The War on Syrian Girls 225
behavior, entitled the "Responsibility to Protect."66 The doctrine states that, if a state fails to
exercise their responsibility to prevent mass atrocity crimes, the international community may
assume a corresponding duty to protect the civilians from crimes against humanity.67 However,
when the United Nations attempted to intervene in the fighting between government and rebel
forces in Libya in 2011, the number of civilian casualties increasingly worsened.68 The United
Nations' Security Council and Human Rights Council condemned the human rights abuses being
committed in Libya, and ultimately imposed a resolution that neutralized the Libyan air force
and halted the rebel forces moving on Benghazi.69 However, the Security Council still faced
difficulty in persuading different rebel groups to hand in their arms in Libya.70 The
Responsibility to Protect doctrine is thus difficult to enforce in many countries during times of
rebellion uprising and violence against civilians.71
B. The Sex Trafficking Crisis in Syria and its Female Minor Victims
The United States Department of State classifies countries into three tiers based on the extent
of government action to combat trafficking, ranked from full compliance at "Tier 1" to minimum
compliance at "Tier 3."72 Among these types of countries, in which various forms of human
trafficking often take place once rebellion forces cause chaos and attack the government, Syria
falls into the category of "Tier 3" countries.73 These countries are classified as woefully
inadequate in assisting with prosecuting traffickers and rescuing victims.74 Syrian children,
specifically young girls, are currently targeted by predators and sex traffickers across the world
as they attempt to escape the civil war occurring in their home country.75Syrian civilians that
could not escape the country have been subjected to horrible traumas at the hands of Syrian
soldiers, ISIL,76 and, oftentimes, their own government officers.77 Women and girls are targeted
by "both governmental and pro-government forces, as well as armed groups opposed to the
government, such as extremist groups like [ISIL]."78 They are often violated in the form of
sexual assault, torture, harassment, and sensory and physical deprivation.79 A recent Human
Rights Watch report reveals that the absence of men in many areas of the country, who are either
fighting against the rebellion or kidnapped by extremist groups, leaves their female family
66 Zifcak, supra note 33, at 59.
68 Id. at 61-62.
69 Id. at 68-70.
70 Id. at 71.
71 Zifcak, supra note 33, at 71.
72 U.S. DEP'T OF STATE, supra note 8, at 10-14.
73 Id.; U.S. DEP'T OF STATE, TRAFFICKING IN PERSONS 2015 REPORT: COUNTRY NARRATIVES,
https://www.state.gov/j/tip/rls/tiprpt/countries/2015/243543.htm (last visited May 28, 2017).
74 Id. at 12.
75 See generally Bulut, supra note 5; Kareem Shaheen, Dozens of Syrians forced into sexual slavery in derelict
Lebanese house, GUARDIAN (April 30, 2016, 2:00 PM), https://www.theguardian.com/world/2016/apr/30/syrians-
76 ISIS is also referred to as ISIL. Gill, supra note 14, at 359.
77 Davaine, supra note 7.