principle in data localisation, underscoring the importance of data for AI control and governance. Sargsyan (2016: 2224), for instance, notes: ‘countries that host intermediaries’ data centres and offices have more opportunities to exercise influence over companies’ decisions and claim jurisdiction over data stored in their territory.’ What is crucial here is the presence of data centres which is vital for AI production, and African countries face challenges in relation to data, since the continent’s data centre landscape is nascent although growing (DCByte, 2023). When it comes to enforcement, only a few countries have been successful in imposing local laws and claiming jurisdiction over data stored in data centres, the most successful being the US (Sargsyan, 2016: 2231). This underscores the difficulties of AI policy implementation that African governments face, since, as CIPESA (2022) notes, there is barely any evidence that data localisation laws have been enforced in Africa. Where implementation has been more practicable is in the imposition of internet taxes on users in countries like Guinea, Benin, Uganda and Zimbabwe (Bergére, 2019). The infrastructure platforms through which governments enforce the taxes are local Internet Service Providers (ISPs) and telecommunication providers (Bergére, 2019). The same process finds expression in the imposition of internet bans in Africa – enforcement targets usage disruption and is done through local ISPs (Parks and Thompson, 2020). African countries ordinarily enjoy a positive balance of power in comparison with local ISPs. Also, the fact that major tech and AI companies can be banned from operating or delivering services in any African country points to the power that the state has to impose controls as a means of last resort. Users can also deploy collective action against AI companies (Fratini and Musiani, 2024). All these highlight the diverse ways in which power and governance are contested at local levels but say little about the place that Africa holds in contributing to and shaping AI ethics, governance and worldviews in the global sense. If, as Sargsyan (2016) notes, the location where a technology company is headquartered has significant powers to influence the decisions of the technology company, then what does Africa’s record in AI development imply for its ability to shape AI design, ethics, cultures and governance? This question is what I aim to answer in interrogating the relevance of the politics of locationality for AI in Africa. Method To this end, I draw from a methodological approach informed by textual analysis of AI policy documents and critical analysis of internet databases containing the location associated with AI companies/models. For the AI policy documents, I focussed on three domains. The first domain concerned the AI policies of African countries, where I selected the AI Strategies of four countries: Mauritius (Mauritius AI Strategy, 2018), Egypt (Egypt AI Strategy, 2021), Rwanda (Rwandan National AI Policy, 2022) and Nigeria [draft] (Nigerian AI Strategy, 2024), representing South, North, East and West Africa respectively. I also reviewed the African Union’s (2024) AI Strategy. Mauritius, Egypt and Rwanda are particularly relevant because they are the first three countries to introduce AI strategies in Africa. I chose AI strategies because they comprise one of the major emphases for policymakers on the continent (Maslej et al., 2024). I analyse the strategies based on themes, which I developed after reviewing and coding the texts. The second domain included the AI policies of leading global players in AI: the US, EU and China. Here, my analysis aimed to ascertain whether these policies mandate AI firms to develop their technologies in line with principles and standards upheld by the leading countries. The third domain included the policies of some of the largest AI companies/models: OpenAI and Gemini (for the US), Darktrace (for the UK) and UBTECH and Qwen (for China). My aim was to examine whether these AI companies/models subject their policies and practices to the countries or places where they are headquartered. For the database searches, I accessed and reviewed the following to ascertain the location of AI companies globally: Datamation (see Jungco, 2024), AI Directory (2024) and the Companies Market Capitalisation (2024). I also drew from sources such as Epoch AI (2024), the Emerging Technology Observatory’s (2024) AI Country Activity Tracker and the AI Index Report (Maslej et al., 2024). Overall, my goal was to assess Africa’s place in AI development in comparison with the leading countries in AI before considering the leverage that locationality affords to nations when it comes to AI design, ethics and governance – the underlying premise for the politics of locationality. Locational advantage and AI development in Africa While acknowledging the mix of factors that comprise AI development, my findings focus on locationality by considering the number of AI companies headquartered in Africa and elsewhere. Here, I found that most AI companies are headquartered in advanced countries, with many of the largest AI companies being in the US. These are companies that have significant capitalisation as listed on the Companies Market Cap to scale globally and invest in AI infrastructure and models that fundamentally impact societies. Jungco’s (2024) review shows that the overwhelming majority (80%) of these companies are based in the US (81 out of 101 companies). The closest to this was the UK, which had eight companies out of 101. India and Canada had three each; China and Germany had two each; and Israel and Hong Kong had one each. The same is true for data compiled by AI Directory (2024) and the Companies Market Capitalisation (2024). I compiled the three listings (Jungco, 2024; AI Directory and the Companies Market Cap) and removed duplicates. The combined list comprised 234 of the largest AI companies (see Table 1), ranging from Apple valued at $3.3 trillion to FR8Tech valued at $2.1 million. The outcome shows that at 73%, the US is the undoubted leader. It is followed by India (5.98%), the UK (5.56%), China (2.99%) and Canada (2.56%). There is no African country on the list.   There is a similar outcome for data on notable AI models, such as OpenAI’s ChatGPT, Alibaba’s Qwen and Meta’s Llama. Table 2 shows that, when isolating for AI models owned by organisations or entities that come from only one country, two-thirds (67.7%) of these notable AI models are traceable to the US. Again, no other country comes close; the closest countries are the UK, China, Canada and Germany. Maslej et al. (2024), in the AI Index, also show that foundation AI models, which are the basis for generative AI, are far more prevalent in the US. Again, there are no entries for Africa.   If Africa does not serve as a headquarter for the largest AI companies or models, what then can be said about AI startups? To answer this, I consulted the 2024 AI Country Activity Tracker, which presents data on the number of approved AI patents based on country locations, including patents for AI startups. The data, presented in Table 3, show that Africa is only ahead of the Middle East; even at this, Africa accounts for only 0.000006% or 157 of the 250,224 AI patents captured in the tracker. And only three African countries account for the continent’s figures: South Africa (139 patents), Morocco (17 patents) and Kenya (1 patent). Although this figure of 157 is slightly more than the 102 startups that Okolo et al. (2023) provided, the conclusions are similar: Africa has some way to go in making up for AI development in the future.   All these show that although Africa provides labour and data for AI companies globally and is poised to be a significant market as internet connectivity spreads (Access Partnership, 2024), it barely serves as a headquarter for AI companies, particularly the largest ones. This underscores Africa’s nascent standing in AI development and suggests that African countries will likely be constrained in their ability to shape wider AI ethics, cultures and governance. It perhaps explains why no African country has passed AI legislation into law (although some attempts are underway), with focus instead on AI task forces, national policies and strategies (Maslej et al., 2024). I turn next to the analysis of these strategies to examine the policy approach to AI development and governance in Africa. Analysing AI strategies in Africa My analysis of the AI strategies/policies of Mauritius, Egypt, Rwanda, Nigeria and the AU shows that they coalesce around four main themes: AI adoption for economic growth, AI partnership and collaboration, improving AI ethics and governance and strengthening local AI capacity. The focus on AI for economic growth is understandable, given that AI’s potential for economic transformation is a major attraction. This focus, which is present in all the strategies, highlights how AI can enhance economic development in various sectors (see in particular, the Mauritian Strategy). But more important, in the context of my discussion, are the inequalities in international cooperation and multistakeholder governance that the strategies point towards. To establish this, I refer to Pillar Two of the Nigerian AI Strategy, which underscores the need for partnership and collaboration among local and international stakeholders to leverage AI expertise and resources. The Rwandan AI Policy also recommends international partnerships and collaboration in AI development. But collaborations, especially with international private actors, highlight the need to evaluate where the major partners come from. These partners can collaborate with African countries and invest in AI, but they still operate primarily by rules set in their home countries, even if they also subscribe to laws in subsidiary countries (I establish this point in the next section). The exception would be collaboration within the continent, as can be found in the Egyptian and AU Strategies. The third theme, which focusses on ethics and governance, acknowledges the risks of AI and the need to mitigate them. It considers the importance of having AI principles such as fairness, transparency and accountability (see the Nigerian Strategy). The AU Strategy also mentions the need to guard against bias and risks to African values, indigenous knowledge and cultural heritage. This is connected to the AU’s Agenda 2063, which has a media and culture mandate to support inclusive and ethical AI through values such as ubuntu. But the plan to address these risks, for the most part, points to multistakeholder governance. The Egyptian Strategy, for instance, seeks to ‘actively contribute to global efforts and playing an active role in AI in different international fora’ (Section 5.1). Rwanda’s Policy also intends to ‘actively contribute to shaping responsible AI principles and practices in international platforms’ (Key Policy Recommendation 14). Likewise, the AU Strategy promotes a ‘multi-tiered governance approach’ (Section 2.4.1). They highlight a move towards greater inclusivity in international governance – hence the use of the word ‘actively’ in many of the strategies. My point, however, is that no matter how ‘actively’ African countries intend to influence AI cooperation, ethics and governance, there is a need to first reckon with Africa’s standing in AI development. Policymakers on the continent seem to have recognised this reality, and it is noticeable in their focus on strengthening local AI capacity. The AU Strategy, for instance, notes that Africa faces challenges around lack of computing platforms, limited data for training AI models and a scarce supply of AI skills, observing that, as of 2023, all the world’s supercomputers are located in only 30 countries. The Nigerian Strategy also recognises the need to build ‘affordable and localised infrastructure foundations and the compute capacity’ (Section 1.4.2) by making high-performance computing available. In Rwanda and Egypt, there is emphasis on AI training in schools. Evident here is a recognition that the continent lags behind in AI development, although it has a growing AI startup ecosystem and an unsaturated market for AI. It underscores the need to interrogate AI development, the locational advantages and disadvantages it represents and its links to governance inequalities. I argue that this should be a major consideration in Africa, based on what I describe as the politics of locationality. The politics of locationality Having established the foundational basis for my argument, I now define the politics of locationality as the way in which the power resident in Big Tech and AI systems is associated with their primary situatedness in places of advanced technological and AI development and how this underlying reality, in turn, (re)produces imbalances and unequal opportunities for AI development and governance faced by countries in the majority world, particularly Africa. The politics of locationality highlights the mix of advantages that countries such as the US, China and those in Europe where the largest AI companies are headquartered have. By contrast, African countries, despite advances that have been made in the AI startup ecosystem and state policy interventions, suffer from a range of disadvantages in locational, political, economic, cultural, data, labour and historical spheres. Addressing this mix of disadvantages is what the continent needs to become a location of influence from which the values, ethics and governance that circumscribe AI can be shaped. To expand on my argument, I refer to the AI policies of some of the largest companies and the guiding principles for AI that leading tech countries have drafted. Take OpenAI for instance. The OpenAI (2024) Terms of Use specify that dispute resolution between the company and users anywhere in the world would be coordinated by National Arbitration and Mediation, headquartered in New York. The law that governs the arbitration is the US Federal Arbitration Act. It adds that, ‘California law will govern these Terms’ and ‘claims arising out of or relating to these Terms will be brought exclusively in the federal or state courts of San Francisco, California’ (see Governing Law Section). This is not surprising, given that OpenAI is headquartered in San Francisco. Also, for Gemini (2024), owned by Google, the governing law of its User Agreement is the laws of New York, and the Agreement is seen as a ‘contract wholly entered into and wholly performed within the State of New York’ (see Governing Law Section). I found a similar pattern in the UK and China. In the UK, Darktrace (2024), an AI cybersecurity firm, notes that the governing law of its Master Services Agreement is the laws of England and Wales, except if the customer is located in the US, in which case the laws of California apply. In China, Section VII of the Terms of Use of UBTECH (2023), an AI robotics firm, states: ‘The establishment, effectiveness, performance, interpretation and dispute resolution of this [user] agreement are subject to the laws of the People’s Republic of China (excluding Hong Kong, Macau, Taiwan).’ The same goes for Alibaba’s Qwen (2023), which is covered by the Alibaba Cloud International Website Terms of Use, the governing law of which is that of Singapore, where Alibaba has its office in the Asia Pacific. Hence, I note that AI companies uphold the laws of the countries where they are headquartered, and they subject the governance of their technologies to these laws. AI companies have also come under sustained pressure to develop rules according to the values, ethics and standards of their host nations, thanks, in part, to the dictates of digital geopolitics and the competition for AI supremacy. The US, for instance, had the Biden Administration’s Executive Order on Safe, Secure and Trustworthy Artificial Intelligence (US Executive Order, 2023), through which it sought to promote an AI market that emphasises US innovation and leadership on AI (Section 2(h)) and the need to encourage international partners to support the voluntary commitments of US AI companies (Section 11(a)(ii)). But these voluntary commitments are underpinned by the need for US leadership and ‘to ensure that artificial intelligence is aligned with values shared by all Americans’ (proposed National AI Commission Act (2023), Section 3(g)(1)). The Biden Executive Order was replaced in January 2025 by the Trump AI Executive Order, aptly named, ‘Removing Barriers to American Leadership in Artificial Intelligence.’ All these underscore that a key intention of US policy is that the design of AI mirrors America’s geopolitical leadership, cultural norms, ethics and jurisprudence. A similar line of argument applies to Europe and China. In Europe, the first clause of the European Union (2024) AI Act says its purpose is to lay ‘a uniform legal framework’ for AI development and deployment ‘in accordance with Union values’ (Section 1) and it supports the ‘European human-centric approach to AI and being a global leader’ in AI development (Section 8). In China, there is the Generative AI Measures released in August 2023. The regulation includes a stipulation that generative AI technologies should not produce content that incite the ‘subversion of national sovereignty or the overturn of the socialist system’ (Henshall, 2023: para. 2). The same ethos is evident in China’s 2023 Management of Deep Synthesis of Internet information Services enacted by the Cyberspace Administration of China (2022). It mandates that in developing products such as AI, companies must abide by Chinese laws, correct political direction and value orientation. This was clearly evident in the January 2025 roll out of DeepSeek, a China-based AI assistant, which when asked about Tiananmen Square, refused to answer, saying it follows ‘ethical guidelines’ and added: ‘I respect the laws and cultural contexts in which I operate’ (author’s conversation with DeepSeek). It goes to show that expansive or restrictive design and deployment of AI technologies are subject to the value system prevalent in their originating countries. Hence, the politics of locationality sustains the different visions that leading tech countries have of AI in their battle for supremacy – visions that are not necessarily inclusive of African perspectives even though they find expression on the continent through pervasive deployment and usage. Conclusion In this paper, I have examined the importance of the location of AI companies and, by so doing, introduced the politics of locationality as a concept to extend our understanding and explain the standing that nations have in AI development and how this translates to the influence they wield in AI governance. My discussion showed that although Africa has a growing AI startup ecosystem, a burgeoning user market base and state influence in policymaking, the continent still faces a mix of disadvantages in historical, technological, political, legal, economic, labour and data spheres. This mix reveals the locational disadvantage that confronts Africa as a place from which AI ethics, cultures and governance can be shaped in the global sense. It relates to Hassan’s (2023) point on the ‘lack of African AI innovations that are rooted in the local context but [have] the potential to compete at the global scale’ (p. 1430). What I found was that AI companies that have global scale and presence are headquartered mainly in leading tech countries (the US, China and European nations) and have subjected themselves to the governing laws of these countries. Conversely, the laws and policies of leading tech countries mandate that these companies, among other things, embed the respective country’s ethos, values and cultures into AI systems. The link between AI systems and cultural values as outlined in this paper, therefore, points to the connection between media and cultural studies and AI. In particular, the paper highlights the importance of considering how AI is produced and shaped by cultural understandings, and how AI further projects, shapes and extends culture. It suggests the need for greater research emphasis on the connections between media, AI and culture, given that AI represents the intersection of human labour, machine learning, infrastructure (e.g. data centres), mineral resources (e.g. lithium), media inputs (vast troves of data: information, texts, pictures, videos, maps, and codes) and classification systems that all combine to transform AI models into mechanics of knowledge construction (Crawford, 2021). The outcome are mediated outputs (e.g. AI responses to prompts and automated decisions) – outputs that simultaneously represent and transform culture, even as they are shaped by it. Equally crucial and more important, in the context of this paper, is the need to consider the locationality of it all. By this I mean the globalised and complex interaction of locations in AI development and governance that potentially determines whose culture is elevated and whose culture is progressively silenced in a relationship defined by hegemony and inequality. Key to understanding this hegemony-inequality mix is the principle of locational advantage, which Iammarino and McCann (2013) describe as a two-way relationship between multinationals and their locational headquarters, noting that just as location is becoming increasingly vital for multinationals, so also are multinationals progressively more important for location (i.e. cities or countries). It underscores my argument on the politics of locationality, which shows that just as large AI firms need locations, such as the US or China, that have the right mix of advantages to serve as headquarters, so also do leading tech countries need and use these firms in setting the cultural and governance paradigm for AI technologies. This structural makeup reflects the imbalances in AI development, explaining why AI governance systems exist within institutional-heterogenous regimes that reproduce Global North dominance (Png, 2022). Addressing these imbalances is what African countries, supported by the AU, should focus on, and there are initial signs that African countries are starting to do this (as seen in the AI strategies). However, a bolder and more robust approach to AI development that is attuned to Africa’s unique sociopolitical context and economic evolution is needed to confront the imbalances tied to the politics of locationality. By so doing, Africa can be positioned to assume locational advantage, with important consequences for inclusive AI and the contribution of global majority countries to the cultures and values embedded in AI systems and the ethics and frameworks by which they are governed. AcknowledgmentsThe author extends appreciation to the editors and reviewers for their helpful and constructive comments, and also to the participants at the 2023 International Symposium on AI Cultures at the University of Turin for their feedback – all of which strengthened the article.Declaration of conflicting interestsThe author declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.FundingThe author disclosed receipt of the following financial support for the research, authorship, and/or publication of this article: This work was supported by the Leverhulme Trust as part of an Early Career Fellowship. 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The structure of the Yemeni crisis (YK) developed step by step throughout the period after the unification in May 1990 of two republican states — the Yemen Arab Republic (YAR) and the People’s Democratic Republic of Yemen (PDRY) — into a unitary state. The rushed and unprepared process of merging the government bodies and armies of two countries with different political systems and ideologies, but related historical, cultural, and ethnic communities, coincided with major global changes: the transformation of the international system, the collapse of the USSR, and the Gulf War, which brought sanctions from the United States and Gulf monarchies against the young state, as well as the expulsion of nearly one million Yemeni labor migrants from these countries. After that, political Islam began to grow stronger across the region. Both countries entered unity carrying a heavy burden of internal social and political problems, hoping that unification would create a new model of development, and that a new source of income from oil exports — from fields recently discovered in the neighboring provinces of Marib and Shabwa — would speed up modernization and help solve these problems. But this did not happen — the democratic institutions, multi-party system, and the first direct presidential elections introduced by the new state’s constitution did not stop the return to power of the conservative coalition from the YAR era, and the oil reserves were not enough to repeat the success of wealthy oil-producing countries. However, the alliance between the General People’s Congress (GPC) and Islah quickly turned into rivalry just a few years after they defeated the former ruling party of the PDRY — the Yemeni Socialist Pa rty (YSP) — in 1994. A religious reform focused on spreading Salafism, led by the Islamist wing of Islah (Yemen’s branch of the Muslim Brotherhood), became a tool of political struggle. It challenged the regime of President Ali Abdullah Saleh (1947–2017), who personally oversaw the state’s security sector but gave Islah control over education and significant legislative functions. The reform led to growing tensions — first due to clashes with the Shafi’i traditions in the South, and then with Zaydi practices in the North. The aggressive spread of a proselytizing version of radical Salafism through a network of religious colleges (ma'ahid ilmiyya) under Islah’s supervision was seen by local communities as an official government policy. This created distance between society and the state. Dissatisfaction with the country’s social, economic, and political situation turned into conflicts of identity of a new kind, with no precedent in Yemen’s history. These conflicts had nothing to do with the traditional Sunni-Shia divide, as Yemen has long been home to two Islamic schools — the Shafi’i (about 60% of the population) and the Zaydi (about 40%) — that are close in theology and law (aqidah and fiqh). In public opinion, the situation was seen as a clash between true Islam rooted in authentic Yemeni traditions and a foreign, radical takfiri current that caused deep divisions. The consequences of this conflict in the South appeared in the idea of a “southern identity,” which replaced the idea of a united Yemeni identity that the republican regimes of the YAR and PDRY had promoted before unification. This idea became the base of the ideology of “southern nationalism,” which set the “southern” society against the “northern” or “Yemeni” one — describing the first as “advanced” and the second as “backward,” tribal, and fundamentalist, and therefore incompatible. Since 2009, political leaders of the South Yemeni separatist movement “Hirak” (Peaceful Southern Movement) have used the slogan of restoring the status quo — independence of the South within the 1990 borders of the PDRY — as the best way to peacefully solve the “southern question.” At the same time, in the northern Zaydi provinces of Yemen, the takfiri practices of the “reformers” caused a similar defensive reaction from Zaydi youth. Against the Salafi proselytism of the international school Dar al-Hadith in Dammaj (near the Zaydi stronghold of Saada since the 9th century), the Zaydi intellectual elite created the “Shabab al-Mu’min” movement, which praised the historical role of Yemenis in Islam. It was led by former MP from Saada province, Sayyid Hussein al-Houthi (1959–2004), who gave lectures in 2001–2002 that formed the base of a new form of political Islam known as “Hussism.” It was a mix of theology and political theory, trying to explain the problems of the Muslim world and offer solutions. Its roots were in Zaydi theology. The idea of the “Qur’anic path” led by a spiritual leader — the ‘alam al-huda — aimed to rebuild unity in the Muslim community (ummah), combining ideas from different Sunni and Shia political movements and adding an element of Yemeni nationalism. Despite its originality, it had some similarities with Khomeinism, Salafism, the Muslim Brotherhood, nationalism, and other ideologies, making it a subject of criticism and speculation, even from other Zaydis. It focused on the civilizational injustice of global politics. In this teaching, takfirism was seen both as a distortion of Islamic values and a tool of US and Israeli (Zionist) policies to block a peaceful solution to the Palestinian issue. After the US invasion of Iraq in 2003, Hussein al-Houthi saw this as a sign that the Arab-Muslim world should mobilize to defend itself from future invasions aimed at taking resources by removing identity. In domestic politics, the Houthi movement followed only legal methods: they called for removing the religious reform (and the Islah party) from state privileges, and excluding the security sector from US cooperation. This idea went against President Saleh’s policy of strategic partnership with the US, which started in 2001 when Yemen joined the global US-led counterterror campaign after 9/11. This partnership gave mixed results: it helped build anti-American feelings in society, even as it made Yemen seem more important regionally and gave Saleh’s relatives in the security agencies close contact with US partners. In 2004, President Saleh declared war on the Houthis after they refused to stop chanting their slogan in mosques in Sanaa: “Death to America! Death to Israel! Curse the Jews! Victory to Islam!” — which became a symbol of the movement and expressed its main ideas. The bloody and failed Saada wars of 2004–2010, and the death of their respected leader in 2004, weakened the regime and brought more armed tribes and other groups to join the Houthi resistance. This made them a strong local opposition force. A year before the peaceful uprising of 2011 that shook Saleh’s regime, the so-called “Houthi problem” had already become one of the country’s top national issues, next to the “southern question.” Experts described Yemen in the 1990s and 2000s as unstable. Many American political scientists saw it as a “fragile state,” a term used by the World Bank in the early 1990s. In the 2000s, Yemen gained the image of a global center of “terrorist threats” and became a testing ground for the military and political actions of US intelligence. The “fragile state” concept helped justify direct foreign intervention. At an international conference in London in January 2010 about Yemen, the focus was on security, not reform, as Yemenis had hoped. In 2011, Yemen became one of the key places hit by the wave of protests known as the “Arab Spring.” The idea of a “fragile state,” military spending, and the weakening of national sovereignty all led to the shift of conflicts into violent areas instead of using the democratic tools in the constitution. But the crisis in the relationship between society and the state, and among political actors, could also be seen as a natural immune response of a healthy cultural system — reacting to political problems: Islah still had support from the kingdom that backed the religious reform, while the US became more involved in Yemen’s security agencies despite public anger. Even though the protests in February 2011 were spontaneous and had no central leadership, they had the signs of a real social revolution. There were clear problems at both the top and bottom of society. The Yemeni revolution followed a unique peaceful transition plan — the Gulf Cooperation Council (GCC) Initiative, launched on 23 November 2011 under the UN Secretary-General’s special envoy. The plan gave the task of creating a new constitution to an inclusive National Dialogue (ND) in Sanaa (March 2013 – January 2014), which showed that civil society was alive and strong in Yemen — something not possible in a truly “fragile state.” The organizers of the ND focused its agenda on the two key issues — the “southern question” and the “Houthi problem” — showing that internal Yemeni problems were the main priority in the transition. The only outside part of the plan was the proposed reform to decentralize and federalize the state, seen as a solution to these problems. A unique part of Yemen’s transition was that President Saleh remained head of the ruling party (GPC) even after officially handing over the presidency to his deputy — interim president Abdrabbuh Mansour Hadi — in February 2012. An attack on Saleh in June 2011 turned the former partners and rivals — the GPC and Islah — into true enemies. This attack also left Islah’s leadership without support in 2014, as the Hashid tribal confederation (which included Saleh himself) no longer backed them. A new alliance formed in 2014, with the GPC and the Houthi movement “Ansar Allah,” combining “conservatives” and “revolutionaries.” This gave a political defeat to Islah, whose spiritual leader saw the revolution as the start of a coming caliphate. President Hadi signed the “Peace and National Partnership Agreement” on 21 September 2014, which the UN Security Council supported. It allowed him to shift his regime’s support from Islah to the new alliance and to form a new technocratic government under Khaled Bahah in December 2014. With this change, the foreign actors’ bets on Islah’s victory failed, and Ansar Allah became one of the expected winners of the transition, along with the GPC. Only in late January 2015 did interim president Hadi show signs of crisis by offering his resignation. But the UN envoy Jamal Benomar still believed in the peaceful plan until 24 March 2015, staying in the capital Sanaa, which was controlled by the new alliance, even after Hadi fled to the separatist-held city of Aden on 21 February 2015. The peaceful project fell apart dramatically in March 2015, and many actors offered different explanations. The idea of a “Houthi coup” (with no exact date) became official after the Arab Coalition launched its military intervention on 26 March 2015. This version was confirmed by UN Security Council resolutions and became part of the Yemeni discourse, now shaped more by the regional rivalry between Saudi Arabia and Iran than by Yemen’s own internal problems. Among the lessons of the transition process, along with proof of the effectiveness of the inclusive National Dialogue (ND), we can also point to the doubt it created about the expert community’s firm belief in decentralization and federalization of Yemen. The debate between Yemeni participants on this issue almost caused the conference to collapse, showing the deep disagreement between major Yemeni actors on how many federal regions there should be and how they should relate to the central government. Strong traditions of regionalism in the young Yemeni state raised real concerns that the result of this idea could be state collapse instead of unity (as seen in the countries the reform authors wanted to copy). By mid-2025, the Yemeni crisis (YC) had gone through four stages: two mentioned earlier — during President Saleh’s rule and the implementation of the Initiative — formed its internal (endogenous) stage; and two newer stages after the Arab Coalition (AC) intervention in March 2015 — the geopolitical (military) stage. The AC military campaign in Yemen lasted seven years before entering a phase of steady de-escalation in April 2022. The current “Palestinian” stage began in October 2023, when the YC shifted into a new kind of conflict — a combined armed conflict of supra-regional level (mixing regional and global elements). What makes it unique is its direct link to the situation in the Palestinian-Israeli conflict (PIC) zone and Israel’s war in Gaza. The leading actors in this stage were first the US and the UK, who formed a naval coalition in December 2023 to stop anti-Israeli Houthi actions, and later Israel itself. We recall the prophetic comparison of the YC to a “ticking bomb” made in summer 2015 by UN Secretary-General Ban Ki-moon, warning that it could explode unless stopped early through political settlement. By summer 2025, the YC had absorbed not only unresolved internal problems but also several layers of subregional and regional issues, becoming a military-political “ticking bomb” for the whole region. Discussions about the cause of the YC’s new military phase range from security threats to shipping in the Red Sea by the Houthis and threats to Israel by the “Axis of Resistance” led by Iran, to opposing claims that the US and Israel are to blame for aggressive actions and blocking a legal settlement to the Gaza war. But for our study of the YC’s structure, another point is more important — the ongoing failure to resolve the YC during all its earlier stages, mostly due to outside geopolitical interference. The new stage stands out because the line between Yemen’s internal and external problems has disappeared. It is now part of a larger ethnic and religious conflict in another part of the region. Still, this link, through an ideological concept born in Yemen, does not feel artificial. Houthism, long under pressure since 2004, has now returned as a form of political will of the population — worn out by war but still determined. This fact again shows how unsuitable military methods are for solving the Yemeni conflict. Another unusual aspect of this new geopolitical stage is the inconsistent way the Houthis are labeled as international terrorists — depending on the mood of the US administration. Regional actors also switch between accepting and ignoring this label based on the situation. The accusation creates a legal problem regarding the status of the second major actor in Yemen’s ruling coalition — the core of the GPC party, which recognized the constitution and formed a government in Sanaa in August 2016. This unrecognized government controls about 30% of the territory, where more than 70% of Yemen’s population lives. The equal participation of Ansar Allah and the GPC in fully restored state institutions leaves open the question of how the US defines the GPC’s role in terrorism, especially since the party, led by ex-president Saleh, was a US partner for nearly 10 years before 2011. In the Supreme Political Council — the top body of the Sanaa government — there are 10 members, five from each group. The head of the council has always been from Ansar Allah, but the posts of prime minister, foreign minister, and some military and security positions were mostly held by GPC members. Another problem is linked to UN Security Council Resolution 2216, which demands the Houthis give up heavy weapons and leave Sanaa — in other words, surrender. But since the ruling coalition in Sanaa is joint, it is unclear whether the same demand applies to the GPC, which traditionally controlled the army and security services. There is no doubt about the status of the internationally recognized government (IRG), which is officially accepted, even by Russia — although Russia criticized Resolution 2216 during discussions and did not vote for it. Still, there is a question about the realism of demanding the Houthis hand over all weapons (meaning the arsenal collected during Saleh’s time) to Hadi’s government in exile, which was located entirely in a neighboring country with a complex past in its relations with Yemen. The main reasons the YC shifted to a new phase in October 2023 likely include: 1) the outdated UN framework for conflict resolution; 2) the limited and misleading use of the “proxy war” model to explain a complex conflict involving the AC, framing it only as a Saudi-Iranian proxy war; 3) the competition of many foreign powers for geopolitical influence in Yemen while ignoring Yemenis' own right to sovereignty. Before the transition of the YC to the "Palestinian" phase, two approaches to its settlement had formed in the discourse on YC — the official one (but non-functional) and the pragmatic one (but not acceptable to several internal, and especially external, powerful actors). The specific nature of this division, reflecting the mixed endogenously-geopolitical nature of YC itself, lies in the attempts by powerful interest groups behind them to implement incompatible approaches through the same permanent special mission appointed by the UN Secretary-General. The first approach was set by UN Security Council Resolution 2216 (April 2015), which formally became the legal basis for the UN mission’s work and focused on a military solution to the “Houthi problem” — applying pressure on the unrecognized regime in Sana'a until the Houthis surrendered completely. The second approach, which emerged almost immediately after the war began in March 2015, came from the expert community. It largely agreed with the criticism of Resolution 2216 voiced by the Russian Permanent Representative to the UN Security Council (2006–2017) V. I. Churkin and was based on an understanding of Yemeni realities rather than the wishes of foreign actors. It has long served as the practical guide for the current head of the UN mission in Yemen, Hans Grundberg, and includes two main elements: a) assisting in the prompt end of foreign military intervention in YC; and b) launching a comprehensive political peace process in an inclusive Yemeni format under UN auspices. This scenario gave a “green light,” in particular, to the Omani track and the de-escalation regime that began in April 2022. The UN mission and Russian diplomacy actively supported its progress at every stage. The de-escalation regime and the Omani track of direct talks between Riyadh and Sana'a on the terms of ending the war became the main outcome of the years-long war in Yemen and one of the most important achievements of the reform policy of the Saudi Crown Prince Mohammed bin Salman. The new leader of the Kingdom began his involvement in YC as the commander of Operation “Decisive Storm” conducted by the AC, and in 2021–2022, thanks to him, Saudi Arabia became the initiator of the process to end the conflict based on its own model and using a regional format. Liberal reforms in Saudi Arabia, which affected the religious sphere starting in 2017, the threatening dynamics of the military conflict in Yemen, which hindered Saudi Arabia’s strategy to achieve leadership under the “Vision 2030” concept, and finally, the revision of approaches to the regional security system involving Iran — all came before this shift toward de-escalation in the YC zone. Its intellectual basis was a scholarly monograph published in 2022 by the respected King Faisal Center for Research and Islamic Studies (KFCRIS) in the Kingdom of Saudi Arabia titled “The Houthi Movement in Yemen: Ideology, Ambitions, and Security.” Most of the articles were written by well-known representatives of various Western schools of Oriental studies and Yemeni research centers. They reached a common conclusion that the concept of “proxy” does not apply to the Yemeni Houthis. According to them, this very construct contributed more to the development of relations between the Sana'a regime and Iran and the “Axis of Resistance” during the war years than it reflected any prior allegiance to Tehran’s interests before the conflict began. The authors agreed that the roots of Houthism lie both in Yemeni history and traditions and in the distressing modern political situation in the Middle East after the September 11 attacks, which, in the view of Sayyid Hussein al-Houthi and his brother — Sayyid Abdul-Malik al-Houthi, the current leader of Ansar Allah — was largely caused by US policy that threw the region into chaos. Of course, these “findings” in the monograph did not make the relationship between Saudi Arabia and Ansar Allah friendly, but removing the label of “enemy agent” from the movement allowed both sides to sit at the negotiating table and return the “Houthi problem” (among others) to the agenda of general YC settlement in the Yemeni format. The stable de-escalation regime received support from the UN mission but faced strong opposition from various competing centers of political influence (CPI), who feared losing status and were united in April 2022 into the Presidential Leadership Council (PLC) headed by the new president of the MPP — Rashad al-Alimi. The United States also supported their discontent out of fear that regional actors might take over the initiative in the Yemeni settlement. US President Biden’s Special Representative for Yemen, Tim Lenderking (2021–2025), repeatedly spoke of the leading role of the US, indirectly blaming the UN mission for its support of the Oman talks. A telling example is his statement at the Foreign Affairs Committee hearings in December 2022: “The Houthis’ last-minute demand to direct limited oil export revenues, received by the Yemeni government, to pay salaries of active Houthi combatants, even though the Houthis refused to commit to a ceasefire, prevented the UN from concluding a new truce agreement between the parties in October… These actions are an insult to the entire international community and completely unacceptable. ” The two official visits exchanged between Riyadh and Sana’a in April and September 2023, after the normalization of relations between Saudi Arabia and Iran with Beijing’s mediation in March, differed significantly in the atmosphere of negotiations: the enthusiasm clearly declined, increasing Sana’a’s uncertainty about the outcomes and timing. If the agreement on a "roadmap" within the framework of the Omani track — whose readiness was only announced by H. Grundberg on December 23, 2023 — had been reached earlier, a new escalation in YC might not have occurred at all or would have taken a much less aggressive form. The new stage of the military phase in YC covers the period from October 7, 2023, to May 6, 2025, and is divided into three phases. The de-escalation regime along the military contact line between AC and SA forces remained in effect, although in all other aspects of the process it noticeably deteriorated, pushing the humanitarian and economic situation to the brink of collapse. It should be noted that the initiative to link YC with the situation in the PIC zone came solely from the unrecognized regime in Sana’a and had nothing to do with the policy of Yemen’s official authorities — the MPP, which expressed itself in supporting resolutions of international summits, the Arab League (AL), and the Organization of Islamic Cooperation (OIC), condemning Israel for the genocide of Gaza’s Palestinian population but prioritizing the goal of preventing conflict escalation. Many members of the Presidential Leadership Council (PLC) sharply criticized the Houthis’ policy, describing them as a terrorist group, and their actions in the Red Sea against Israel as harmful to Yemen. This nuance should be taken into account, especially when encountering media headlines like “Yemen enters war with Israel,” which rather reflect the strong resonance of Sana’a’s policy in the Arab-Muslim world, coordinated with members of the so-called “Axis of Resistance.” The following refers specifically to the policy of the unrecognized regime — the initiator of the new stage. The push to move to a new phase in YC was triggered by the sudden raid of Hamas fighters on October 7 — “Al-Aqsa Flood” — and the large-scale, well-prepared Israeli army operation in Gaza “Iron Swords,” which led to near-total destruction of the city and raised the number of victims to about 9% of its population by June 2025. During the first phase from October 7 to December 18, 2023, the leaders of Ansar Allah took full control over shaping the domestic and foreign policy of the unrecognized Sana’a regime, achieving a significant breakthrough in unifying its ideological base on the Houthi doctrine. The Palestinian issue had already played a major role in the rhetoric of Ansar Allah leaders when condemning the military intervention in Yemen by Saudi Arabia and the UAE — which they called “unprovoked aggression,” staged by their common enemies — the US, Britain, and Israel (referred to as the “unholy trinity” in the regime’s rhetoric), aimed at preparing a strategic base in the Red Sea under the hostile New Middle East project. Now the topic of Palestine and Jerusalem became dominant. The solidarity campaign with the Palestinians under the name “Battle of the Promised Victory and the Holy Jihad” covered all areas of the unrecognized regime’s policy and filled the entire internal discourse. Weekly, well-organized mass marches with slogans from the Demonstration Organizing Committee, accompanied by public lectures and religious sermons by the movement’s leader Sayyid Abdul-Malik al-Houthi broadcast on screens, served as the official manifestation of the Yemeni people’s will and determination to stand firm in defending the rights of the Palestinian people. They included not only threats against enemies but also criticism of Arab and Islamic states’ policies for their “negligence,” and of the MPP, described as “anti-people.” In October–November 2023, the campaign of civilian solidarity with the people of Gaza was supplemented by military-political actions of the Houthi regime under the slogan directed to Hamas organizations, “You are not alone!” The unrecognized authorities blocked Israeli shipping through Bab-el-Mandeb, launched missiles toward the Israeli Red Sea port of Eilat, significantly disrupting its operations. At the same time, combat training courses were organized to prepare “hundreds of thousands of Yemenis” for voluntary entry into the war against Israel. Expressions of loyalty to the “leader of the revolution” — Sayyid Abdul-Malik al-Houthi — reached unprecedented levels, spreading across the military leadership at all levels. The head of the Supreme Political Council (SPC) of the Sana’a regime, Mahdi al-Mashat, emphasized that the countermeasures he introduced against Israel were tied exclusively to the war and blockade in the Gaza Strip, with no intention to obstruct freedom of navigation through the Bab-el-Mandeb strait for other companies and ships. Overall, the ban affected about 1–1.5% of the cargo flow. The second phase, from December 18, 2023, to January 19, 2025, covers the conduct of the “Poseidon Archer” military operation with the participation of the US-UK Maritime Coalition (USUKMC) during the Biden administration. In a joint statement from the US government and several of its partners dated January 3, 2024, referring to attacks on about 10 cargo ships using around 100 drones from Yemen’s shores, it stated: “... the attacks threaten the lives of innocent people around the world and pose a serious international problem requiring collective action. Nearly 15% of global maritime trade passes through the Red Sea, including 8% of global grain trade, 12% of maritime oil trade, and 8% of liquefied natural gas. International shipping companies continue to reroute their vessels around the Cape of Good Hope, resulting in significant costs and weeks-long delays in deliveries, ultimately putting at risk the transportation of essential food, fuel, and humanitarian aid worldwide. Let our message be clear: we call for an immediate end to these illegal attacks and the release of unlawfully detained ships and crews. The Houthis will be held accountable for the consequences if they continue to threaten lives, the global economy, and the free movement of trade along key regional waterways.” The strikes launched by USUKMC on January 11, 2024, aimed to “restore freedom of navigation” through the strait and deprive Sana’a of the military capability to continue its ship attacks. Israel was not mentioned, but within Yemen, the openly pro-Israel orientation of the campaign against the Sana’a alliance (SA) seriously complicated the MPP’s position. The operation ended on January 19, 2025, without achieving its objectives, following Biden’s departure from the presidency. U.S. partners in the EU and the region refused to operate under U.S. command. The EU’s “Aspides” operation focused on covering and escorting merchant ships. Among the Gulf countries, only Bahrain participated in the US-UK Maritime Coalition (USUKMC), providing a base for U.S. and British fleets and CENTCOM’s command headquarters. The U.S. invoked Article 51 of Chapter VII “Action with respect to threats to the peace, breaches of the peace, and acts of aggression” of the UN Charter (the right of self-defense) to justify its aggression in Yemen. The legal side of the USUKMC operation was extensively criticized by the Russian Ministry of Foreign Affairs and Russia’s Permanent Representative to the UN Security Council, V.A. Nebenzya. In his detailed letter to UN members dated January 22, 2024, he presented Russia’s position, describing the actions of the U.S. and Britain as a blatant violation of international law and a threat to peace. Russia did not support the Houthi threats to navigation but, amid the even more explosive situation in Gaza — which the Houthi countermeasures aimed to contain — proposed that both issues be resolved simultaneously through balanced, comprehensive solutions. This approach was also shared by most regional actors, who were primarily concerned about threats to shipping posed by the USUKMC military campaign in the Red Sea itself. According to the 2024 annual report of the Suez Canal Authority, revenue from ship traffic fell by 60%, depriving Egypt of about $7 billion (compared to a 2–3% drop before the formation of the “Guardian” coalition). Almost every quarter during the military phase of the “Palestinian” stage, the Houthis demonstrated new types of weapons and improved tactics for attacking maritime targets, including both commercial and military ships of the U.S. and Britain, which were added to Sana’a’s blacklist after the aggression began. This development triggered threats toward Iran, accused of supplying weapons to the Houthis while bypassing all checkpoints established since March 2015 — long controlled by the U.S. and British navies. On July 20, 2024, Israeli aviation joined the USUKMC “Archer” operations — one day after a Yemeni drone exploded in Tel Aviv. In the second half of the year, Israel launched three more attacks, coordinated with USUKMC combat operations. Meanwhile, strikes on Israeli territory from Yemen intensified. From October 2023 to mid-January 2025, Sana’a media reported 92 air raids on various targets in Israel, including the Haifa port on the Mediterranean (jointly with Iraqi resistance forces) and Ben Gurion International Airport in Tel Aviv. During this period, the Houthis also attacked 24 Israeli ships. They carried out 78 combat operations against the U.S. Navy, attacked 30 American commercial vessels, and 13 British ships. Attacks on Israeli territory involved cruise and ballistic missiles, some with hypersonic capabilities that pierced Israel’s defense systems, as well as large numbers of drones. According to incomplete data, during the first year of the “Archer” operation, USUKMC launched 1,200 strikes on Yemen. The combat experience gained by U.S. forces in the war with Yemen in the Red and Arabian Seas was recognized by many experts as instructive, becoming a subject of close study of a conflict in which drones worth up to $20,000 were countered by air defense missiles costing $1–4.5 million each. The change of administrations in the White House triggered a pause in the Gaza war on January 19, 2025, and a simultaneous halt in Houthi attacks on all ships in the Red and Arabian Seas. However, the arrival of President Trump was accompanied by a major escalation of the U.S. military operation, which was named “Furious Rider.” Trump's designation of the Houthis as a Foreign Terrorist Organization (FTO) on January 22, 2025, coincided with the pause in hostilities and contradicted the call from UN mission head H. Grundberg for a full ceasefire in the Red Sea, citing Yemen’s dire humanitarian situation. At the UN Security Council briefing on February 13, 2025, he began his speech with a call for deescalation. However, on March 15, 2025, the U.S. resumed heavy bombing of Yemen just before the truce in Gaza collapsed due to Israeli actions. The Washington Times wrote: “President Trump warned the Iran-backed terrorist group that it must stop all attacks on commercial shipping in the Red Sea, or ‘you will face a hell like you’ve never seen before.’” The new wave of daily, unprecedentedly intense strikes on Yemen under the “Furious Rider” operation continued from March 15 to May 6, 2025. The beginning of the operation was marked by a loud political scandal — “Signalgate” — related to the leak of confidential information about the planned U.S. military operation in Yemen. The leak was published in an article by The Atlantic’s editor-in-chief Jeffrey Goldberg, who had accidentally joined a messenger chat created by National Security Secretary Mike Watts, who was later dismissed over the incident. The operation involved the aircraft carrier USS Harry S. Truman (CVN-75), which lost three F-18 jets in multiple incidents, each valued at $67 million. The U.S. also lost over a dozen heavy MQ-9 Reaper drones, each worth $30 million, shot down over Yemen. The cost of the U.S. operation in Yemen is estimated at around $7 billion. In late April 2025, British aircraft rejoined the “Rider” operation. On May 5, Israeli aircraft carried out its first large-scale strike of the campaign on sensitive infrastructure and residences of Ansar Allah’s political and military leaders, continuing attacks even after President Trump declared the operation over. At an investment forum in Riyadh in mid-May, the American president gave the following comment on his decision: “In recent weeks, after repeated attacks on American ships and on the freedom of navigation in the Red Sea, the U.S. military carried out more than 1,100 strikes on the Houthis in Yemen. As a result, the Houthis agreed to stop. They said, ‘We don’t want this anymore.’ You’re hearing this from them for the first time. They’re tough guys, they’re fighters. But just a few days ago, we asked them to stop attacking commercial ships. They had no intention whatsoever of targeting trade vessels or anything American, and they were very happy that we stopped. But we had 52 days of thunder and lightning like they’d never seen before. It was fast, fierce, decisive, and an extremely successful use of military force. Not that we wanted it, but they were hitting ships. They were firing at you. They were firing at Saudi Arabia. We were not.” The prospects for further development of the YC remain unpredictable. The linkage of YC with the PIC remains in effect. YC has transitioned into a format of direct confrontation between SA and Israel. A new war front was opened by Israel's attack on Iran on January 13, 2025, and the twelve-day war that followed — ending with a U.S. strike on Iran’s nuclear facilities and Iran’s retaliatory strike on a U.S. Air Force base in Qatar — sparked Sana’a’s willingness to support Iran while continuing to tie YC to the situation in Gaza and maintain the blockade of Israeli shipping through the Bab-el-Mandeb Strait. Russia’s position throughout all phases of the second stage of the military phase was consistently focused on political resolution of YC. On May 14, 2025, Russia’s Permanent Representative to the UN, V.A. Nebenzya, stated that during the nearly two-month confrontation between the U.S. and the Houthis, the death toll had exceeded 200 people, with several hundred more injured. Strikes were carried out almost nightly on the territory of sovereign Yemen, targeting not only military but also civilian infrastructure, with no result — neither the suppression of Ansar Allah’s military capabilities nor their abandonment of their course of action. Welcoming the cessation of U.S. attacks on Yemen, the Russian envoy remarked: “Better late than never, as the saying goes. It seems that Washington has finally acknowledged the futility of the military approach, something we have pointed out repeatedly… This could have been a first step toward general de-escalation around Yemen. But unfortunately, it is not yet the case, because Israel has now begun relay-style bombardments of Yemen.” The U.S.-UK coalition’s military campaign in Yemen bore all the hallmarks of a large-scale neocolonial military adventure. It immediately took the form of a demonstration of military superiority, hardly differing in method or tactics from earlier AC operations, when nearly 250,000 strikes were launched on Yemen from March 2015 to April 2022. The USUKMC's failures to organize a ground operation — necessary for military victory — also echoed past lessons. The AC’s refusal to participate in favor of maintaining the de-escalation regime, and the conditional agreement by Yemeni CPIs in the MPP to join only if supplied with U.S. arms (thus endangering their patrons from the AC), yielded no results. Moreover, the Palestinian backdrop of the new phase raised the risk that all of the accumulated military power of SA’s enemies might eventually pivot against Israel’s allies. The second stage of the geopolitical phase of the crisis cannot be considered fully complete, yet it may transform into a third one if Israel attempts to seize the initiative. * Organization designated as terrorist and banned in the Russian Federation.References:Bokov T.A. The Yemeni Houthi Movement: Causes of Origin, Formation and Development. Dissertation abstract. St. Petersburg, 2023. P. 162.In January 2021, outgoing president D. Trump designated the Houthis as an international terrorist group, which was reversed by incoming president J. Biden in February. In January 2024, the group was re-designated, and Trump began his new term in January 2025 by raising the threat level of the Houthis to a “Foreign Terrorist Organization” (FTO).The Huthi Movement in Yemen: Ideology, Ambition and Security in the Arab Gulf / Abdullah Hamidaddin. London: I.B. Tauris, 2022.The book’s editor was Dr. Abdullah Hamidaddin, Assistant Secretary General of the Center. Contributors included B. Haykel (Princeton), M. Brandt (ISA, Austria), E. Ardemagni (ISPI, Italy), among others.The same article served as the legal reference for launching the AC’s “Decisive Storm” operation in March 2015.United Nations S/2024/90 Security Council Distr.: General 22 January 2024 — Letter dated 22 January 2024 from the Permanent Representative of the Russian Federation to the United Nations addressed to the President of the Security Council.MQ-9 Reaper — remotely piloted UAV, medium-altitude and long-endurance. Primarily used for reconnaissance, surveillance, targeting, and strikes.

Abstract Recent changes in US foreign policy and strategic posture have forced Europe to think about meeting its security needs without US support. One issue that requires a particular focus is the question of how to deter and defend against Russia in a conventional war. This article attempts a high-level assessment of European military capability and considers whether existing military doctrine is adequate. It argues that Europe should maintain its focus on NATO’s manoeuvrist mode of war fighting and identifies key capability gaps that need to be filled for (a) a coalition of the willing and (b) Europe as a whole to be able to fight in this way. It cautions against an unduly defensive, attritional method of fighting, based on conscript armies, as playing to Russia’s strengths instead of our own. Introduction War has come back to Europe and so has the need to think about how to fight it. Between 24 February 2022 and 21 January 2024, we put the need to rethink our defence to one side, because the Biden administration allowed us the luxury of being able to repurpose Cold War institutions (most obviously NATO), deterrence and habits to support Ukraine and dissuade Russia from another overt attack. This was a mixed blessing, because while it saved us the need to put our societies and economies on a war footing, it also blinded us to the need to build something new. The old system was not the best to contend with Russia’s aggression. While the US had only half an eye on Europe—with the rest of its focus on China—Western Europeans continued to free-ride on American resources. Neither Germany’s Zeitenwende, nor the aspersion cast by Emanuel Macron that ‘NATO is brain-dead’ (Macron 2019) translated into larger defence budgets, increased orders for ammunition, the conversion of civilian manufacturing to military use or the running of plants in shifts to replenish stockpiles. Only the Nordics, Baltics and Poland really moved to a war footing, and even their restructuring suffered from a desire, exposed as wishful thinking by Trump’s victory in November 2024, to keep the US involved. Now, with the US being led by an unstable pro-Russian Donald Trump and an anti-European JD Vance, the choice has been made for us. Steps are already being taken to prepare Europe’s industrial base, whether it is the creation of a European defence commissioner, Germany’s removal of its debt brake or initiatives such as the EU’s proposed Security Action for Europe (SAFE) financing instrument. But our political elite also needs to educate itself beyond these industrial and economic matters. War has once again become an essential part of what every responsible political leader needs to know. As it had been until 1945, if not 1989, some understanding of the military arts has, unfortunately, again become indispensable for European statespeople. This article will start by outlining certain concepts to help inform our debate about how we defend ourselves against Russia. It will relate them to the state of our military equipment, and pose questions about how we should fight with what we have, and how we should make more of what we need to fight in the way that gives us the maximum advantage over Russia. It will ask what elements of the existing NATO way of war should be kept, and which ought to be replaced, as a new European way of war—a European ‘doctrine’—is developed. And it will identify the key gaps in capability that need to be filled to apply such a doctrine in two scenarios: one where most of Europe confronts Russia (excluding neutrals, such as Ireland or Austria; potentially hostile states, such as Hungary and Slovakia; and Greece and Turkey, which deploy military resources to deter a conflict between themselves), and another where the burden is taken up by a coalition of the willing. This coalition is drawn up narrowly to constitute the Nordic–Baltic Eight (NB8),1 the UK, Poland and Ukraine. Other countries, for example, Czechia and the Netherlands, would currently be considered part of this coalition, but their contributions have, conservatively, been excluded for the purpose of this assessment. This article does not assume that the European military effort should replicate the American one (for the cost of replication, see Wolff 2025). Instead it seeks to assess how Europe would deter and defeat Russia in ways that exploit our advantages against the Russian military. We do not need to replace the Americans one-for-one, but nor should we replicate Russia’s relatively low-technology and low-skill warfare. That would be to give up the strongest advantages our free and technologically advanced societies provide. Centre of gravity The first concept we need to outline is the ‘centre of gravity’: the phrase, whose application to war we owe to Clausewitz (1918, 270), refers to that feature of a belligerent that will cause it to change its behaviour when subject to pressure. The aim of military strategy, he argued, was not necessarily the destruction of the enemy’s forces, still less their population, but the application of force to their centre of gravity in order to achieve your war aim. With this in view, the most important question for European military planners is, where is Putin’s, or Russia’s, centre of gravity? This question will occupy our strategists’ minds for the foreseeable future: its answer includes determining whether it is Putin, or some other group in the Russian elite, such as the military, energy producers or business oligarchs, on whom pressure should be applied, and if so what pressure is required. Under what conditions would Putin sue for peace, or be replaced by someone who would, if Russia extended its war to conventional military aggression against Europe? Only once these conditions have been identified, is it then relevant to ask how they might be brought about. This consideration of centre of gravity begs an important question: how is Russia to be deterred from attacking Europe? How can sufficiently severe consequences be imposed on Russia, bearing in mind that the loss of almost 400 aircraft (Minfin.com.ua 2025) and several thousand tanks, and close to a million men killed and wounded have not been enough to push Putin to retreat from Ukraine? It is, however, necessary to pose this question, because there is a temptation to avoid it by focusing on ‘deterrence by denial’. This idea would be to defend ourselves in the manner in which the Chinese are thought to defend themselves against the US: by preventing US forces from landing in China by attacking its large, expensive ships. This does not apply to the Russian case for two reasons: first, Russia is willing to sacrifice men and equipment in human-wave assaults; the only equipment it seems to have decided to preserve is its air force. Second, Russia has a land border with Europe, so it does not need to attack using small numbers of vulnerable ships. Denial is extremely difficult against human-wave attacks, as US forces found in Korea, and Iraqis found in the Iran–Iraq war when revolutionary Iran employed them. (See Meyer zum Felde 2024 for a deterrence by denial–focused approach.) Order of battle A second concept is the ‘order of battle’: what are the forces arranged on either side of a conflict and how do they measure up to each other? As well as military units, it is worthwhile also considering the broader elements of societal strength—economic, political and cultural—that each side has, and how these contribute to the war effort. For example, our open societies leave us more vulnerable to hybrid attacks and disinformation, but on the other hand supply great strength and flexibility. Democratic societies do not wait for the government to tell them what to do, but organise social defence in ways that dictatorships find more difficult; the market economy possesses enormous flexibility that centrally planned systems do not; and an entrepreneurial can-do culture can also produce superior military performance through the concept of ‘mission command’ (see below). But the first question is who would be fighting? Sometimes pieces are written as if it would only be Britain and France confronting Russia (Barker et al. 2025), but borders have shifted since the Cold War: Eastern Europe, including the highly capable Polish and Finnish militaries, as well, of course, as Europe’s strongest army, Ukraine’s, would be arrayed against Moscow, not operating under its orders. Europe’s total military-age population is considerably greater than Russia’s. If Austria, Hungary, Ireland and Slovakia are excluded for political reasons, and Greece and Turkey as well, because they will wish to preserve resources in case a conflict breaks out between them, ‘Europe’ has 89.5 million military-age men and 88 million military-age women, compared to Russia’s 31 million military-age men and 33 million military-age women.2 The question of how such forces are recruited and generated, particularly in the economically more successful parts of Europe, is of course relevant, but the sheer capacity to provide sufficient personnel is not in doubt. It is useful to consider the matter of mobilisation. Russia was in transition from a conscript to a professional army when it launched its attack on Ukraine. It still mobilises 160,000 men per year, mostly to fill rearguard positions and free up front-line deployment for professional troops. This is equivalent to 17% of the annual cohort of young men.3 Europe (as defined above) could generate similar forces without much difficulty. A one-year cohort of the European population includes 2.7 million men and 2.5 million women. Even if it limited itself to calling up men, it would only need to recruit 6% of the population. Such a number would be feasible with a voluntary reserve service programme, and would not require universal conscription. Considering the countries most at risk of Russian aggression, and most likely to need to defend against it, presents a starker picture. The NB8 plus Poland and the UK between them have an annual cohort of 7.7 million men and 7.3 million women. If the male population of these countries took part in military service at the same rate as Russians, this would generate 130,000 personnel, requiring an additional 30,000 female personnel to match Russian numbers. This would require a female reserve participation rate of 4%, which is an achievable figure. For example, at least 25% of Norway’s annual conscription quota comprises women. Despite a recent surge in calls to reintroduce universal military service in Europe, this is not necessarily advisable in all countries. Training a large cohort of conscripts takes resources away from exercises and advanced training for professional officers. While it may be justified for small nations on the front line, it is not the best use of resources for larger countries. The required manpower needs can in most cases be met by a selective reserve system. European stocks of platforms (as distinct from ammunition stocks, which are dangerously low) are also not outrageously out of balance with the requirement for a mission against Russia, though this is partly due to Ukraine’s destruction of Russian equipment since 2022. The following (table 1) compares stocks of fighter jets, main battle tanks and artillery pieces across several groups of European countries (some including Ukraine) versus Russia. This analysis is necessarily somewhat crude, as it excludes infantry fighting vehicles, mortars and other equipment. It also completely sets aside analysis of naval forces. Its fighter aircraft figures comprise fourth-generation fighters, old fighters (predating the fourth generation or the Warsaw Pact) and F35s.4 Finally, these figures do not take future production (either European or Russian) or the evolution of land and air drones into account (International Institute for Strategic Studies 2024).   Source: International Institute for Strategic Studies (2024). Note: This table compares the main platforms (fighter jets, main battle tanks and artillery pieces, including rocket artillery) that various European countries have at their disposal. Countries are placed in different categories and then compared against Russia. Each category also appears in two variants: one including Ukraine, and one that does not include Ukrainian forces. The ‘NB8+ coalition’ is the NB8 plus the UK and Poland. Non-neutral Europe means EU members plus the UK and Norway, but minus Ireland, Austria, Hungary and Slovakia. Using this table one can see, for example, that the NB8+ coalition has 542 fewer fighter jets at its disposal than Russia but essentially the same number of main battle tanks. With the exception of the scenario in which only the NB8+ coalition and Ukraine face off against Russia, Europe currently has approximately the required numbers of platforms to resist a Russian attack (bearing in mind a deficit in artillery pieces if Ukraine is not included). This leads to the following conclusions: • Ukraine needs to be considered an integral part of European defence against Russia, and its defeat would allow Russia to focus its forces on EU territory.• The coalition faces a notable air-power shortage in confronting Russia. While it has enough planes to deter Russian use of its aerospace, it does not have sufficient equipment to attempt to establish air superiority.• At an overall European level the priority should not be buying new platforms. Platform acquisition should be part of any rearmament plan, but priorities should be determined by the specific needs of a campaign against Russia, with importance given to filling the key gaps needed to conduct such a campaign. Platforms, ammunition and network-centric warfare The analysis above is only a first approximation of military strength. It considers only equipment and mobilisation potential, rather than force generation, and concentrates on land and air forces, setting aside the navy because a Euro-Russian conventional war would largely be fought on land. (The air force calculations do include naval aviation equipment, however, as these could be brought to bear). It also deals only with the main ‘platforms’: main battle tanks, fighter planes and artillery pieces, ignoring armoured personnel carriers and infantry fighting vehicles, engineering and support equipment, and, most importantly, ammunition. Simply replicating Russian numbers of platforms without considering communications, software and unmanned systems risks equipping ourselves to fight the last war (Tallis 2025). The spectrum that runs between a platform, which serves to move weapons systems into a place where they can be fired, and a piece of ammunition, fired from a platform, is another dimension of analysis. For example, during the Second World War the distinction was clear: an artillery shell was ammunition; an artillery piece a platform. But how should one categorise a cruise missile, which could be launched from a plane (so it appears to be ammunition launched from a platform), or directly from land, in which case it could arguably be a platform on its own? What is the difference between a cruise missile and a long-range drone? The war in Ukraine has seen the rapid development of short-range single-use drones that behave, in some ways, like super-intelligent artillery shells; and actual shells have incorporated guidance systems, and even propulsion systems, so that they have become what are known as ‘loitering munitions’. The point here is that strength is not just measured by platforms, but by the things that can be delivered to the battlefield with them (or independently of them), and an assessment of military strength needs to include an understanding of stocks of ammunition, the ability to replenish it and to fire it at where it is needed. This brings us to the idea of networks. War has always given the advantage to the side that could bring force to bear in a coordinated fashion while itself avoiding being the target of a coordinated enemy attack. The latest iteration of this is known as ‘network-centric warfare’, which, in its ideal form, means that every participant in the battle, from planes and ships all the way down to individual soldiers and drones can observe the ‘battlespace’ and communicate information about it to the right layer of command. Using this information, commanders, assisted by artificial intelligence, can decide where ‘effect’ is to be concentrated to bring about maximum damage to the enemy, more quickly than it can cause damage. This capability is not necessarily confined to the most expensive high-tech armies. Ukraine has shown how off-the-shelf electronic components can be added to existing systems to improve them (for example, to allow its artillery to concentrate fire on a single target despite the artillery systems themselves being dispersed). Precision If in the popular imagination precision weapons are used mainly to reduce collateral damage (and this was indeed their main use during the campaigns against terrorist groups in the first two decades of this century), in high-intensity war their advantage is that they conserve resources and time. Even if an individual precision artillery shell is more expensive, it is more useful to be able to use one or two guided shells to hit a target than 30 or 40 unguided ones. Not only is less ammunition used, but fewer troops are needed to operate it, and the wear and tear on the artillery pieces is considerably less. Precision results in greater ‘effect’ from the inputs to the process. Though sometimes presented as its opposite, precision should be understood as a way of delivering ‘mass’; this concept, also from Clausewitz (1918, 98), refers to the quantity of force that can be brought to bear against an enemy at a particular time. It matters because fighting is not a continuous linear process where the amount of force one applies has an effect in proportion to its quantity—in war having more power at one place at the right time means you will win the battle and the enemy will be weaker for the next one. The slightly stronger force can often inflict damage on the weaker one in a way that is disproportionate to the difference in their strength. To take a simple example for the purposes of illustration, suppose we start with 100 tanks, and so do they. Thanks to our commander’s skill we are able to concentrate 50 of our tanks against 40 of theirs. We lose 10 tanks, they lose 35. Now we have 90 tanks, they have 65. In this example our ability to get those extra 10 tanks in the right place has given us an advantage that can be pressed further in the next battle. It is these facts that underpin the approach that NATO, and the West more broadly, has applied to fighting. Although Western democracies have been able, due to their superior economic systems and technological advantage, to outproduce their enemies, winning a war of attrition is not where they consider their advantage to come from. Instead they emphasise their speed of movement and thought, and their ability to confuse their enemies, tricking them into dividing or misdirecting their forces, and then pouncing at the right moment; this is the ‘manoeuvrist’ creed of war, in which we fight smart and overcome the enemy by more than brute force. It is important not to draw the distinction between attrition and manoeuvre too crudely. Manoeuvre warfare is easier when you have more and better kit, and your leaders are informed by better intelligence obtained through technological as well as human sources. It also takes advantage of the characteristics of free societies. Manoeuvre warfare is strengthened by ‘mission command’: the notion that subordinate officers are given the ability to decide exactly how to fulfil their orders. This gives Western militaries a flexibility that is absent from the armies of dictatorships, in which such freedom is rarely granted,5 but of course this depends on officers and soldiers being sufficiently well-trained, and possessing a good enough level of general education, to operate independently. It is the best way for us, as free and well-educated peoples, to fight—it is not necessarily the best for everyone. A manoeuvrist force, is, as the name suggests, on the move. It is constantly advancing, communicating its changing position, attempting to bypass and confuse the enemy. It operates at a high tempo in order to overwhelm the enemy mentally as well as physically, and the ability to sustain this type of fighting informs training, equipment command and intelligence: ‘the key to winning battles is to have greater forces at the key location than does the enemy. The trick is to outwit the enemy and thus out-concentrate him at the right time’ (Warden 1998, 79). This matters for learning the right lessons from Ukraine’s fight for survival. Ukraine has only been able to master some of the lessons of manoeuvrist warfare. It has been hampered by its limited capacity in the air, which slows it down and makes it hard to break Russian lines except with artillery and long-range fire (such as the famous HIMARS rockets). It is in transition from Soviet- to Western-style command. But it has also shown tremendous capacity to innovate, particularly in its use of drones to hold a defensive line. Ukraine’s tremendous first-person drone capacity allows it to stop Russian attacks while risking far fewer troops (drone operators work behind the lines, where they are at much lower risk than the men in the trenches) and even compensate for artillery.6 These principles feed into NATO’s existing doctrine (NATO 2022), which involves identifying the enemy’s centre of gravity, achieving air superiority to deliver firepower against its command and control nodes, and then overcoming its disoriented forces at speed. It relies on synthesising intelligence through networks of sensors and exploiting the information they provide to deploy massed precision against them. Such operations, however, require certain capabilities that depend on equipment and structures provided mostly by the US. The first of these is NATO’s command structure. NATO’s armies have a single command structure that conducts exercises together. At the top is the Supreme Allied Commander (American) and the Deputy Supreme Allied Commander (European). American units are integrated throughout the force structure. European forces will need to plan, exercise and be ready to fight without these American elements—it is not merely a matter of detaching them. The second is the intelligence and planning capability to carry out those war plans and adapt to the evolving battle. These integrate intelligence gathered from sensors, satellites and human sources, and artificial intelligence is increasingly involved in its processing as extremely large amounts of data must be handled quickly and secretly. As well as certain sensors (satellites and aircraft), the US’s processing software is also vital here, though Europeans have equivalent capabilities at reduced scale. Third are the sensors, software and missiles needed to suppress enemy air defences (SEAD). SEAD missions are a prerequisite for establishing air superiority against adversaries that possess sophisticated air defence systems, such as Russia. Indeed, the failure of Russia’s SEAD missions in Ukraine, and Ukraine’s ability to deter Russian aviation, may also indicate that an effective air defence is easier to mount than had been thought.7 Europe, however, currently lacks the ability to make the latest generation of anti-radiation missiles (which target enemy radar) essential to the success of SEAD. India’s poor performance against Pakistan, where it appears to have attempted to conduct deep strikes against its rival without conducting SEAD, underlines the importance of these capabilities (Economist 2025). It will take some years to develop them, and this needs to be prioritised. A full discussion of the requirements for successful SEAD against Russia can be found in Bronk and Watling (2025). Finally there is the question of Russia’s nuclear threats. Though the UK and France possess ‘strategic’ nuclear arsenals, these, because they threaten the complete destruction of the world, can only credibly deter the most extreme sort of attack. Russia and the US both have low-yield or ‘tactical’ nuclear weapons, and Russia has regularly threatened to use them. These threats would significantly complicate elements of a European campaign to deter Russia, which might involve actions such as seizing Kaliningrad or advancing from Finland towards the environs of St Petersburg. Europe needs the ability to restrict Russia to conventional weapons in such circumstances. Though such deterrence does not have to be supplied using tactical nuclear weapons of our own (Hoffmann 2021), these would be the most straightforward instrument for this purpose. As the UK’s nuclear weapons systems are submarine launched (and use American missiles), France’s arsenal would have to be expanded to provide this capability, and be able to be deployed closer to the front as, for example, Donald Tusk has hinted.8 Conclusion and recommendations Fighting without the Americans does not necessarily mean we need to replace exactly what they used to supply. Instead we need to understand the mission required, which is to deter Russia by credibly showing how Russian forces would be defeated, in the field, should Putin attempt to attack us. In an ideal world this credible threat would cause the military to remove Putin should he attempt further adventurism against Europe, but we cannot rely on such an eventuality. This means that we have to think carefully about how we would fight and sustain political support for a major European war. The good news is that provided that the bulk of Europe is willing to contribute, we have the resources and equipment needed to defeat Russia. Upgrades, in particular in SEAD capability and tactical nuclear weapons, need to be made, but they are not out of reach. In addition, we have a solid basis in military doctrine that can be used to organise a campaign that takes advantage of our military cultures and technological lead. The less good news is that the countries that can be guaranteed to make up a ‘coalition of the willing’ (the NB8 plus Poland, the UK and Ukraine) would currently struggle to mount an offensive campaign on their own. They would, in particular, struggle to field a sufficiently large air force to win air superiority over Russia, though they have enough aircraft to deny Russia air superiority of its own. This would limit their ability to put manoeuvrist doctrine into practice, and, notwithstanding advances in drone warfare pioneered by the Ukrainians, could cause them to fall back to static defence and attritional warfare, as illustrated by the proposed Baltic Defence Line. Such an approach would stretch the human resources of a coalition of the willing extremely thin. It is perhaps ironic that Europe as a whole could win a war of attrition against Russia, but it also would not have to, as it could prosecute a campaign of manoeuvre against the Russian military and Putin’s state. Accordingly my recommendations are laid out below. Europe should focus on what it needs to defeat Russia, rather than what would be required to replace the American commitment to NATO. Nevertheless, it should not, as a whole, revert to using conscript-based armies designed to fight a war of attrition against Russia. These give up the greatest advantages of technologically advanced free societies and would leave us fighting the kind of war Russia would want us to fight. Certain small front-line states might need to make different calculations. Universal military service might be required so that they can, in extremis, mount a defensive campaign—for example, if Finland and the Baltic states were required to fight on their own without support from European allies. This highly extreme scenario is sufficiently unlikely that it should not form the basis of other countries’ military planning. The core ‘coalition of the willing’—the Nordic countries, the Baltic states, plus Poland, the UK and Ukraine—could defend themselves against Russia, and with some effort would be able to conduct an offensive campaign to bring about Russian defeat. They would need, however, to make important improvements to their defence. The coalition would require an integrated command structure and a programme of exercises. The expansion of the UK-led Joint Expeditionary Force and the UK’s command headquarters would be a suitable nucleus for such capability. The coalition would face a manpower deficit compared to Russia, and matching Russian mobilised reserve levels would be a challenge. The coalition could, however, match Russian mobilisation levels with a Swedish- or Norwegian-style selective military service programme for young men and women (it could achieve sufficient coverage for defensive purposes by recruiting 16% of men and 6% of women each year). The coalition is also severely short of aircraft with which to pursue an air superiority campaign against Russia. Though it would fare better than Ukraine on its own, increasing the size of the coalition’s air forces must be a priority, and the risk of over-dependence on the F35 needs to be considered. Though ‘kill switches’ are a myth, a sovereign spare parts supply chain (as Finland is creating) and sovereign intelligence software (as used by Israel) are required to reduce the risk of US unreliability. The coalition would also need to consider replacing the F35’s intelligence and command capabilities with replacements that could operate on European aircraft, such as the Gripen or Rafale. The lack of stealth capability would also hamper the coalition’s air forces until a sixth-generation fighter could be developed. Europe as a whole has forces of the necessary scale to conduct operations against Russia. Its shortfalls in ammunition production and inefficiencies due to the diversity of its equipment have been covered elsewhere. Some inefficiency is likely to persist as long as Europe remains a relatively decentralised continent, but it is likely to be better to bear the extra cost now, than waste time with the ambitious political integration projects required to eliminate it quickly. Europe as a whole would need to develop its own command structure. At this level it may be possible to repurpose NATO’s Supreme Headquarters Allied Powers Europe (SHAPE) using the Berlin Plus process, though care would need to be taken to avoid a potentially hostile US, as well as unfriendly NATO members, such as Hungary, blocking operations. As urgent as ammunition production (a category that includes missiles as well as artillery) is the manufacture of equipment to conduct SEAD campaigns. Reviving European capacity to produce anti-radiation missiles and in intelligence capability to uncover targets for them should be a matter of the highest priority. The final priority area is the expansion of Europe’s tactical nuclear capability. Though the French and British strategic arsenals can provide the ultimate deterrence against Russia, tactical, or low-yield, weapons are needed to deter Russia from threatening European forces with its tactical nuclear weapons. As the British programme is not suitable, these would have to be based on the French programme, and questions related to how this expansion would be paid for, and how tactical nuclear use would be authorised, would need to be addressed. Footnotes1. Iceland, Norway, Sweden, Denmark, Finland, Estonia, Lithuania and Latvia.2. These estimates are based on Eurostat data for the EU member states, the Office for National Statistics population projections for the UK and the most recent available data for Russia, which is based on UN data not currently available but which have been reported on Wikipedia. The Russian data are from 2012, so these overestimate Russian demographic strength slightly. The military age calculation aggregates the standard five-year demographic groups between 20 and 49. Obviously a military may mobilise younger and older people as well, but the comparison remains valid.3. In this case, by taking the 10-year sample of 15–24-year-olds and dividing it by 10 to smooth out fluctuations. Again, because of declining Russian demographics (even without accounting for losses due to the war), this is likely to be an underestimate of the proportion mobilised (because the total number of 18-year-old men is lower than the statistics indicate).4. F35s are easily the most advanced fighter available, and the only one reliably able to penetrate Russian air defences before suppression of enemy air defence missions have been accomplished. The deterioration in relations with the US, however, poses questions about the ongoing reliability of the supply chain associated with them. Though ‘kill-switches’ are a myth, European countries will need to maintain their own spare parts supply and software upgrade path if they are to gain the most out of the aircraft in the long run. Finland, for example, is establishing its own sovereign spare parts supply, and Israel has a sovereign software intelligence solution on its F35s.5. An exception was the Wehrmacht, which inherited mission command from the Prussian Army; however, its generals found themselves micromanaged by Hitler, which (fortunately) affected their performance.6. These small drones are very different from those deployed in the early stages of the war such as the Bayraktar TB2 or Western drones such as the Reaper. They are much closer to ammunition than platforms, and (in good weather, at least) replace artillery or close air support.7. It could also indicate that Russian aviation is not as good as had been thought, but it would be dangerous to plan on that assumption.8. Author’s conversation with a Polish official who wished to remain anonymous.ReferencesBarker K., Smialek J., Erlanger S. (2025). Europe prepares to face Russia as Trump’s America steps back. New York Times, 24 February.Bronk J., Watling J. (2025). Rebalancing joint fires to deter Russia. Royal United Services Institute Occasional Paper. London, 15 April. https://static.rusi.org/rebalancing-european-joint-fires-to-deter-russia.pdf. Accessed 15 April 2025.Clausewitz K. von. (1918). On War. Trans. Graham J. J. (London: K. Paul Trench, Trubner & Co.)Dalaaker A. (2017). Statement by Norway on gender equality in the military – universal conscription. Organisation for Co-operation and Security in Europe. 8 March. https://www.osce.org/files/f/documents/b/9/304861.pdf. Accessed 9 April 2025.Economist. (2025). Chinese weapons gave Pakistan a new edge against India. 15 May. https://www.economist.com/asia/2025/05/15/chinese-weapons-gave-pakistan-a-new-edge-against-india. Accessed 16 May 2025.Hackett M., Nagl J. (2024). A long hard year. Russia–Ukraine war lessons learned 2023. Parameters, 54(3), 41–52.Hoffmann F. (2021). Strategic non-nuclear weapons and strategic stability – promoting trust through technical understanding. Fondation pour la recherche strategique. https://frstrategie.org/sites/default/files/documents/programmes/Programme TNP - P5/2021/202103.pdf. Accessed 9 April 2025.International Institute for Strategic Studies. (2024). The military balance. London: Routledge.Meyer zum Felde R. (2024). Kann sich Europa konventionell gegen eine militärische Bedrohung durch Russland behaupten? Sirius, 8(3), 267–83.Minfin.com.ua. (2025). Casualties of the Russian troops in Ukraine. Updated daily. https://index.minfin.com.ua/en/russian-invading/casualties/. Accessed 5 March 2025.Nagl J., Crombe K. (2024). A call to action: Lessons from Ukraine for the future force. Carlisle, PA: US Army War College Press.NATO. (2022). Allied joint doctrine. December. https://www.gov.uk/government/collections/allied-joint-publication-ajp. Accessed 9 April 2025.Tallis B. (2025). Emerging defence: Offset and competitive strategies for Europe. Democratic Strategy Initiative. https://www.democratic-strategy.net/_files/ugd/dcfff6_ca54854b6dc7499e829a5fa4d7b01b74.pdf. Accessed 16 March 2025.Warden J. (1998). The air campaign: Planning for combat. Washington, DC: National Defence University Press.Wolff G., Burlikov A. (2025). Defending Europe without the US: First estimates of what is needed. Bruegel, 21 February. https://www.bruegel.org/analysis/defending-europe-without-us-first-estimates-what-needed. Accessed 9 April 2025.

In Latin America, Cuba, Nicaragua, and Venezuela are not alone in their support for Russia and its invasion of Ukraine. In many cases, support has been disguised as an interest in peace or a neutral stance towards the conflict, as seen in the cases of Colombia, Mexico, and Brazil. While we find manifold diplomatic approaches toward Russia and Ukraine in Latin America, the underlying motivations can be understood in terms of support or rejection. While a majority of nations reject the invasion, considering it a threat to territorial sovereignty and self-determination, others have been reluctant to place any blame on Russia. More broadly, there has been less of an ideological bloc and more of an anti-imperialist or anti-colonial sentiment, with a few exceptions, such as Gabrie Boric from Chile who has publicly repudiated Russia’s aggression against Ukraine. His opposition is a departure from other Latin American leftist leaders like Luiz Inácio Lula da Silva and Gustavo Francisco Petro who have been more critical of Volodymyr Zelensky than Vladimir Putin. However, we can still identify three distinctive approaches to the crisis: 1) geopolitical, 2) economic, and 3) historical. The region has a keen interest in keeping its doors open to Russia. BRICS members like Brazil have managed to maintain their alleged neutrality in the pursuit of peace—even as President Lula has explicitly supported  Putin—while simultaneously protecting their economic interests. Others like Colombia and Mexico have shielded their unwillingness to condemn Putin’s invasion of Ukraine in an apparent push for peace. On the economic front, attitudes towards Russia are more tenuous given that Russia’s capability for foreign direct investment has been significantly reduced by the brunt of the war, along with the impact of the economic sanctions that followed their aggression. To be sure, Russia’s investments in the region have been winding down for some time, with a decreasing profile in areas such as energy, oil, and gas, as well as software and IT. However, the economic ties are more significant in the cases of Cuba, Nicaragua, and Venezuela—where they are joined more by their subjection to economic sanctions, and therefore the necessity to evade the consequences of economic isolation. There are specific areas key to this alliance: Russian fertilisers, along with oil and diesel, are critical to bypassing Western sanctions. Meanwhile, historical ties are more consequential than is commonly understood. Misinterpretations of Russia’s Soviet past by leftist-governed Latin American countries and longstanding social and cultural commonalities partially explain the continued support from diverse leaders such as Lula and Jair Bolsonaro in Brazil. These ties, rooted in shared anti-colonial sentiments and cultivated over decades, and regardless of ideological shifts, illustrate Russia’s multifaceted regional influence. This context underscores the fact that Russia’s regional impact transcends ideological lines, with both left and right-wing governments either explicitly supporting Russia or criticising Ukraine’s NATO aspirations to justify Russia’s aggression. The return of Donald Trump to the White House has prominent leaders of the Latin American left aligning with the new administration, resulting in significant consequences for the region. The new US administration’s criticism of Kyiv resonates with positions held by Brazil, Mexico, Colombia, Cuba, and Nicaragua. Despite ideological differences, their alignment emerges from a mix of political affinities, geopolitical strategies, and historical connections. Putin’s explicit defiance of Donald Trump’s negotiation efforts raises questions about Latin America’s influence over the conflict, largely due to its initial reluctance to adopt a decisive stance against Putin. The lonely voice condemning Putin’s war of attrition continues to be Chilean President Gabriel Boric, in stark contrast to Lula DaSilva and Gustavo Petro, who remain in Putin’s corner, making it unlikely they can be viewed as honest brokers in a peace initiative. Trump’s policies have prompted Brazil and Colombia to voice limited concerns about US plans for Ukraine, although still refraining from outright condemnation of Russia. This stance appears less a genuine support for Ukraine and more an opposition to US involvement in peace processes, even blaming Ukraine as partially responsible. Meanwhile, ideology alone has proven insufficient to prompt unified condemnation of Russia or widespread support for Ukraine in Latin America. Previous efforts by the Biden administration to secure regional military assistance for Ukraine were met with firm rejection and reluctance. This distancing, interpreted as tacit support for Russia, contributes to concerns about increasing authoritarian tendencies in the region, reflecting a diminished commitment to emerging democracies in crisis. Effectively abandoned by the international community, Ukraine faces negotiations with nations seeking its valuable earth minerals in exchange for protection, essentially framing it within a debt relief context. The absence of significant Latin American critique of this neocolonial approach underscores a troubling shift where sovereignty and self-determination appear increasingly disposable, contingent upon geopolitical interests and contexts. Maria I. Puerta Riera is a Visiting Professor of Political Science at Valencia College in Orlando, FL., where she teaches U.S. Government and International Politics. She holds a PhD. in Social Sciences, with her research focusing on the crises of democracies in Latin America. She has a special interest in Venezuela, Cuba, and Nicaragua, and is currently working on the effects of the illiberal regimes of China and Russia and their use of sharp power in the region. This article is published under a Creative Commons License and may be republished with attribution.

Abstract We examine the roles of Gold and Bitcoin as a hedge, a safe haven, and a diversifier against the coronavirus disease 2019 (COVID-19) pandemic and the Ukraine War. Using a rolling window estimation of the dynamic conditional correlation (DCC)-based regression, we present a novel approach to examine the time-varying safe haven, hedge, and diversifier properties of Gold and Bitcoin for equities portfolios. This article uses daily returns of Gold, Bitcoin, S&P500, CAC 40, and NSE 50 from January 3, 2018, to October 15, 2022. Our results show that Gold is a better safe haven than the two, while Bitcoin exhibits weak properties as safe haven. Bitcoin can, however, be used as a diversifier and hedge. This study offers policy suggestions to investors to diversify their holdings during uncertain times. Introduction Financial markets and the diversity of financial products have risen in both volume and value, creating financial risk and establishing the demand for a safe haven for investors. The global financial markets have faced several blows in recent years. From the Global Financial Crisis (GFC) to the outbreak of the pandemic and uncertainty regarding economic policy measures of governments and central banks, the financial markets including equity markets around the world were faced with severe meltdowns. This similar behavior was observed in other markets including equity and commodity markets, resulting in overall uncertainty. In this scenario, the investors normally flock toward the safe-haven assets to protect their investment. In normal situations, investors seek to diversify or hedge their assets to protect their portfolios. However, the financial markets are negatively impacted when there are global uncertainties. Diversification and hedging methods fail to safeguard investors’ portfolios during instability because almost all sectors and assets are negatively affected (Hasan et al., 2021). As a result, investors typically look for safe-haven investments to safeguard their portfolios under extreme conditions (Ceylan, 2022). Baur and Lucey (2010) provide the following definitions of hedge, diversifier, and safe haven: Hedge: An asset that, on average, has no correlation or a negative correlation with another asset or portfolio. On average, a strict hedge has a (strictly) negative correlation with another asset or portfolio.Diversifier: An asset that, on average, has a positive correlation (but not perfect correlation) with another asset or portfolio. Safe haven: This is the asset that in times of market stress or volatility becomes uncorrelated or negatively associated with other assets or a portfolio. As was previously indicated, the significant market turbulence caused by a sharp decline in consumer spending, coupled with insufficient hedging opportunities, was a common feature of all markets during these times (Yousaf et al., 2022). Nakamoto (2008) suggested a remedy by introducing Bitcoin, a “digital currency,” as an alternative to traditional fiduciary currencies (Paule-Vianez et al., 2020). Bitcoin often described as “Digital Gold” has shown greater resilience during periods of crises and has highlighted the potential safe haven and hedging property against uncertainties (Mokni, 2021). According to Dyhrberg (2016), the GFC has eased the emergence of Bitcoin thereby strengthening its popularity. Bouri et al. (2017) in their study indicate that Bitcoin has been viewed as a shelter from global uncertainties caused by conventional banking and economic systems. Recent research has found that Bitcoin is a weak safe haven, particularly in periods of market uncertainty like the coronavirus disease 2019 (COVID-19) crisis (Conlon & McGee, 2020; Nagy & Benedek, 2021; Shahzad et al., 2019; Syuhada et al., 2022). In contrast to these findings, a study by Yan et al. (2022) indicates that it can function as a strong safe haven in favorable economic times and with low-risk aversion. Ustaoglu (2022) also supports the strong safe-haven characteristic of Bitcoin against most emerging stock market indices during the COVID-19 period. Umar et al. (2023) assert that Bitcoin and Gold are not reliable safe-havens. Singh et al. (2024) in their study reveal that Bitcoin is an effective hedge for investments in Nifty-50, Sensex, GBP–INR, and JPY–INR, at the same time a good diversifier for Gold. The study suggests that investors can incorporate Bitcoin in their portfolios as a good hedge against market volatility in equities and commodities markets. During the COVID-19 epidemic, Barbu et al. (2022) investigated if Ethereum and Bitcoin could serve as a short-term safe haven or diversifier against stock indices and bonds. The outcomes are consistent with the research conducted by Snene Manzli et al. (2024). Both act as hybrid roles for stock market returns, diversifiers for sustainable stock market indices, and safe havens for bond markets. Notably, Bhuiyan et al. (2023) found that Bitcoin provides relatively better diversification opportunities than Gold during times of crisis. To reduce risks, Bitcoin has demonstrated a strong potential to operate as a buffer against global uncertainty and may be a useful hedging tool in addition to Gold and similar assets (Baur & Lucey, 2010; Bouri et al., 2017; Capie et al., 2005; Dyhrberg, 2015). According to Huang et al. (2021), its independence from monetary policies and minimal association with conventional financial assets allow it to have a safe-haven quality. Bitcoins have a substantial speed advantage over other assets since they are traded at high and constant frequencies with no days when trading is closed (Selmi et al., 2018). Additionally, it has been demonstrated that the average monthly volatility of Bitcoin is higher than that of Gold or a group of international currencies expressed in US dollars; nevertheless, the lowest monthly volatility of Bitcoin is lower than the maximum monthly volatility of Gold and other foreign currencies (Dwyer, 2015). Leverage effects are also evident in Bitcoin returns, which show lower volatilities in high return periods and higher volatilities in low return times (Bouri et al., 2017; Liu et al., 2017). According to recent research, Bitcoins can be used to hedge S&P 500 stocks, which increases the likelihood that institutional and retail investors will build secure portfolios (Okorie, 2020). Bitcoin demonstrates strong hedging capabilities and can complement Gold in minimizing specific market risks (Baur & Lucey, 2010). Its high-frequency and continuous trading further enrich the range of available hedging tools (Dyhrberg, 2016). Moreover, Bitcoin spot and futures markets exhibit similarities to traditional financial markets. In the post-COVID-19 period, Zhang et al. (2021) found that Bitcoin futures outperform Gold futures.Gold, silver, palladium, and platinum were among the most common precious metals utilized as safe-haven investments. Gold is one such asset that is used extensively (Salisu et al., 2021). Their study tested the safe-haven property of Gold against the downside risk of portfolios during the pandemic. Empirical results have also shown that Gold functions as a safe haven for only 15 trading days, meaning that holding Gold for longer than this period would result in losses to investors. This explains why investors buy Gold on days of negative returns and sell it when market prospects turn positive and volatility decreases (Baur & Lucey, 2010). In their study, Kumar et al. (2023) tried to analyse the trends in volume throughout futures contracts and investigate the connection between open interest, volume, and price for bullion and base metal futures in India. Liu et al. (2016) in their study found that there is no negative association between Gold and the US stock market during times of extremely low or high volatility. Because of this, it is not a strong safe haven for the US stock market (Hood & Malik, 2013). Post-COVID-19, studies have provided mixed evidence on the safe-haven properties of Gold (Bouri et al., 2020; Cheema et al., 2022; Ji et al., 2020). According to Kumar and Padakandla (2022), Gold continuously demonstrates safe-haven qualities for all markets, except the NSE, both in the short and long term. During the COVID-19 episode, Gold’s effectiveness as a hedge and safe-haven instrument has been impacted (Akhtaruzzaman et al., 2021). Al-Nassar (2024) conducted a study on the hedge effectiveness of Gold and found that it is a strong hedge in the long run. Bhattacharjee et al. (2023) in their paper examined the symmetrical and asymmetrical linkage between Gold price levels and the Indian stock market returns by employing linear autoregressive distributed lag and nonlinear autoregressive distributed lag models. The results exhibit that the Indian stock market returns and Gold prices are cointegrated. According to the most recent study by Kaczmarek et al. (2022), Gold has no potential as a safe haven, despite some studies on the COVID-19 pandemic showing contradictory results. The co-movements of Bitcoin and the Chinese stock market have also normalized as a result of this epidemic (Belhassine & Karamti, 2021). Widjaja and Havidz (2023) verified that Gold was a safe haven asset during the COVID-19 pandemic, confirming the Gold’s safe-haven characteristic. As previously pointed out, investors value safe-haven investments in times of risk. Investors panic at these times when asset prices fall and move from less liquid (risky) securities to more liquid (safe) ones, such as cash, Gold, and government bonds. An asset must be bought and sold rapidly, at a known price, and for a reasonably modest cost to be considered truly safe (Smales, 2019). Therefore, we need to properly re-examine the safe-haven qualities of Gold and Bitcoin due to the mixed evidences regarding their safe-haven qualities and the impact of COVID-19 and the war in Ukraine on financial markets. This work contributes to and deviates from the body of existing literature in the following ways. We propose a novel approach in this work to evaluate an asset’s time-varying safe haven, hedge, and diversifier characteristics. This research examines the safe haven, hedging, and diversifying qualities of Gold and Bitcoin against the equity indices; S&P 500, CAC 40, and NSE 50. Through the use of rolling window estimation, we extend the methodology of Ratner and Chiu (2013) by estimating the aforementioned properties of the assets. Comparing rolling window estimation to other conventional techniques, the former will provide a more accurate representation of an asset’s time-varying feature. This study explores the conventional asset Gold’s time-varying safe haven, hedging, and diversifying qualities during crises like the COVID-19 pandemic and the conflict in Ukraine. We use Bitcoin, an unconventional safe-haven asset, for comparison. Data and Methodology We use the daily returns of three major equity indices; S&P500, CAC 40, and NSE 50 from January 3, 2018, to October 15, 2022. The equity indices were selected to represent three large and diverse markets namely the United States, France, and India in terms of geography and economic development. We assess safe-haven assets using the daily returns of Gold and Bitcoin over the same time. Equity data was collected from Yahoo Finance, Bitcoin data from coinmarketcap.com, and Gold data from the World Gold Council website. Engle (2002) developed the DCC (Dynamic Conditional Correlation)-GARCH model, which is frequently used to assess contagion amid pandemic uncertainty or crises. Time-varying variations in the conditional correlation of asset pairings can be captured using the DCC-GARCH model. Through employing this model, we can analyse the dynamic behavior of volatility spillovers. Engle’s (2002) DCC-GARCH model contains two phases; 1. Univariate GARCH model estimation2. Estimation of time-varying conditional correlation. For its explanation, mathematical characteristics, and theoretical development, see here [insert the next link in “the word here” https://journals.sagepub.com/doi/10.1177/09711023251322578] Results and Discussion The outcomes of the parameters under the DCC-GARCH model for each of the asset pairs selected for the investigation are shown in Table 1.   First, we look at the dynamical conditional correlation coefficient, ρ.The rho value is negative and insignificant for NSE 50/Gold, NSE 50 /BTC, S&P500/Gold, and S&P500/BTC indicating a negative and insignificant correlation between these asset pairs, showing Gold and Bitcoin as potential hedges and safe havens. The fact that ρ is negative and significant for CAC 40/Gold suggests that Gold can be a safe haven against CAC 40 swings. The asset pair CAC/BTC, on the other hand, has possible diversifier behavior with ρ being positive but statistically insignificant. Next, we examine the behavior of the DCC-GARCH parameters; α and β. We find that αDCC is statistically insignificant for all the asset pairs, while βDCC is statistically significant for all asset pairs. βDCC quantifies the persistence feature of the correlation and the extent of the impact of volatility spillover in a particular market’s volatility dynamics. A higher βDCC value implies that a major part of the volatility dynamics can be explained by the respective market’s own past volatility. For instance, the NSE 50/Gold’s βDCC value of 0.971 shows that there is a high degree of volatility spillover between these two assets, with about 97% of market volatility being explained by the assets’ own historical values and the remainder coming from spillover. Thus, we see that the volatility spillover is highly persistent (~0.8) for all the asset pairs except NSE 50/BTC. The results above show that the nature of the dynamic correlation between the stock markets, Bitcoin and Gold is largely negative, pointing toward the possibility of Gold and Bitcoin being hedge/safe haven. However, a detailed analysis is needed to confirm the same by employing rolling window analysis, and we present the results in the forthcoming section. We present the rolling window results for S&P500 first. We present the regression results for Gold in Figure 1 and Bitcoin in Figure 2   Figure 1. Rolling Window Regression Results for S&P500 and Gold.Note: Areas shaded under factor 1 represent significant regression coefficients. In Figure 1, we examine the behavior of β0 (intercept term), β1, β2, and β3 (partial correlation coefficients). The intercept term β0 will give an idea about whether the asset is behaving as a diversifier or hedge. Here, the intercept term shows significance most of the time. However, during 2018, the intercept was negative and significant, showing that it could serve as a hedge during geopolitical tensions and volatilities in the global stock market. However, during the early stages of COVID-19, we show that the intercept is negative and showing statistical significance, suggesting that Gold could serve as a hedge during the initial shocks of the pandemic. These findings are contrary to the results in the study by Tarchella et al. (2024) where they found hold as a good diversifier. Later, we find the intercept to be positive and significant, indicating that Gold could act as a potential diversifier. But during the Russia-Ukraine War, Gold exhibited hedge ability again. Looking into the behavior of β1, which is the partial correlation coefficient for the tenth percentile of return distribution shows negative and insignificant during 2018. Later, it was again negative and significant during the initial phases of COVID-19, and then negative in the aftermath, indicating that Gold could act as a weak safe haven during the COVID-19 pandemic. Gold could serve as a strong safe haven for the SP500 against volatility in the markets brought on by the war in Ukraine, as we see the coefficient to be negative and large during this time. From β2 and β3, the partial correlation coefficients of the fifth and first percentile, respectively, show that Gold possesses weak safe haven properties during COVID-19 and strong safe haven behavior during the Ukraine crisis. Next, we examine the characteristics of Bitcoin as a hedge/diversifier/safe haven against the S&P500 returns. We present the results in Figure 2.   Figure 2. Rolling Window Regression Results for S&P500 and Bitcoin.Note: Areas shaded under factor 1 represent significant regression coefficients. Like in the previous case, we begin by analysing the behavior of the intercept coefficient, which is β0. As mentioned earlier the intercept term will give a clear picture of the asset’s hedging and diversifier property. In the period 2018–2019, the intercept term is positive but insignificant. This could be due to the large volatility in Bitcoin price movements during the period. It continues to be minimal (but positive) and insignificant during 2019–2020, indicating toward weak diversification possibility. Post-COVID-19 period, the coefficient shows the significance and positive value, displaying the diversification potential. We see that the coefficient remains positive throughout the analysis, confirming Bitcoin’s potential as a diversifier. Looking into the behavior of β1 (the partial correlation coefficient at tenth percentile), it is positive but insignificant during 2018. The coefficient is having negative sign and showing statistical significance in 2019, suggesting that Bitcoin could be a good safe haven in that year. This year was characterized by a long list of corporate scandals, uncertainties around Brexit, and tensions in global trade. We can observe that throughout the COVID-19 period, the coefficient is showing negative sign and negligible during the March 2020 market meltdown, suggesting inadequate safe-haven qualities. However, Bitcoin will regain its safe-haven property in the coming periods, as the coefficient is negative and significant in the coming months. The coefficient is negative and shows statistical significance during the Ukrainian crisis, suggesting strong safe-haven property. Only during the Ukrainian crisis could Bitcoin serve as a safe haven, according to the behavior of β2, which displays the partial correlation coefficient at the fifth percentile. Bitcoin was a weak safe haven during COVID-19 and the Ukrainian crisis, according to β3, the partial correlation coefficient for the first percentile (coefficient negative and insignificant). According to the overall findings, Gold is a stronger safe haven against the S&P 500’s swings. This result is consistent with the previous studies of Triki and Maatoug (2021), Shakil et al. (2018), Będowska-Sójka and Kliber (2021), Drake (2022), and Ghazali et al. (2020), etc. The same analysis was conducted for the CAC 40 and the NSE 50; the full analysis can be found here [insert the next link in “the word here” https://journals.sagepub.com/doi/10.1177/09711023251322578]. However, it is important to highlight the respective results: In general, we may say that Gold has weak safe-haven properties considering CAC40. We can conclude that Bitcoin’s safe-haven qualities for CAC40 are weak. We can say that Gold showed weak safe-haven characteristics during the Ukraine crisis and good safe-haven characteristics for the NSE50 during COVID-19. We may say that Bitcoin exhibits weak safe haven, but strong hedging abilities to NSE50. Concluding Remarks In this study, we suggested a new method to evaluate an asset’s time-varying hedge, diversifier, and safe-haven characteristics. We propose a rolling window estimation of the DCC-based regression of Ratner and Chiu (2013). Based on this, we estimate the conventional asset’s time-varying safe haven, hedging, and diversifying properties during crises like the COVID-19 pandemic and the conflict in Ukraine. For comparison purposes, we include Bitcoin, a nonconventional safe-haven asset. We evaluate Gold and Bitcoin’s safe haven, hedging, and diversifier properties to the S&P 500, CAC 40, and NSE 50 variations. We use a rolling window of length 60 to estimate the regression. From the results, we find that Gold can be considered as a better safe haven against the fluctuations of the S&P 500. In the case of CAC 40, Gold and Bitcoin have weak safe-haven properties. While Bitcoin demonstrated strong safe-haven characteristics during the Ukraine crisis, Gold exhibited strong safe-haven characteristics during COVID-19 for the NSE 50. Overall, the findings indicate that Gold is the better safe haven. This outcome is consistent with earlier research (Będowska-Sójka & Kliber, 2021; Drake, 2022; Ghazali et al., 2020; Shakil et al., 2018; Triki & Maatoug, 2021). When it comes to Bitcoin, its safe-haven feature is weak. Bitcoin, however, works well as a diversifier and hedge. Therefore, from a policy perspective, investing in safe-haven instruments is crucial to lower the risks associated with asset ownership. Policymakers aiming to enhance the stability of financial portfolios might encourage institutional investors and other market players to incorporate Gold into their asset allocations. Gold’s strong safe-haven qualities, proven across various market conditions, make it a reliable choice. Gold’s performance during crises like COVID-19 highlights its potential to mitigate systemic risks effectively. Further, Bitcoin could also play a complementary role as a hedge and diversifier, especially during periods of significant volatility such as the Ukraine crisis. While Bitcoin’s safe-haven characteristics are relatively weaker, its inclusion in a diversified portfolio offers notable value and hence it should not be overlooked. Further, policymakers may consider how crucial it is to monitor dynamic correlations and periodically rebalance portfolios to account for shifts in the safe haven and hedging characteristics of certain assets. Such measures could help reduce the risks of over-reliance on a single asset type and create more resilient portfolios that can better withstand global economic shocks. For future research, studies can be conducted on the estimation of the rolling window with different widths. This is important to understand how the safe-haven property changes across different holding periods. Further, more equity markets would be included to account for the differences in market capitalization and index constituents. This study can be extended by testing these properties for multi-asset portfolios as well. We intend to take up this study in these directions in the future. Data Availability StatementNot applicable.Declaration of Conflicting InterestsThe authors declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.FundingThe authors received no financial support for the research, authorship, and/or publication of this article.ReferencesAkhtaruzzaman M., Boubaker S., Lucey B. M., & Sensoy A. (2021). Is gold a hedge or a safe-haven asset in the COVID-19 crisis? Economic Modelling, 102, 105588. Crossref. Web of Science.Al-Nassar N. S. (2024). Can gold hedge against inflation in the UAE? A nonlinear ARDL analysis in the presence of structural breaks. PSU Research Review, 8(1), 151–166. Crossref.Barbu T. C., Boitan I. A., & Cepoi C. O. (2022). Are cryptocurrencies safe havens during the COVID-19 pandemic? A threshold regression perspective with pandemic-related benchmarks. Economics and Business Review, 8(2), 29–49. 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In the Middle East, China seeks to appear neutral by engaging in dialogue with all actors, from Tehran to Tel Aviv, including Riyadh. Beijing's objective is clear: to establish itself as a guarantor of stability to secure its energy and commercial interests. The People's Republic of China's (PRC) commitment to the Middle East reflects a carefully calibrated geostrategic approach, aiming to preserve regional stability, ensure uninterrupted access to energy resources, and promote its famous Belt and Road Initiative (BRI), also known as the 'New Silk Roads.' In this region, the Sino-Iranian relationship is most often highlighted due to its political weight and military dimension; however, whether in economic, diplomatic, or strategic terms, Beijing's presence in this area certainly extends beyond its ties with Tehran. As elsewhere in the world, in the Middle East, China divides its diplomatic partnerships into several types, listed here in descending order of intensity: "global strategic partnerships" (in the Middle East: Egypt, Iran, Saudi Arabia, United Arab Emirates, and Bahrain); "strategic partnerships" (Iraq, Jordan, Kuwait, Oman, Qatar, Syria, Turkey, and the Palestinian Authority); "friendly cooperation partnerships" (Lebanon and Yemen); and finally, "innovative global partnerships" (Israel). China is redefining its priorities in the Middle East  Energy dependence is one of the essential drivers of China's policy in the region. Gulf countries, particularly Saudi Arabia, the United Arab Emirates, and Kuwait, are among the main suppliers of crude oil to the PRC—well ahead of Iran in terms of volume, as well as reliability and investment opportunities. This economic reality compels China to invest much more heavily in the Gulf Cooperation Council (GCC) countries, where financial stability, political predictability, and institutional openness promote sustainable strategic partnerships and infrastructure development, unlike in Iran. For these reasons, the Gulf countries have indirectly become essential nodes in the architecture of the BRI through trade, receiving nearly six times more Chinese investments than Iran. Although Iran has geographical interest as a potential corridor between China and Europe, the persistent effect of international sanctions, poor economic management, and regional adventurism severely limit its ability to attract sustainable Chinese investments. In contrast, Israel offers a functioning and favorable environment for investors, making it a preferred destination for Chinese capital and infrastructure projects. Its economy is based on solid infrastructure and a dynamic technology sector. Despite geopolitical shocks, including the recent clashes with Iran – which will undoubtedly impact the country's business environment – Israel, as a member of the OECD, remains attractive in terms of business environment and investment, mainly because the foundations of its economic environment are stronger than those of Iran or Saudi Arabia. The Hebrew state occupies an increasing place within the BRI – not due to the volume of Chinese direct investments, but because of its strategic position and ambitious infrastructure agenda. Its geographical location – straddling Europe, Asia, and Africa via the Mediterranean – makes it a key land and maritime connectivity point that provides an alternative option to Iran for linking China to Europe. In this context, China and Israel have made progress in their negotiations for a free trade agreement that has been discussed since 2016. Although discussions have been suspended since 2023, there remains hope that an agreement could be signed once stability returns to the region. China's trade with Israel and Iran: divergent trajectories China's commercial relations with Israel and Iran reveal two distinct economic approaches.  With Israel, trade is increasingly marked by imports of high technologies - particularly in the semiconductor field - reflecting a growing technological interdependence.  In contrast, trade with Iran remains focused on industrial goods and natural resources, illustrating a more traditional partnership based on access to raw materials. These contrasting dynamics reflect China's strategic flexibility, which relies on Israeli innovation while securing its supplies from Iran.  Tensions in the Strait of Hormuz are testing China's strategy in Iran  For nearly fifty years, Iran has turned to China for economic support. However, despite 21 Chinese greenfield investment projects between 2003 and 2020 – mainly in the energy sector – Beijing has gradually begun to disengage due to international sanctions and ongoing regional instability. Large companies such as CNPC and Sinopec have reduced their stake, or even abandoned some projects, while tech companies like Huawei and Lenovo have also scaled back their presence in the Iranian market. Between 2017 and 2019, Iran reportedly saw an outflow of Chinese capital estimated at $990 million. China views instability in the Middle East, particularly the confrontation between Israel and Iran, as a direct threat to its economic and commercial interests. As the world's largest buyer of Iranian oil, China is especially concerned about potential disruptions in strategic maritime routes, particularly the Strait of Hormuz. In June 2025, Chinese oil imports from Iran significantly increased, reaching up to 1.8 million barrels per day – a surge that occurred just before the military escalation between Israel and Iran, which raised concerns about the security of the Strait of Hormuz. A sign of the weight of the PRC in this region: after the reciprocal airstrikes between Israel and Iran, and Tehran's threat to close this crucial passage, U.S. Secretary of State Marco Rubio urged Beijing to intervene, emphasizing China's heavy dependence on this oil route. China–United States: strategic tensions in a transitioning Middle East China and the United States recently signed a trade agreement and established a 90-day tariff truce, aiming to resolve some key disputes and stabilize economic relations. Furthermore, on the military front, Iran and China signed a military cooperation agreement as early as 2016, reflecting their mutual desire to counter American influence in the region and secure trade routes. Historically, China has supported Iran through arms sales, technology transfers, and training programs. Moreover, despite the official rhetoric, some reports suggest that Chinese technologies have contributed to the development of Iran's ballistic program. The Sino-Iranian relationship in defense illustrates a two-level diplomacy: China discreetly supports Iran's military autonomy while ensuring it does not compromise its strategic relationships with other important regional partners, including Israel, with whom it also maintains top-level security dialogues. This highlights Beijing's broader ambition: to avoid regional polarizations and maintain a balance of power favorable to its interests. China's strategy in the Middle East towards the United States is based on a principle of equidistance: to increase its influence without direct confrontation, while drawing strategic benefits from Saudi Arabia, Israel, Iran, and Egypt. In this perspective, the People's Republic of China does not seek to replace the United States as the dominant power in the region, but rather to offer a multipolar presence focused on preserving stability. Maintaining the status quo, avoiding direct conflicts, and building a parallel system of influence through infrastructure, trade, and diplomacy are the pillars of China's position in the Middle East. This approach ensures Beijing secure access to energy, trade corridors, and sustainable geopolitical influence from Tel Aviv to Tehran.