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the hands of the other mainstream opposition in the northern part of Syria.29 The various groups
that make up the Islamic Front, part of the other coalition, are divided in their attitude toward Al-Nusra and ISIL; while some remained loyal to the secular opposition, some groups have
terminated such cooperation and have subsequently aligned with the jihadist groups.30 As of late
2015, the various opposition groups, including the Al-Nusra Front, controlled approximately
twenty percent of Syrian territory.31 The primary aim of the mainstream opposition is to
overthrow the present government, while the jihadist Al-Nusra Front and some of the other more
mainstream Islamist 'groups' goal is to establish an ultra-conservative, theocratic government,
fundamentally focused on implementing Islamic law.32
According to international law, when certain crimes are committed as part of a
widespread or systematic attack against civilians, and the perpetrators know that their conduct is
part of this attack, such offenses constitute crimes against humanity.33 The Syrian government
has failed to control the now-raging civil war in its country, as rebellion forces continue to
terrorize civilians and dictate their everyday lives.34 The United Nations found "reasonable
grounds to believe that Government forces […] committed crimes against humanity, war crimes,
and violations of international humanitarian law, and thus authorized its Security Council to
intervene.”35 The burden has thus shifted from the Syrian government to more stable foreign
countries, including the United States, to intervene and save these victims' lives.
I. THE CAUSES OF MINOR SEX TRAFFICKING AND THE GROWING SEX TRADE IN SYRIA
The United States’ State Department's annual Trafficking in Persons Report defines
human trafficking as "the act of recruiting, harboring, transporting, providing, or obtaining a
person for compelled labor or commercial sex acts through the use of force, fraud, or
coercion."36 Sex trafficking is the third highest grossing crime in the world.37 Sex trafficking
falls under the umbrella of human trafficking, and can occur even without any physical
transportation of the victim, as long as the individual is forced to act without their consent and
against their will.38 The Trafficking in Persons Report further defines severe sex trafficking as
"trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which
the person induced to perform such an act has not attained 18 years of age."39 According to the
International Labour Organization, around 20.9 million men, women, and children are currently
31 Gill, supra note 14, at 358.
32 Id. at 358-59.
33 Zifcak, supra note 18, at 80.
34 Ved P. Nanda, The Future Under International Law of the Responsibility to
Protect After Libya and Syria, 21 MICH. ST. INT'L L. REV. 1, 18 (2013).
35 Id. at 19.
36 Lee, supra note 6, at 385.
37 Id. at 383.
38 U.S. DEP'T OF STATE, supra note 8, at 6.