The Sahel has known a turbulent history of rebellions against the central state. In Niger, the Tuareg ethnic community, which forms a minority in Niger as a whole but a majority in the Agadez region, mainly led these rebellions. At times, the Tuareg also joined forces with the Tubu, who form an even smaller minority within the Agadez region and the central state. Northern Chad has had an even more tumultuous past – marked by persistent rebellions against a distant central state.[145] In both regions, the ethnic groups behind these rebellions now dominate the facilitation of irregular migration – not in the least because of their intimate knowledge of the desert. Yet in both countries, the central state has also become more active in controlling economic activities, such as human smuggling and gold mining, in their peripheral regions. This raises the question of how contemporary migration governance in the Sahel has affected stability in the region – in particular, with regard to changes in cross-border trade relations and the appearance of anti-migration forces. How has migration governance changed the relationship between the various actors involved in the facilitation of irregular migration, how have these actors responded to the measures taken against them, and what consequences does this have for stability in the region more generally?

Migration actors

In Niger, the main actors involved in developing and facilitating migration routes are smugglers belonging to the Tuareg and Tubu ethnic groups. ‘Smugglers’ include the passeurs who head the smuggling networks, the drivers and vehicle owners, the ghetto owners and managers, and the intermediaries or ‘coaxers’.

The Tuareg live in the north-west of Niger and the Tubu in the north-east. The Ténéré desert between Agadez and Bilma constitutes a natural and historical border between both communities. Importantly, many of the Nigerien Tuareg smugglers between Niger and Libya are former rebels, or relatives thereof. On the Tubu side, many smugglers are young men with less military experience, except for some who fought with Libyan Tubu militias and who managed to acquire vehicles in Libya after the 2011 revolution. Some of those smugglers have been, or even still are, members of Libyan ethnic Tuareg and Tubu militias, or have connections with them, which facilitates their movement along roads and across border posts and checkpoints controlled by these forces. It can also facilitate their access to weapons in Libya.

Because of the geographic distribution of both ethnic groups, and of cross-border connections with the same communities in Algeria and Libya, Tuareg smugglers operate mostly on routes between Niger and Algeria as well as on routes to the Salvador Pass area at the tri-border between Niger, Algeria and Libya, from where they can drive to the Tuareg-dominated towns of Ghat and Ubari in Libya’s south-western corner. The Tubu control most of the routes between Niger and Libya, including the key axis between Dirkou and Sebha. This control has strengthened since the 2011 fall of Muammar Qaddafi, when Tubu militias took control of most of Libya’s southern borders. The conflict that then erupted between Tubu and Tuareg over Ubari and neighbouring oilfields made Tuareg presence on this Tubu axis more problematic. The active conflict resolution efforts of traditional and political elites in the Agadez region has largely prevented this conflict from spilling over into Niger.[146]

Since 2011, Tubu empowerment in Libya has allowed the Tubu to dominate migrant smuggling between Niger and Libya to the detriment of the Tuareg. As a result, the Tubu have benefitted relatively more from the post-Qaddafi migration industry than the Tuareg have. This has created new tensions between the two communities in Niger, and aggravated tensions between them over control of Ubari town (itself a smuggling hub) in south-western Libya.[147] One unexpected positive consequence of migration governance has been, however, that it has forced the two communities to work together to circumvent security controls in the Nigerien desert. The industry has moved to a model in which the Tuareg generally facilitate the travel of irregular migrants up to the Dirkou area, where migrants are handed over to Tubu smugglers for the remainder of the journey.[148]

Box 8
Ties between human smuggling and other illicit activities in Niger

There are connections between migrant smuggling in Niger and other activities considered illicit. It would be simplistic, however, to suggest that all those activities are undertaken by the same people, or even fall under the control of a small number of mafia-style organisations.[149] In fact, Saharan communities appear to make a clear distinction between activities that may be – either traditionally or because of recent evolutions – officially prohibited by law but not seen as illicit, and others which are seen as actually criminal. Among activities widely considered as licit, because they do not necessarily generate violence, are both migrant smuggling and gold mining (which only recently became prohibited – partly due to foreign pressure).[150]

Activities generally considered as truly criminal, such as drug trafficking and arms trafficking, appear to involve a smaller number of young men, with ethics and track records different from migrant smugglers, even if there are some connections between them. Some drivers agree to work in drug trafficking, often for a brief period, in order to obtain enough money to buy their own vehicles for migrant smuggling. It is even said that a driver would be given a vehicle as a reward for successfully driving several drug convoys.[151] The coincidence of the crackdown on migration and the closure of the Djado gold mine in 2017 had the effect of reportedly turning some disgruntled migrant smugglers to drug trafficking and other criminal activities.[152] Ironically, the fact that migrant smuggling is now seen as a criminal activity and gold mines have been closed to individual miners, has made activities such as drug trafficking more acceptable ethically.[153]

Three communities occupy Chad’s northern region: the Tubu in the north-west (mostly in the Tibesti region), the Goran (in an area stretching between the north of Lake Chad and the Chad-Libya-Sudan tri-border), and the Zaghawa in the north-east. Smugglers from the three communities operate on different stretches of northern Chad, largely based on their ethnic homelands and the trade routes they travelled historically. Thus, the Tubu mostly operate on routes between Tibesti and Libya. The Goran operate in particular on the main road between Faya and Kufra. The Zaghawa operate on routes between eastern Chad and Libya, notably the direct road between Tina, on the Chad-Sudan border, and Kufra. The Zaghawa also operate on routes between eastern Chad and the north-west of the country, up to Tibesti.

The ability of the Zaghawa to operate in Chad, far from their historical homeland, is largely due to the fact that Chadian president Idriss Déby is a Zaghawa.[154] Since Déby took up power in the 1990, the Zaghawa have dominated the Chadian army. Zaghawa smugglers thus have ethnic connections with the Chadian army, facilitating their movement across the country and their ownership of vehicles and arms, and allowing them to avoid regular confiscations of their equipment. It would be a mistake, however, to equate the Zaghawa with the Chadian regime. One of the Chadian rebel groups based in Libya is also Zaghawa, and some of its members or former members are reportedly involved in cross-border smuggling. Even more crucially, the Zaghawa straddling the border between Chad and Sudan make up a significant number of the Darfur rebels based in Libya. Through these connections, Zaghawa smugglers are able to transport Horn of Africa (including Sudanese) migrants from Sudan to Chad and then to Libya.[155]

Goran migrants also have links with Chadian rebels based in Libya, where the Goran, with three distinct rebel groups, make up the majority of Chadian combatants. Some Goran migrant smugglers are former rebels with direct connections to these groups. Yet, of the three northern Chadian communities, the Tubu smugglers are those with the most important connections in Libya, as they have links with Libyan Tubu militias. Some Libyan Tubu militia members also smuggle migrants between Chad and Libya, including in association with members of other Chadian communities.

As discussed in the introduction, European migration governance does not target Chad as a country of migrant transit. As a result, no significant efforts have been supported to strengthen the northern border or to address human smuggling and irregular migration. As the next section will show, any effort to do so would need to take into account the particular conflict dynamics and tensions that exist between the central state and these northern actors. Failure to do so could contribute to further instability and human rights abuses in northern Chad.

Box 9
Ties between human smuggling and other illicit activities in Chad

Members of all three Chadian northern communities benefited from gold rushes in Chad, in Niger and in Libya. Rather than just workers, members of those communities are also the ‘bosses’ of those workers, the equipment and vehicle owners and the drivers of the gold miners. Because the gold mines are situated near the Libyan border, with the main gold area of Kouri Bougoudi straddling the Chad-Libya border, vehicles travelling from the south to Kouri Bougoudi have begun to transport migrants along with gold miners, thus opening what became the new, main route between Chad and Libya. In practice, it is often difficult to distinguish between gold miners and migrants, with migrants interrupting their journeys to look for gold and gold miners becoming migrants.[156]

Many Goran and Zaghawa former rebels have turned to migrant smuggling but also, to a larger extent, to gold mining, drug trafficking, and other illegal activities. Looking at individual and group trajectories, it does not seem that the same groups or individuals are involved in all sorts of illegal activities. Rather, it appears clearly that individuals were able to choose in which activity they wanted to work, including depending on their personal ethics and their evaluation of the risks involved.[157]

Stability risks

As discussed in Chapter 2, EU-sponsored interventions targeting irregular migration in Agadez have been effective at putting migrant smugglers out of business but without, however, providing them with viable economic alternatives. Grievances are further aggravated by the fact that the peace talks, which ended northern insurgencies in the 1990s and 2000s successively, largely failed to integrate rebels into national armed forces. As a compromise, ex-combatants were encouraged to transport migrants, openly and legally. As such, former rebels who invested in migrant smuggling regard the implementation of Law No. 2015-036 as a rupture of the peace agreements that had allowed northern Niger to be unusually stable for a decade.[158] It has therefore been suggested that the growing dissatisfaction among northern communities with this situation could possibly lead to a resurgence of Tuareg and Tubu rebellions.

At the same time, however, regional and traditional elites, as well as prominent smugglers and drug traffickers, vehemently oppose the idea of further rebellion. They say that any effort to start a rebellion now would risk attracting radical armed groups to the region. As the Malian and Libyan examples have shown, once such groups become involved in domestic conflicts, the situation (and control over the smuggling and trafficking industries) can become uncontrollable in a very short period of time. National and regional political leaders therefore continually engage in conflict mediation efforts to maintain peace and address any sign of potential conflict.[159] When in early 2017, Adam Tcheke announced the formation of the Movement for Justice and the Rehabilitation of Niger (Mouvement pour la justice et la réhabilitation du Niger, MJRN) in response, notably, to migration policies that were felt to be harming Tubu smugglers disproportionately, authorities quickly responded. The President – together with Interior Minister Mohamed Bazoum and Tubu government minister Barkay Yusuf – sent delegations of Tubu traditional chiefs to placate Tcheke.[160]

Such interventions are crucial because, at a more micro-level there is some degree of instability as a result of the fragmentation of smuggling routes. While some smugglers have abandoned migrant smuggling for other activities, including criminal activities such as joining armed groups, or taking up road banditry or drug trafficking, others have chosen to continue migrant smuggling on more dangerous routes, necessitating better organisation – which has led to a level of professionalisation in the migrant industry. Increasing risks have also made it desirable to carry weapons, which has led to militarisation of the migrant industry. As discussed in Chapter 1, migrant smugglers are now travelling at night on more remote routes, often close to borders (including the Algerian and Chadian borders), and to ungoverned areas used by drug and arms traffickers. One of the main dangers on these new routes is the growing presence of road bandits, from different communities, including reportedly former migrant smugglers. It seems road bandits tend to avoid attacking members of their own communities, and that Tuareg bandits target Tubu vehicles crossing Tuareg land, and vice versa. Local drivers also suggest that bandits of various ethnic groups associate in the same gangs but divide the labour along ethnic lines in order to avoid provoking intratribal tensions.[161]

In recent years, particularly since 2017, northern Niger has also suffered attacks by foreign road bandits reportedly belonging to the Zaghawa community. These groups, made up of Chadian and Darfurian gunmen, first operated in Libya but have now entered Niger. They are suspected of being Chadian army soldiers or ex-soldiers, as well as Chadian and Darfurian rebels or ex-rebels. This new form of insecurity has aggravated tensions between Tubu and Zaghawa communities, as well as between northern communities and the Nigerien authorities, accused of turning a blind eye.[162] At the same time, since 2011, the lack of economic opportunities in the north-east of Niger has caused young Tubu and Tuareg to go to Libya where they work as mercenaries for ethnic militias or rival authorities in northern Libya, often to earn enough money to set themselves up in cross-border smuggling and trafficking industries.[163] This increased presence of armed groups in this remote region obviously does not contribute to stability in the long term.

In Chad, national migration policies are few, yet some signs are underway that the government seeks to position itself as a reliable partner for migration governance – similar to the Nigerien model. Formally partnering on migration governance might attract funding to support the further deployment of armed forces in the northern part of the country, where – not coincidentally – the government has become increasingly active in the fight against rebel groups. In October 2018, for example, as Chadian forces attacked Tubu self-defence militias in the Tibesti mountains, the Chadian Defence Minister accused the Tubu of being not only rebels and drug traffickers but also ‘human traffickers’, while the Interior Minister described them as ‘wild slave drivers’ and ‘terrorists, mercenaries, highwaymen and anything else’. The Interior Minister further claimed to have liberated ‘more than one thousand slaves enslaved by the wild slave drivers in Tibesti’.[164]

These statements can be interpreted as an attempt by the Chadian regime to capitalise on international concerns about migration and human trafficking to request international support for, or leniency towards, its recent belligerence in Tibesti. A recent diplomatic initiative to form a regional border security facility with Libya, Sudan and Niger should also be regarded in this light; the discourse of fighting irregular migration is used by these states to attract international funding for that initiative. Yet previous Clingendael research in Sudan and Chad shows that the main aim of state forces is to control border areas at best and that, at worst, they may themselves become the main human smuggling actors and/or engage in abuses against local populations in the process.[165]

Anti-migration forces

The armed forces responsible for enforcing anti-migration measures in Niger belong to the various components of the Nigerien defence and security forces (FDS), such as the national armed forces, the gendarmerie and the police. Those forces recruit mostly in communities of south-western Niger, and, despite some attempts in the past, have largely failed to integrate, or have resisted integrating, members of Saharan communities. With the exception of a few units into which Tuareg former rebels have been integrated, the security provisions of successive peace agreements for the integration of members of rebel fronts into the national armed forces have remained largely unimplemented.[166]

As a result, relations have remained tense between the FDS and the Tuareg and Tubu communities. Current high-ranking officers are known for having fought the rebels and for having committed abuses against civilians in the past. Many still view the Saharan communities as enemies and possible rebels.[167] As for Tuareg and Tubu civilians, they very much see the national armed forces as foreign forces or ‘occupation’ forces; they complain that those forces constantly impose illegal taxes or ask civilians for bribes, particularly in towns hosting military garrisons, for example Dirkou.[168] Corruption is also endemic at the many roadblocks, where ordinary traders and migrant smugglers alike have to pay large bribes. This risks further strengthening the rifts between the central state and these peripheral regions.

Security forces are not the only ones engaged in operations against irregular migration and people smuggling. Another effect of the enforcement of securitised migration policies in the region is that it has encouraged non-state armed groups to put themselves forward as proxy border forces in the hope of obtaining European funding. Although this happened much more in Libya than in the Sahel, in 2017, Barka Sidimi a former Nigerien Tubu rebel and migrant smuggler, as well as adviser to the Nigerien government, formed a new armed group that announced it would close the border and prevent migrant smugglers from entering Libya. There were allegations he received funding from the EU, Italy or France, but this was denied by all three countries.[169] Such dynamics contribute not only to further militarisation and militia-isation of the region, but also risk creating new tensions between pro- and anti-smuggling forces.

Recent tensions in northern Chad revolve around the gold issue more than the migrant issue. But because gold and migrant routes are increasingly the same, government policies affecting the gold routes also affect the migration routes. In particular, the repeated and sometimes violent evacuations of the Kouri Bougoudi gold mines by the Chadian armed forces have harmed both gold miners and migrant smugglers. The routes to Kouri Bougoudi were closed for periods of several months, most recently since August 2018 following a 24-hour ultimatum and aerial strikes. Some gold miners and migrants living in, or transiting through, Kouri Bougoudi, repeatedly fled to the Libyan side of the border, in spite of the greater risks of travelling in Libya. Some gold miners even reportedly migrated towards northern Libya and Europe because of the closures and evacuations of gold mines.[170]

The Chadian government has also repeatedly confiscated, or threatened to confiscate, pickup trucks transporting either gold miners or migrants. N’Djaména equates these pickups to military vehicles that should only be used by the Chadian armed forces, and thus considers the owners of civilian pickups as rebels. This has considerably aggravated tensions between the state and northern communities (Tubu, Goran and Zaghawa), for whom the pickup trucks are a key economic asset. Similar policies were implemented in Sudan at the same time, which left the Chad-Sudan Zaghawa feeling targeted on both sides of the border.

The Tubu also increasingly felt targeted by Chadian government policies in the Tibesti region. The Tibesti has long suffered from a very unstable administration, with a constant shift of officials. The government also has to a great extent manipulated Tubu traditional chieftaincies, by increasing the number of chiefs so as to reward allies while disempowering perceived opponents. Those two actions had destabilising effects across the entire country, but the Tubu felt particularly targeted.[171] This perception was greatly aggravated in August 2018, when a large part of eastern Tibesti, including the important Miski gold mines, became part of the Borkou region, dominated by the Goran. Later on, three Tubu traditional chiefs seen as opponents were dismissed, while a new chieftaincy was given to a Goran candidate.[172]

These developments have created tensions between the Tubu and the Goran and, even more, between the Tubu and the state, seen as responsible for fuelling ethnic tensions. Also in August and September 2018, as a reaction to a rebel attack in Kouri Bougoudi, Chadian air forces reportedly struck the Kouri Bougoudi area twice, killing two traders. In the same period, the Miski gold mining area was also bombed and three Tubu wounded, despite Miski being far away from Kouri Bougoudi and the Tubu being neither part of, nor supporters of, the rebel attack.[173] Then, in October 2018, Chadian ground forces attacked self-defence militias in Miski, which had initially formed to protect the area from gold miners and which had cooperated with the army before tensions began to pit them against each other after late 2017.[174]

These attacks have been justified by declarations from Chadian officials describing the Tubu, as mentioned above, as ‘human traffickers’ and ‘wild slave drivers’.[175] The attacks have been perceived as further hostile acts towards the Tubu and have generated considerable anger against the state among the Tubu. These developments may push the Tubu, including existing self-defence militias and more recently mobilised youths, to start another insurgency or join existing rebel groups in spite of the fact that the Tubu community has not been part of, or supported, the Chadian armed opposition since 2010.

The situation in northern Chad is thus becoming increasingly volatile – something that future efforts at migration governance in Chad should take into account so as not to become a pawn in the larger power struggle between the central state and rebel forces in the north. To date, the international community has not taken sufficient account of these developments. On the contrary, in August 2018, the same month that the Miski bombings took place, the French military announced the planned redeployment of the eastern headquarters of the EU-supported regional G5-Sahel anti-terrorist force from N’Djaména to Wour, in Tibesti, less than 100km from the area that had just been attacked by the rebels.[176] The northern Chadian communities regarded this as a message that the EU – and France in particular – was ready to militarily support the Déby regime against rebel attacks.[177]

Both regions are located in volatile regions, surrounded by (radical) armed groups and instability in neighbouring countries such as Mali, Algeria, Libya and Sudan.
Interview Mardami Moursal, Tubu Representative in Agadez, Agadez, 2018. 31 August. Interview member of the Comité Regional de paix d’Agadez. Agadez. 2018. 3 September.
Murray, R. 2017. Southern Libya Destabilized: The Case of Ubari. SANA Briefing Paper. Geneva: Small Arms Survey. April. link
Interview member of the Comité Regional de paix d’Agadez. Agadez. 2018. 3 September. Interview Tuareg trafficker, Niamey, 2018. 14 July. Interview Tubu smuggler, Agadez, 2018. 2 September. Email correspondence with a staff member of a humanitarian organisation active in Agadez. 2018. 10 October.
Tubiana and Gramizzi, forthcoming, op. cit.
Gold discoveries in northern Niger were made in the years 2012-2014, coinciding with the migrant smuggling boom that followed the Libyan revolution. Both activities require similar skills, in particular drivers with a good knowledge of desert routes. This is the reason why many Tubu and Tuareg young men moved back and forth between migrant smuggling and gold mining. Many abandoned migrant smuggling at times of promising gold rushes, then returned to it at periods when gold mines were shut, or when findings were disappointing, or sometimes when they had found sufficient gold to buy their own vehicle. Tubiana and Gramizzi, forthcoming, op. cit.
Personal interviews with drug traffickers, Niger, March 2017-April 2018.
Former migrant smugglers mainly turn to the trafficking of Tramadol (a morphine-like analgesic), which has seen an upsurge in Niger. See: Tinti, P., 2018. ‘New trends in tramadol trafficking in Niger’, The Global Initiative Against Transnational Organized Crime, 25 June, link. The cannabis resin and cocaine trafficking industries require more seasoned operators and are more difficult to penetrate by outsiders. Interview Mohamed Anacko, President of the Agadez Regional Council. Agadez. 2018. 30 August. Interview Tubu smuggler, Agadez, 2018. 2 September.
Personal interviews with migrant smugglers and drug traffickers, Niger, March 2017-April 2018.
According to a Sudanese asylum seeker who recently travelled to Libya through Chad, ‘in Chad it is illegal to detain a pickup truck. But the Zaghawa face no problem with this interdiction. So 80% of the owners of pickups are Zaghawa. For a Zaghawa, it is very easy to cross the border, there is no procedure.’ Personal interview with A.A., Sudanese asylum seeker. 2018. Location withheld, July.
An significant number of the migrants travelling from both Chad and Sudan to Libya are Zaghawa themselves. Once in Libya, they can benefit from connections with the Darfur rebels and even join them as combatants, and from links with the Zaghawa diaspora in Libya at large, whose historical presence sometimes offers protection to migrants. Thus, as mentioned above, in 2018, Darfurian (Zaghawa) migrants expelled from Niger to Libya and abandoned at the border, in the desert – were then rescued thanks to an effort of the Darfurian community in Libya. Tubiana, Warin and Saeneen, op. cit., 62-66.
Tubiana, Warin and Saeneen, op. cit.
Personal interviews with Chadian rebels and former rebels, gold miners, migrant smugglers and drug traffickers. Chad, Niger and other locations. 2017-2018.
See: Compte-rendu des échanges. Forum International Pour la Paix et la Stabilité. Agadez, 20-21 July 2018. For more information on the role that migrant smuggling played in the peace agreement, see Tubiana, J. 2017. ‘Europe’s “Migrants Hunters”’, Foreign Affairs, 31 August. link
See, for example, Compte-rendu des échanges. Forum International Pour la Paix et la Stabilité. Agadez, 20-21 July 2018.
Tubiana and Gramizzi, forthcoming.
Personal interviews with drivers. 2017, Agadez and Dirkou, February-March. This dynamic may also have affected the negative perception that the Agadez community holds of Darfurian asylum seekers.
Compte-rendu des échanges. Forum International Pour la Paix et la Stabilité. Agadez, 20-21 July 2018. Interview Tubu public official, Niamey, 2018. 4 September.
Compte-rendu des échanges. Forum International Pour la Paix et la Stabilité. Agadez, 20-21 July 2018. Interview Tubu public official, Niamey, 2018. 4 September.
RFI. 2018. ‘Tchad: affrontements entre l'armée tchadienne et une rébellion du nord’, 25 October. link ; Alwihda Info. 2018. ‘Tchad : plus d'un millier d'esclaves libérés au Tibesti, annonce le ministère de la Sécurité’, 30 0ctober. link
Tubiana, Warin and Saeneen, op. cit.
Compte-rendu des échanges. Forum International Pour la Paix et la Stabilité. Agadez, 20-21 July 2018.
Interviews with members of the Tuareg and Tubu communities, officials and military officers. Niamey, Agadez and Dirkou, March 2017-April 2018.
Tubiana, J. and Gramizzi, C. Forthcoming. Lost in Trans-nation: Tubu (Teda) and Other Armed Groups and Smugglers on Libya’s Southern Borders, Small Arms Survey and Conflict Armament Research.
Tubiana, Warin and Saeneen, op. cit., 32-35; Penney, J. 2018. ‘Europe Benefits by Bankrolling an Anti-Migrant Effort. Niger Pays a Price’, New York Times, 25 August. link
Personal telephone interviews with Kouri Bougoudi gold miners. 2017-2018.
Tubiana, J. and Gramizzi, C. 2017. Tubu Trouble: State and Statelessness in the Chad–Sudan–Libya Triangle, HSBA Working Paper No 43, Geneva, Small Arms Survey and Conflict Armament Research, June, 59-69. link
République du Tchad. 2018. ‘Ordonnance No. 0037/PR/2018 portant création des unités administratives et des collectivités autonomes’, 7 August.
Interviews with Chadian Tubu politicians, locations withheld, August-September 2018. It should be noted that the main international actors in the region did not condemn these bombings.
RFI. 2018. ‘Tchad: affrontements entre l'armée tchadienne et une rébellion du nord’, 25 October. link ; Alwihda Info. 2018. ‘Tchad : plus d'un millier d'esclaves libérés au Tibesti, annonce le ministère de la Sécurité’, 30 0ctober. link
Ibid.
The G5 Sahel is made up of Chad, Niger, Mali, Mauritania and Burkina Faso. Its eastern zone is made up of Chad and Niger, and includes Chadian troops based in Wour and Nigerien troops based in Madama.
Interviews and telephone interviews with Chadian Tubu, various locations, August-September 2018. It should be noted that the EU-funded Security and Border Management programme (SECGEF), which focuses on Chad’s western borders with Cameroon and Niger, does take this risk into account. However, the proposed measures that address this risk are vague at best. See: European Commission, 2017. Document d’action du Fonds fiduciaire de l’UE, 6 December, link.