El Salvador’s Femicide Crisis

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Winter Issue 2019

Written by: Sophie Huttner, Yale ’22

By the time a Salvadoran woman turns thirty, she will more likely than not have experienced gender-based violence.[1] This is the grim reality of life in a country where 67.4% of women report having experienced at least one instance of gender-based violence in their lifetimes, and 45.8% of women under thirty report having been abused within the last twelve months.[2] Even more grim is the fact that these staggering statistics on gender violence account only for the “lucky” ones—that is, those who survive the abuse. Women who do not survive—victims of femicide, or gender-based homicide—are all too numerous. One woman is murdered by a man every 24 hours in El Salvador, making for the highest rate of femicide in the world.[3] This paper will address the nature of El Salvador’s femicide epidemic, its causes, and the impact of increased rates of femicide on both Salvadoran society and on United States security. It will also report and analyze the ways that the Salvadoran government has attempted to manage this crisis, and the current impact of US policy on rates of femicide and on the safety of Salvadoran women.

The Nature and Scope of the Problem

Article 45 of a 2011 Salvadoran Law defines femicide as the murder of a woman where “the motives [of her murder] are hatred or contempt for her status as a woman.”[4] Such motives are often difficult to identify, but may manifest in the context of the murder, the identity of the killer (a male family member, or a current or ex-domestic partner), and the nature of the killing (where and how the woman is wounded, how her body is disposed of, whether the victim was raped prior to being murdered). Nevertheless, the difficulty of categorizing femicides, and the reticence of Salvadoran law enforcement in reporting these murders as gender-based, means that the statistics available for gendered homicides are likely underestimated.[5] Furthermore, femicide statistics fail to account for forced disappearances of women and girls, despite the fact that 209 disappearances of women and girls were reported in the first five months of 2018 alone.[6] Even so, El Salvador’s officially recorded femicide rate stands out from countries around the world, not only because it is the world’s highest, with 13.49 deaths per one hundred thousand women, but also because it has risen significantly in recent years.[7] According to the Observatory on Gender Violence, femicide rates more than doubled between 2013 and 2017, with 218 femicides a year rising to 520. 

Salvadoran femicides are also notable for the shocking impunity with which they are carried out. A 2018 study found that only 5% of femicide cases brought to court end in a sentence, and only 3% of cases carry a guilty verdict.[8]Given that many cases never make it to court, this statistic likely underestimates the true extent of impunity. A 2009 report by the United Nations Special Rapporteur on Violence Against Women reflects the fact that few cases ever result in the trial of an alleged perpetrator. The report analyzed 164 femicides reported in four major national newspapers from January to June 2009 and found that “perpetrators were only identified in 14 of the above murders, despite the presence of witnesses at the crime scene in at least 41 percent of cases.”[9] Though rates of impunity for femicides are high all across Latin America, the situation in El Salvador is particularly challenging and tragic.

The Causes of Femicide 

El Salvador’s femicide crisis is fueled by an ingrained culture of virulent machismo, high levels of gang and narco-violence, and a corrupt, unaccountable police force, untrained in the appropriate handling of gender violence cases. Machismo permeates every sector of society, not only as a central tenet of gang culture but also as an ideology deeply embedded in law enforcement, including among both police and judges. Cecilia Menjivar, an expert on gender violence in El Salvador, writes: “[m]ost men and many women in El Salvador believe that domestic violence is normal; it is what men do…Women are treated as property…[and] women must accept their role in the home, which includes demands for sex and physical abuse.”[10]

The normalization of violence against women is, in part, a product of the nation’s recent history. In 1979, Carlos Humberto Romero, the dictator of El Salvador, was pushed out of power by a junta of reformist politicians and officers. As living conditions failed to improve under the new government, and right wing paramilitary groups perpetrated increasingly worse human rights violations, a leftist coalition, the Farabundo Martí National Liberation Front (FMLN), formed an army to oppose the government and paramilitary forces. El Salvador’s government was soon embroiled in what would be a brutal twelve-year civil war against the FMLN insurgents. Seeking to prevent the rise of communism in Latin America, the United States sent one to two million dollars a day in support of the right-wing military.[11]

A gruesome part of the US-funded Salvadoran military strategy against the FMLN was the shockingly brutal rape and torture of civilian women. The Salvadoran Civil War thus contributed to a pattern of extreme gender violence that would shape the nation for decades to come. In her book, State-Perpetrated Wartime Sexual Violence in Latin America, Michele Leiby details one 1981 massacre in El Mozote, Morazán: “The soldiers of the Atlacatl battalion separated the men from the women and the children of the community. The women were taken to the nearby hills where they were raped (perhaps gang raped) before all of the residents were systematically executed.”[12] This massacre would later become a rallying cry for human rights advocates in the region. But at the time, the systematic rape, and often mutilation, of women was a routine part of wartime violence. In her book Rape During Civil War, Dara Kay Cohen writes, “One human rights advocate who was an activist during the [Salvadoran] war recalled that of the women who founded a prominent organization, ‘all of their daughters were raped.’ This [activism] was dangerous work during the war.”[13] The high-profile rape and murder of four American churchwomen was also attributed to the El Salvadoran National Guard. 

Though the war ended almost three decades ago, El Salvador has yet to confront this legacy of gender violence. Just this year, the country passed a “National Reconciliation Law” that all but guarantees impunity for war crimes including rape committed during conflict or wartime.[14] As most of the men who were either perpetrators or witnesses of wartime sexual violence remain alive and free, the legacy of the Civil War continues to impact Salvadorian society through the normalization of contemporary sexual violence and gendered homicide in El Salvador. 

The machista ideology shows no signs of lessening among El Salvadoran youth, who were born after the end of the war. One 2018 OXFAM survey found more than half of young Salvadoran men aged 15-19 believe “women endure violent relationships because they believe violence in a relationship with a man is normal.” Eighty-five percent of young men agreed that “a decent woman should not dress provocatively, nor be out on the streets late at night.” [15]  Such beliefs make it easier to blame male violence on the actions of women. These widespread attitudes thus make it particularly difficult for women to access social support to leave an abusive relationship. Women who face sexual and physical violence are often said to be deserving of it; families and the police see domestic violence as “just the way things are.” Too many abusive relationships end in femicide instead of breakups, owing to insufficient intervention and a lack of social support prior to the woman’s death.

Social isolation for women facing physical and sexual abuse is compounded by a police force that fails to recognize domestic violence as a crime and does little to protect women from their abusers. Indeed, The Organization of Salvadoran Women for Peace in El Salvador (ORMUSA) found in 12 percent of the cases of violence against women, “the perpetrators were the judges, prosecutors, lawyers, or police officers in the communities in question.”[16] One Salvadoran woman was asked if she had ever considered calling the police on her abuser. She responded, “The police? Who would think of calling the police back there [in El Salvador]?. . .Everyone will laugh if a woman calls for help if her husband is beating her.”[17] The Observatory of Gender Violence against Women reports at least six women murdered in 2012 were murdered by partners who were serving police officers.[18]

Widespread gang violence is another contributor to the epidemic of femicides in El Salvador. Agnes Callamard, the United Nations’ Special Rapporteur on Extrajudicial Killings, describes this phenomenon in a 2018 CNN report: “[B]odies are treated as a territory for revenge and control. Gangs are male-dominated and girls and women are parts of the territories they control.”[19] If a woman tries to leave a relationship with a gang member, or if she refuses to have sex with a gang member, the result is all too often violent retribution. Violence against women is a part of how gangs retain control over communities and intimidate those who challenge their power. This is why the government of El Salvador has primarily blamed gangs for the epidemic of femicide. “The rise in violent deaths of women in recent years coincides with the entry of these gangs,” said David Munguía, Minister of Justice and Public Safety.[20] Yet, though gangs certainly drive violence against women, it is important not to overemphasize gang perpetration of femicides over other perpetrators, particularly men previously known to the victims. The United Nations Special Rapporteur on Violence Against Women reflected on a 2009 investigation of femicides in El Salvador: “The fact that only seven murders [out of 164 analyzed] were clearly associated with gang members and that the majority of identified perpetrators were men known to the victims contradicts some official claims that gangs are the primary perpetrators of such crimes.”[21]  Clearly, for female partners of gang members, intrafamilial violence and gang violence gruesomely intersect.

Legislative Developments to Combat Femicide; Strengths and Weaknesses

In 1995, El Salvador signed the Inter-American Convention on the Prevention, Punishment and Eradication of Violence Against Women, proclaiming the right of all women to “a life of dignity and free of violence.” Fifteen years after signing onto the convention, El Salvador still faced rising femicide rates. Under pressure from human rights activists, the Salvadoran government began a series of meaningful legislative attempts to ameliorate the crisis. 

In 2011, the Salvadoran government (under their first leftist president since the war, Mauricio Funes) passed a remarkably progressive law entitled “For a Life Free of Violence Against Women.” The legislation criminalized all forms of violence against women, “from female murders (with 20-35 years of imprisonment for those convicted), to mocking, disparaging or isolation of women in their workplaces, communities or schools (with punishments such as fines of between 2-25 times the national monthly minimum wage, or community work).”[22] The document also contains dozens of articles aimed at combatting the misogyny that women encounter in courtrooms. It prohibits discriminating against women in proceedings based on “sexual history,” and it outlaws court-mandated reconciliation or mediation efforts, which are widely seen as grossly ineffective among Salvadoran women. Referencing those now outlawed programs, Menjivar writes, “rather than men being punished for their abuse, the mediation process…teaches women how to cope with an abusive man.”[23] Thus, the prohibition of court-mandated reconciliation is a particularly meaningful and positive step in combatting Salvadoran gender violence. Finally, the law encourages the creation of programs that seek to help people “unlearn conventional models…and learn a new model based on equality, equity, diversity, and democracy.” An effort to change the culture around gendered violence is a necessary component of any policy aimed at ending femicide. It is also perhaps the most difficult, and as evidenced by continued machista attitudes amongst young Salvadoran men,[24] re-education initiatives have a long way to go. Still, the goals laid out in the 2011 law are admirable and indicate a will for progress. 

Nevertheless, as a result of severely inadequate funding, and, in some areas of law, plain bureaucratic resistance toward enforcement, the full implementation of the laws has been slow and remains incomplete. Since the law does not legally appropriate new funds to proposed projects, some promised programs either insufficiently serve the needs of the population or have yet to materialize. For example, despite legislative commitments to establish women’s shelters across the country, the government has only created two such shelters, both with extremely limited capacities (one accommodates only 15 women).[25] Moreover, the 2011 law has had little short-term impact on reported femicide rates. In fact, in the years after its passage, the rate of femicide in El Salvador has increased, not decreased. 

Since then, the Salvadoran government has endeavored to improve upon its previous efforts. In 2017, a group of specialized courts was created for dealing with femicides and other forms of violence against women. Its purpose was to remove proceedings from patriarchal institutions that have typically failed to punish male perpetrators in the past. Judges in these specialized courts are trained by the government to avoid biased behavior. Glenda Baires, an appointed judge to one specialized court, spoke to a reporter about her aspirations for the new system: “My hope is that … the women who today will be our initial users can convey to their daughters that there’s no longer a culture of enduring violence.”[26] The purview of these courts, however, is surprisingly limited, as it excludes both sexual and intrafamilial violence, the two most common forms of violence against women. Furthermore, there are only six established courts, located in only three departments, meaning that women in rural areas have geographical challenges in accessing specialized court systems. Another major issue is that the court system is arranged in such a way that a woman must go to an ordinary court prior to being heard in a specialized court, thus allowing ordinary court proceedings to undermine the avowed purpose of the specialized courts.[27]

In conclusion, while El Salvador continues to make some legislative progress toward preventing femicide and ending widespread impunity for abuse and violence against women, the reality faced by the average Salvadoran woman is changing substantially slower. Femicide rates remain extremely high, and the limited scope of anti-violence programs–along with a serious lack of funding and systemic resistance on the judicial and law enforcement level–mean that even the most progressive laws can only do so much.

US Policy and Security Concerns

The United States government should be deeply concerned about the ongoing crisis of femicide in El Salvador. Not only does the crisis represent an egregious violation of human rights, but it is also a major security concern, as widespread femicide both destabilizes El Salvador and fuels mass migration toward our southern border. According to a study from the Icahn School of Medicine at Mount Sinai, in 2016 alone, 65,000 women from El Salvador, Honduras and Guatemala “fled gender based violence…and attempted to seek asylum in the USA.”[28] Salvadoran petitioners represent one of the largest groups of U.S asylum grants, second only to those from China.[29] The massive influx of female asylum seekers from the region, combined with a new presidential administration, has led to several fundamental changes in the last two years regarding US policies meant to address femicide in El Salvador. 

Prior to the Trump Administration, USAID programs had proven effective in El Salvador, particularly in the United States’ efforts to prevent violence against women. Notable examples are the seven “assistance centers” for victims of gender-based violence created and run with the help of US foreign assistance. The centers “provide services ranging from medical treatment and psychological counseling to legal representation and vocational training,” and are, according to the USAID website, “among the first multi-institutional, fully integrated domestic violence service providers in Central America.”[30]  USAID reports that these shelters have been remarkably effective in reducing impunity rates for perpetrators of violence against Salvadoran women. A sample study in one of the centers found that out of 99 domestic violence cases taken on by the center, 97 resulted in convictions.[31] Compared to a national 95% impunity rate for cases involving violence against women, the success of this program is astounding. Locally based violence-prevention projects have also seen impressive results. According to USAID, between 2015 and 2017, “El Salvador saw a 61 percent reduction [in murders] in the municipalities in which USAID operates. This compares to a 42 percent reduction nationwide.”[32]

Yet, the Trump administration has placed the future of these USAID projects in question by severely cutting the amount of aid sent to El Salvador. From 2017 to 2018, aid to El Salvador was cut almost in half–from 88 million to 46 million USD a year–with much of the remaining funds redirected to programs for border and drug control. Requested funding for human rights program went from 46% of the budget to 32% of the budget. Funding for programs meant to combat violence against women dropped from $2.3 million in 2017 to $600,000 the following year.[33] With such a small operating budget to handle the largest femicide crisis on the planet, effective programs like the aforementioned US-funded assistance centers are in jeopardy. In April 2018, the Trump administration decided to freeze all funding to El Salvador, Guatemala, and Honduras, due to their failure to prevent migration.[34] The move alarmed many lawmakers who believe that continued aid is vital to US security, contributing to decreased migration rates in those areas which are beneficiaries. The president resumed a small fraction of aid in June 2019, but the immediate future of US-funded anti-violence programs in El Salvador remains in question. 

Meanwhile, changes to domestic policies on asylum have done little to relieve Salvadoran women trying to escape extreme violence. In June 2018, US Attorney General Jeff Sessions overrode an asylum grant for a woman fleeing domestic violence in Guatemala, claiming that “married women in Guatemala who are unable to leave their relationship” does not count as a particular social group under asylum law.[35] Sessions then used that decision to issue a new policy, writing “[g]enerally, claims by aliens pertaining to domestic violence or gang violence perpetrated by non-governmental actors will not qualify for asylum.” [36] His logic: domestic violence is perpetrated by an individual, not by the government as asylum laws specify must be the case. A study of gender violence in the region shows how misguided this argument is. Epidemics of gender violence and femicide are a deeply institutional problem, a crime abetted by a judicial and political system unable and often unwilling to step in. In December of 2018, Session’s policy barring migrants from seeking asylum on the basis of domestic violence was overturned by a US District Judge. 

Nonetheless, the future of almost all Salvadoran asylum applicants remains in doubt. On September 19th, the Trump administration signed a deal that paved the way for a “safe third country” agreement with El Salvador. The United States will now require migrants who passed through El Salvador on their way north to first apply for asylum there. Though this particular policy will not affect native Salvadoran asylum seekers, similar safe-third-country agreements with Honduras and Guatemala (2nd and 4th worst in Latin America for femicides, respectively) will force fleeing Salvadoran women to settle in countries not much safer for vulnerable women than their own.[37] The Associated Press reported that El Salvador signed onto the deal in hopes that it would result in resumed aid to the region. Alexandra Hill Tinoco, El Salvador’s foreign minister, commented that the deal “has to be a real partnership.”[38]

In October of 2019, Trump fulfilled his end of the agreement: aid was restored to El Salvador, Guatemala, and Honduras, in exchange for their actions to stem the flow of asylum seekers north. Yet the end result of the deal put Salvadoran women in a significantly worse position than that which they were in before. Moreover, the mere fact that the United States is trying to designate El Salvador as a “safe third country” for female migrants represents a complete denial of the extreme dangers women face in El Salvador—dangers detailed by their own human rights reports. The US State Department’s 2018 Human Rights Report describes the situation for Salvadoran women, stating “[Salvadoran l]aws against rape were not effectively enforced… Laws against domestic violence remained poorly enforced, and violence against women… remained a widespread and serious problem.”[39] With Salvadoran asylum grants largely blocked in the United States, along with decreased anti-violence funding from USAID, El Salvador’s women have little recourse against the high rates of gender violence and widespread impunity that plague their country, and the United States is doing very little to help them.

Conclusion

While El Salvador has made genuine legislative progress in the last decade, their solutions have thus far suffered from deep structural flaws, inadequate funds for implementation, and most pervasively, widespread cultural norms that condone violence against women. The United States has always been intimately connected to the Salvadoran femicide epidemic. Its historic support of paramilitary forces that condoned and perpetrated the mass rape and murder of civilian women during the nation’s civil war contributed to the contemporary femicide epidemic now rebounding as a national security concern to the US. Violence against women is both an effect and a driver of the destabilization plaguing northern Central American countries and of the droves of desperate migrants arriving at our southern border. Clearly, any viable solution must combine national security interests with a respect for fundamental human rights. What is required is a sustained effort to strengthen law enforcement institutions in El Salvador and to shift national cultural attitudes. At the present moment, it seems that neither El Salvador nor the United States are fully prepared to make that happen.


Works Cited

[1]Encuesta Nacional De Violencia Contra La Mujer, El Salvador 2017. Dirección General De Estadística y Censos, 2017. Gender based violence is defined as psychological, physical, sexual, economic, or an attempted femicide against a woman committed in public or in the home. Statistics are from the National Survey of Violence Against Women, conducted by the El Salvadoran government in 2017.

[2]Ibid.

[3] Nugent, Ciara. “Violence in El Salvador Is Driving Women to the U.S. Border.” Time, Time, time.com/5582894/gender-violence-women-el-salvador/.

[4] DECRETO No 520. ASAMBLEA LEGISLATIVA – REPUBLICA DE EL SALVADOR, 4 Jan. 2011, es.scribd.com/document/398012177/Trabajo-zCompleto-2018.

[5] Recinos, Marvin, et al. “In the Region’s Most Violent Country, Killings of Women Pushed Aside.” Univision, 3 Apr. 2018

[6] Observatorio De Violencia De Género Contra Las Mujeres, May 2018, http://observatoriodeviolencia.ormusa.org

[7] “Un 67% De Las Mujeres Ha Sufrido Algún Tipo De Violencia En El Salvador | Noticias ONU.” United Nations, United Nations, news.un.org/es/story/2018/04/1431372.

[8] Observatorio De Violencia De Género Contra Las Mujeres, May 2018, http://observatoriodeviolencia.ormusa.org/boletinas/2018-0506_BOLETINA_VG.pdf

[9] El pecado de nacer mujer: Informe sobre el femicidio en El Salvador”, Instituto de Estudios de la Mujer Norma Virginia Guirola de Herrera, January – July 2009

[10] Menjivar, Cecilia. The Status of Women in Domestic Relationships in El Salvador. Arizona State University, 28 Aug. 2014.

[11] Donovan, Louise, and Christina Asquith. “El Salvador Kills Women as the U.S. Shrugs.” Foreign Policy, 7 Mar. 2019, foreignpolicy.com/2019/03/07/el-salvador-kills-women-as-the-us-shrugs/.

[12] Leiby, Michele. “State-Perpetrated Wartime Sexual Violence in Latin America.” UNM Digital Repository, digitalrepository.unm.edu/pols_etds/4/.

[13] Cohen, Dara Kay. Rape during Civil War. Cornell University Press, 2016.

[14] “OAS – Organization of American States: Democracy for Peace, Security, and Development.” IACHR Notes with Concern the Passage of the National Reconciliation Bill in El Salvador, Which Contains Provisions Contrary to Human Rights, 21 May 2019, www.oas.org/en/iachr/media_center/PReleases/2019/123.asp.

[15] “Young People in Latin America Still Think Violence against Women Is ‘Normal.’” Oxfam, 25 July 2018, www.oxfam.org/en/pressroom/pressreleases/2018-07-25/young-people-latin-america-still-think-violence-against-women.

[16] “Femicide and International Women’s Rights.” Global Americans, https://theglobalamericans.org/reports/femicide-international-womens-rights/

[17]  Menjivar, Cecilia. The Status of Women in Domestic Relationships in El Salvador. Arizona State University, 28 Aug. 2014.

[18] Lakhani, Nina. “Violence against Women Rises in El Salvador.” El Salvador | Al Jazeera, Al Jazeera, 7 June 2013, www.aljazeera.com/indepth/features/2013/06/20136493135956422.html.

[19] Walsh, Nick Paton. “Gangs in El Salvador Use Women’s Bodies for ‘Revenge and Control’.” CNN, Cable News Network, 14 June 2018, www.cnn.com/2018/06/14/americas/el-salvador-gangs-women-intl/index.html.

[20] “El Salvador Tiene La Tasa De Feminicidios Más Alta Del Mundo.” Elsalvador.com, 5 Mar. 2013, historico.elsalvador.com/historico/102949/el-salvador-tiene-la-tasa-de-feminicidios-mas-alta-del-mundo.html.

[21] Manjoo, Rashida. “Report of the Special Rapporteur on Violence against Women, Its Causes and Consequences.” Follow-up Mission to El Salvador*, United Nations Human Rights Council, 14 Feb. 2011.

[22] “Global Database on Violence against Women.” Law for a Life Free of Violence against Women, 2011, evaw-global-database.unwomen.org/en/countries/americas/el-salvador/2011/law-for-a-life-free-of-violence-against-women–2011-.

[23] Menjivar, Cecilia. The Status of Women in Domestic Relationships in El Salvador. Arizona State University, 28 Aug. 2014.

[24] “Young People in Latin America Still Think Violence against Women Is ‘Normal.’” Oxfam, 25 July 2018, www.oxfam.org/en/pressroom/pressreleases/2018-07-25/young-people-latin-america-still-think-violence-against-women.

[25] Musalo, Karen. EL SALVADOR–A PEACE WORSE THAN WAR: VIOLENCE, GENDER AND A FAILED LEGAL RESPONSE. Yale Journal of Law & Feminism, 2018.

[26] Moloney, Anastasia. “Judge at New El Salvador Women’s Courts Ready to Tackle Gender Violence.” Reuters, Thomson Reuters, 24 Aug. 2017

[27]  Musalo, Karen. EL SALVADOR–A PEACE WORSE THAN WAR: VIOLENCE, GENDER AND A FAILED LEGAL RESPONSE. Yale Journal of Law & Feminism, 2018.

[28] Nugent, Ciara. “Violence in El Salvador Is Driving Women to the U.S. Border.” Time, Time, time.com/5582894/gender-violence-women-el-salvador/.

[29] Bray, Ilona, and J.d. “Which Countries Do Most People Granted Asylum in the U.S. Come From?” Www.nolo.com, Nolo, 20 Jan. 2017, www.nolo.com/legal-encyclopedia/which-countries-do-most-people-granted-asylum-the-us-come-from.html.

[30] “Preventing and Responding to Gender-Based Violence.” U.S. Agency for International Development, 7 May 2019, www.usaid.gov/gbv.

[31] Albaladejo, Angelika. “How Violence Affects Women in El Salvador.” How Violence Affects Women in El Salvador | Security Assistance Monitor, 22 Feb. 2016, securityassistance.org/blog/how-violence-affects-women-el-salvador.

[32] “USAID/El Salvador Country Fact Sheet. USAID, July 2018, www.usaid.gov/sites/default/files/documents/1862/El_Salvador_External_Fact_Sheet_July_2018.pdf.

[33] “El Salvador Foreign Assistance.” El Salvador | ForeignAssistance.gov, Department of State and USAID, www.foreignassistance.gov/explore/country/El-Salvador.

[34] McDonnell, Tim. “Trump Froze Aid To Guatemala. Now Programs Are Shutting Down.” NPR, NPR, 17 Sept. 2019, www.npr.org/sections/goatsandsoda/2019/09/17/761266169/trump-froze-aid-to-guatemala-now-programs-are-shutting-down.

[35] Matter of A-B-, Respondent. The United States Department of Justice, Office of the Attorney General, 2018, www.justice.gov/eoir/page/file/1070866/download.

[36] Ibid.

[37] “Femicide and International Women’s Rights.” Global Americans, https://theglobalamericans.org/reports/femicide-international-womens-rights/

[38] Long, Colleen. “US, El Salvador Sign Asylum Deal, Details to Be Worked Out.” AP NEWS, Associated Press, 20 Sept. 2019, www.apnews.com/de6a00632755415fad2a952c7cd4bd72.

[39] EL SALVADOR 2018 HUMAN RIGHTS REPORT. US Department of State, 2018, www.state.gov/wp-content/uploads/ 2019/03/EL-SALVADOR-2018.pdf.

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