“To be accepted, to be recognized, you have to do the impossible. You have to be Zidane.” This sentiment is commonly felt by Algerian immigrants living in France, that the only way to become accepted as part of the French nation is to succeed at the highest level like their greatest icon Zinedine Zidane did at the FIFA World Cup. After leading the French to a World Cup Championship in 1998, the son of Algerian immigrants was declared “President Zizou” by crowds of adoring Frenchmen. However, for the millions of Algerian immigrants that could not lead the French to glory on the pitch, acceptance is far more challenging, due to over a century of cultural tension between France and Algeria that defies the French demand for cultural assimilation. The evolution of the cultural exchange and relationship between France and Algeria demonstrates the importance of tension in driving cultural exchange, while revealing both the frontiers and limitations of global citizenship and offering a model for how nations can foster cooperation through difference. 

In 1848, Algeria was officially declared as French territory, beginning 114 years of rule defined by a policy of cultural assimilation. One of the major pillars of this assimilation policy was the suppression of Islamic institutions, demonstrated through the Senatus-consulte of July 14, 1865 that offered citizenship on the condition of rejecting Islamic law. This was done in an attempt to “civilize” the Algerian people, consistent with broader European colonial practices. 

By the 1930s, the Arabic cultural revival began, through the Association of Algerian Muslim Ulema, arising in direct response to French cultural policy. This growing tension led to the Algerian War of Independence (1954-1962), a conflict with profound cultural and political ramifications. Algeria’s independence did not end its cultural relationship with France but rather allowed for Algeria to redefine how that relationship existed for the first time. The new Algerian government’s first attempts at reorienting this relationship were through the policy of Arabization, which involved suppressing and reducing the impact of the French culture and language that remained in Algeria. However, these efforts proved as unsuccessful as France was in assimilating the Algerian people. As a result, the Algerian-French cultural relationship came to be characterized by a syncretic culture and identity formed around both French and Algerian practices. 

Following Algerian independence in 1962, waves of Algerian migrants settled in France, primarily in urban banlieues (communities on the urban periphery), in search of economic opportunity. Their children, known as the beur generation, were raised with Algerian cultural traditions but surrounded by French society, leaving them caught between two distinctly different identities. Nevertheless, the beur generation quickly became a powerful cultural force in France, challenging France’s model of cultural assimilation. This was exemplified through the rise of Verlan, a form of French slang. Though Verlan predates Algerian immigration, it gained cultural momentum when Algerian immigrants blended Arabic influences with French terms in an effort to resist assimilation into mainstream French society. However, even as Verlan was originally intended to resist the traditional French language, many Verlan terms began to become accepted as part of the French language. Words such as keuf (cop), tepo (buddy), and relou (annoying) have seen a rise in usage outside of Verlan’s traditional informal immigrant contexts. Consequently, words like meuf, derived from femme, have become so absorbed into mainstream French that younger speakers re-inverted it as feumeu, showing how the tension between cultures continues driving linguistic evolution. 

This cultural dynamism extended beyond language, as the post-independence migration waves to France brought their music with them, with the most culturally significant being raï.

This musical form began in Algeria in the early 20th century, combining both Arab and European influences, and when raï reached France, it crossed social barriers, transcending its immigrant origins to reshape French popular music and propel Algerian artists like Cheb Khaled and Cheb Mami to fame in France and worldwide. A central figure in raï’s evolution was Rachid Taha, a fellow Algerian-born artist who became known for fusing rock and punk music with traditional raï. One of his best-known songs was Rock El Casbah, an Arabic cover of the Clash’s song Rock the Casbah, which contributed to the growth of raï music as an international genre consumed worldwide, illustrating the global reach of the French-Algerian cultural exchange. Taha, who requested to be buried in Algeria instead of France, captured the duality of his identity in his autobiography, writing “Algérien pour toujours, et Français tous les jours” – French every day, but Algerian forever. His identity, neither fully French nor Algerian, embodied the same tension that defined both raï and the beur generation as a whole. For its impact in bridging cultural boundaries, raï was recognized by UNESCO as part of their Representative List of the Intangible Cultural Heritage of Humanity in 2022. Together, Verlan and raï represent the creative output of a people who were caught between two distinct worlds, contributing to a cultural identity that cannot be defined by a single state. 

The beur generation and their descendants occupy a unique cultural space, one where they are too French for Algeria and too Algerian for France, yet their identity is shaped by both countries. Their experiences embody a real-world approximation of global citizenship, which is the idea that a person’s identity can transcend the traditional cultural constraints of geography and political borders. Importantly, this concept does not require the rejection of national identity, but rather placing national identity secondary to a broader sense of shared humanity. The beur generation and their descendants partially reflect this: they are neither fully French nor fully

Algerian, but rather a hybrid culture that transcends the borders of both nations. However, contrary to the idealized version of global citizenship, beur and French-Algerian identity does not fully transcend nationality altogether; instead, the nations of both France and Algeria matter deeply. This space was not created by intentional design, but rather through centuries of continued cultural tension between France and Algeria, demonstrated through the rise of Verlan and raï. Ultimately, true global citizenship, as defined in theory, is likely unattainable in the near future, but France and Algeria’s cultural relationship shows what the benefits of a limited application of the concept can be. 

The most valuable lesson from the cultural exchange between France and Algeria is the importance of tension. The development and expression of beur culture, seen through Verlan and raï, was only able to occur due to the tension between the French cultural expectation of assimilation and Algerians resisting that expectation. Both France and Algeria originally failed in creating productive space for tension, with the French colonial forced assimilation policies and the post-independence Algerian Arabization efforts. By forcing culture upon their people, both governments left no space for productive cultural exchange to emerge. Instead, countries need to create conditions where this dynamic can exist. This can be done through sustained cultural contact, based on voluntary exchange rather than the coercion of previous assimilation policies. Rather than repressing other cultures, countries need to create spaces where their cultures can be challenged, reframed, and adapted. The unresolved tension between France and Algeria offers a lesson for other post-colonial states in how to navigate their own colonial friction, suggesting that productive exchange does not require complete historical reconciliation, but instead space for that tension to generate new identities. This has major implications for cultural diplomacy, which currently relies on using the exchange of cultural ideas and practices to build bonds

between countries. However, through tension, these bonds could be made stronger if each culture was able to challenge the assumptions of the other, creating the space for a new, shared identity to emerge that can link countries closer than ever before. 

28 years after his father led the French to World Cup glory, Luca Zidane heads to North America for the World Cup, not as a Frenchman, but as an Algerian. The 28-year-old goalkeeper made the decision to represent Algeria over his birth country of France at the 2026 FIFA World Cup, saying “We’ve lived in an Algerian culture since we were small. It’s an honor to play for Algeria.” Luca Zidane’s choice embraced his unique identity as someone who is neither fully French nor Algerian. While his father represented the unrealistic standards that many Algerian immigrants faced in their efforts to assimilate, the younger Zidane represents a transnational identity that does not have to assimilate to either culture. 

France and Algeria reveal that cultural exchange and the potential for global citizenship can emerge from tension expressing itself in unexpected ways, which leads to the type of transnational identity that allows for the son of a French hero to play for the country his grandparents emigrated from.

References: 

Featured/Headline Image Caption and Citation: Algerian embassy in France | Image sourced from Wikimedia Commons | CC License, no changes made

Britannica Editors. “FIFA World Cup Legends: Zinedine Zidane, Master of the Midfield.” Encyclopedia Britannica, June 20, 2026. https://www.britannica.com/biography/Zinedine-Zidane.

Britannica Editors. “raï.” Encyclopedia Britannica, November 6, 2015. https://www.britannica.com/art/rai-musical-style.

Ismail, Donia. 2025. “Zinedine Zidane and the Myth of ‘the Good Arab.’” GQ Middle East. May 16, 2025. https://www.gqmiddleeast.com/article/zinedine-zidane-the-good-arab. 

Gitto, Andrew. 2026. “Why Does Luca Zidane Play for Algeria? Son of French Great Zinedine Zidane Is Starting Goalie for African Side.” Sportingnews.com. June 17, 2026. https://www.sportingnews.com/us/soccer/news/why-does-luca-zidane-play-algeria-zinedi ne-zidane/d72f374cb8477eeaf24d4490. 

Gündoğdu, Badra. 2024. “Citizenship of Algerians During the French Colonial Period Between 1865 to 1919”. Sosyal Ve Kültürel Araştırmalar Dergisi (SKAD) 10 (20): 39-49. https://doi.org/10.25306/skad.1440060. 

“La Banlieue: Verlan et Argot.” 2020. Elon.io. 2020. https://elon.io/grammar/french/regional/banlieue-and-verlan.

Lefkowitz, Natalie J. 1989. “Verlan: Talking Backwards in French.” The French Review 63, no. 2 : 312–22. http://www.jstor.org/stable/394763. 

Manby, Christine. 2018. “Rachid Taha: French Musician Whose Algerian Roots Were Both an Inspiration and an Impediment | the Independent.” The Independent. September 18, 2018. https://www.independent.co.uk/news/obituaries/rachid-taha-died-french-musician-algeria n-rock-the-casbah-the-clash-a8541931.html. 

Mohamed, Rana Noor. 2021. “Negotiating Alternative Linguistic Practices: The Struggle between Verlan Usage and the Académie Française – Makings Journal.” 

Makingsjournal.com. August 5, 2021.https://makingsjournal.com/negotiating-alternative-linguistic-practices-the-struggle-betw een-verlan-usage-and-the-academie-francaise/.

“UNESCO – Raï, Popular Folk Song of Algeria.” n.d. Ich.unesco.org. https://ich.unesco.org/en/RL/rai-popular-folk-song-of-algeria-01894.

Zaimeche, S., Brown, L.C., Sutton, K., Chanderli, A.K. “Algeria.” Encyclopedia Britannica, June 28, 2026. https://www.britannica.com/place/Algeria.

Czechoslovakia and Vietnam: an unplanned citizenship

If you take the red metro line from central Prague to Kačerov station, change to bus 113, ride twelve stops south through housing estates and warehouses, and step off at Sídliště Písnice, you will come across the address Libušská 126. There is no English signage. The complex was built on the site of a former meat-packing plant that closed in 1999; on the grounds of a one-time poultry farm, the smell of pho now rises from stalls that once held slaughtered chickens. This is Sapa, the Vietnamese marketplace of Prague: twenty-five hectares of vendors, a Buddhist temple, a wedding hall, a kindergarten, several gambling rooms, a recording studio, and the third generation of a Vietnamese community that first entered Czechoslovakia in 1967. Neither the market nor the community were planned by the state, and yet they remain an illustrative example of how durable cultural integration and international cooperation can be in post-Communist Europe, revealing that cultural relationships extend far beyond treaties. 

The Czechoslovak-Vietnamese labour exchange began as a Vietnam War-era arrangement: in lieu of paying for Semtex and other military aid, Hanoi sent workers, as the historian Alena Alamgir documents from Czechoslovak archives. The first cohort of 2,100 arrived in June 1967 to train in heavy industry, chemicals, energy, food processing, and, oddly, filmmaking. By 1983 there were 23,000 Vietnamese in Czechoslovak factories; by August 1989 there were 29,600, by far the largest single group of foreign workers in the country, ahead of the Cuban and Polish contract-labor cohorts Czechoslovakia also hosted. But migrants were not welcomed into idyllic conditions. Workers received only forty percent of their wages directly, with the Vietnamese state taking the remainder to service its debt, and any pregnancies came with the guarantee of deportation. Alamgir calls the final phase of the program “beleaguered internationalism”: the contract involved cheap labour under a Marxist veil. Czechoslovakia ran similar contract-labour arrangements with Cuba and Mozambique, and Vietnamese workers were never alone in the country’s network of socialist guest-labour schemes. What set the Vietnamese program apart was its longevity and its scale: where the Cuban arrangement was bounded by fixed four-year rotations and the Mozambican one stayed comparatively small, the Vietnamese exchange ran continuously for over two decades and grew with each renewal, producing a long-term settled population.

However, with the monumental symbolism of the fall of the Berlin Wall in 1989, these contracts fell with it. The expectation was that workers would return home to Vietnam, and in East Germany they mostly did: the Vertragsarbeiter program there had peaked at nearly 60,000 Vietnamese, and after reunification the German state offered DM 3,000 (around $1,850 in 1990 dollars) to anyone willing to repatriate; tens of thousands accepted, as the anthropologist Christina Schwenkel recounts. Yet in Czechoslovakia, no such buy-out was made possible. Around 13,000 Vietnamese were still in the country when the state contracts ended, and they were not paid to leave or invited to stay. Ignored, many obtained small-scale retail licences in the chaotic early 1990s and went into trade. Corner grocery stores called potraviny spread across the country while the Czech state busied itself privatising its old enterprises. By 2011, Nguyễn was the ninth most common surname in the Czech Republic, per Czech Statistical Office census data.

A strange relationship ensued between the Vietnamese and Czech people. The sociologist Adéla Souralová, in fieldwork published in 2015 and in a dedicated chapter on the practice, documented one of the more surprising kinship arrangements in post-Communist Europe. Vietnamese parents, working sixteen-hour days at their shops, hired recently retired Czech women, often pensioners with adult children of their own, as nannies for their children. The nannies would read Czech fairy tales, sing Czech lullabies, and cook Czech food, and the children grew up bilingual, biculturally raised, often calling the nanny babička. Souralová’s respondents describe these women as grandmothers rather than employees; one teenager in her study, when asked what would change in her life if she did not have her babička, replied that she would simply be alone. The integration was unplanned by the Czech state, occurring through a match in the needs of Vietnamese parents for caretakers, and Czech women on pensions who needed the work.

The second generation were named banánové děti, banana children: yellow on the outside, white inside. A Vietnamese-Czech tour guide named Nicolas explained the term to a journalist from Expats.cz in 2024: “It’s not offensive. It’s true. We may look Vietnamese on the outside, but we speak Czech better than Vietnamese.” The self-mocking phrase reflects the rupture, cultural and linguistic, between first and second generation Vietnamese: a testament to the degree of integration seen in the country.

In July 2013 the Czech government adopted Resolution No. 530, which restructured the Council for National Minorities to include a Vietnamese representative. The post went to Phạm Hữu Uyển of the civic association Văn Lang. In Czech administrative terms, it was the recognition the community had asked for nine years earlier and been refused, on the grounds that “national minority” was a status reserved for indigenous groups. The 2013 decision also required the Council to invent a new category: a minority defined by cultural and regional rather than historical significance. Vietnam is now the fourteenth recognised national minority of the Czech Republic, the only one originating from a Comecon labour contract.

The COVID-19 pandemic deepened the relationship between the two cultures. In March 2020, the Czech government made face masks mandatory in public, one of the first European countries to do so, despite having a supply shortage as Al Jazeera reported at the time. In response to hospital rationing of masks, within days an organisation called Làm Cha Mẹ CZ (“Being Parents in Czech”), a Prague-based group of Vietnamese mothers, was sewing cloth masks at home and routing them to hospitals through a Facebook group. Their tally was over 30,000 masks in the first weeks of lockdown, according to Balkan Insight. The hashtag #vietnamcipomahaji, “Vietnamese are helping,” aggregated similar efforts: free meals to police officers, baskets of gloves left outside grocery stores, and fundraising for a ventilator at the hospital in Ústí nad Labem. A blogger named Tran Van Sang, who pushed the hashtag, told the same outlet that “I felt that we had stopped a wave of xenophobia” that had been building in the first weeks of the pandemic, when Vietnamese in public masks were treated with racism. In October 2020, President Miloš Zeman awarded the Medal of Merit to Tan Trinh, head of the Vietnamese Association in the Moravian-Silesian Region. The grandchildren of people who had once been sent to repay a war debt were now distributing equipment to Czechia’s hospitals.

Yet Czechia remains an anomaly in the former Eastern bloc. The same integration that occurred in Prague was absent from Berlin. The anthropologist Christina Schwenkel, comparing socialist mobility regimes across the Eastern Bloc, finds the post-1989 trajectories sharply divergent: in East Germany, structural exclusion and the skinhead violence of the early 1990s pushed the Vietnamese community into invisibility; in Czechoslovakia, the economic upheaval and chaos of privatisation meant that they went unnoticed, allowing them to remain. Interestingly, the integration was not the result of Czech action, such as the passing of inclusivity laws or the extending of rights. Rather, it was inaction that facilitated the Vietnamese entry into small commerce, the only sector with low enough barriers to entry. 

A useful comparator outside Europe is the United States Bracero programme, which ran from 1942 to 1964 and ended, like the Czechoslovak contract, in a formal termination rather than a managed transition. However, the Mexican-American case featured an absence of any legal path to citizenship once the contracts ended, forcing the descendants of Braceros to build their lives largely outside the protection of the law for a generation, in conditions more similar to the East German policy of exclusion than to the Czech one of indifference.

Yet none of this should be viewed as romantic. The first generation of Vietnamese-Czechs was indentured under Gustáv Husák’s government and their children were called Vietnamec as a slur; the Sapa market has been raided more than once on suspicion of money laundering and counterfeit goods, and Czech-language media circulated the image of Vietnamese marijuana grow-houses as a national security threat for two decades. The community’s most successful businesses still remain concentrated in low-margin retail. Souralová titled one of her studies after a recurring theme in her interviews: that Vietnamese parents had given their children everything for them and nothing with them. The Vietnamese community in Czechia did not and have not experienced what might be viewed as a traditional success story. 

Thus, the Czech-Vietnamese case suggests three things about how cultural relationships between countries can deepen. First, official recognition follows facts on the ground rather than producing them. Vietnamese became a Czech national minority in 2013 because by then the relationship was already a routine matter, involving pho deliveries, school runs, and shared grandmothers. Official recognition served only to close the gap between the law and the street rather than creating it. Second, the bilateral relationships that survive global shocks and changes to the world order are not necessarily the ones in which governments share the most ambassadorial niceties. Instead, they can be the ones whose citizens have something each side wants and an opportunity to acquire it. In March 2020, Hanoi did not send aid to Prague. It was Vietnamese-Czech mothers, with sewing machines, that cemented the relationship. Third, global citizenship does not require individuals to feel at home. A shared marketplace can serve as a stronger bond than shared values. This poses an uncomfortable implication for policy given that the European Union has spent the last decade attempting to enable integration through values screening, something achieved in Czechia by leaving a community alone long enough that it became a part of the nation organically.

In January 2025, Vietnamese Prime Minister Phạm Minh Chính visited Sapa during an official trip hosted by Czech Prime Minister Petr Fiala, and at a community gathering that same week called the Vietnamese-Czech community a “solid bridge” in the relationship between Hanoi and Prague. Yet this metaphor may be slightly misrepresentative: a bridge presumes that the two sides exist separately and that the crossing is the goal. But the trip on bus 113 to Libušská 126 offers an alternative: a third place, built originally on an expired labour contract, by people who became citizens of Czechia over time. 

The evolution of the relationship between the Czech Republic and its Vietnamese population offers a peculiar insight into the possibilities of citizenship: it can work in the absence of policy, perhaps more effectively than in the presence of it, through an alignment in supply and demand. Values, cultures, and language can transform over time when the economic and social needs of a nation are met. Czechia and Vietnam teach us that communities are more malleable than they might seem, and that real human connection can transcend seemingly insurmountable differences in culture. 

Bibliography

Featured/Headline Image Caption and Citation: TTTM Sapa Prague-south entrance | Image sourced from Wikimedia Commons | CC License, no changes made

Alamgir, Alena J. “Socialist Internationalism at Work: Changes in the Czechoslovak-Vietnamese Labor Exchange Program, 1967–1989.” Ph.D. dissertation, Rutgers University, 2014.

Cohen, Deborah. Braceros: Migrant Citizens and Transnational Subjects in the Postwar United States and Mexico. Chapel Hill: University of North Carolina Press, 2011.

Kušniráková, Tereza, and Andrea Gerstnerová. “Vietnamese ‘Guests’ in Socialist Czechoslovakia: Apprentices, Contract Workers, and Illegal Entrepreneurs.” In Asian Migrants in Europe. Springer, 2025.

Schwenkel, Christina. “Rethinking Asian Mobilities: Socialist Migration and Post-Socialist Repatriation of Vietnamese Contract Workers in East Germany.” Critical Asian Studies 46, no. 2 (2014): 235–258.

Souralová, Adéla. New Perspectives on Mutual Dependency in Care-Giving. Farnham: Ashgate, 2015.

Souralová, Adéla. “‘My parents did everything for us but nothing with us’: Parenting and mothering in Vietnamese immigrant families in the Czech Republic.” Asian and Pacific Migration Journal 30, no. 1 (2021): 39–59.

Souralová, Adéla. “‘Můžeš prostě říct, že máš babičku’: Vietnamské děti, české babičky a význam prarodičovství v jejich biografiích.” Sociologický časopis 51, no. 5 (2015): 815–844.

Souralová, Adéla. “Vietnamese Immigrants in the Czech Republic: Hiring a Czech Nanny.” In Asian Migrants in Europe, edited by Sylvia Hahn and Stan Nadel, 95–112. Goettingen: V&R unipress, 2014.

The Tiau River is narrow enough to cross on foot during the dry season. The Indian village of Zokhawthar sits on one bank, and the Myanmar village of Khawmawi on the other. A woman dying of breast cancer rests in a tin-roof shack on the Indian side, while her aunt, BM Thangi, crosses the river to fetch her belongings from the Myanmar side. BM Thangi’s husband, a Mizo farmer named Vanlalchaka, has made his home a haven for five refugees from the Myanmar junta’s seizure of power in 2021. Until 2024, these crossings did not require an Indian passport or permission from Delhi or Naypyidaw.
“The people of Zokhawthar and Khawmawi operate as a single village,” Vanlalchaka told a reporter in 2024. “When someone dies,” he added, “we join the funeral process; when someone falls ill, we cross the border to visit patients and stay overnight if needed.” The villagers belong to the Zo tribe, known as Mizo in Mizoram State on the Indian side and as Chin in Chin State on the Myanmar side. For centuries, people crossed the river to bury their loved ones, marry, and trade. These crossings predated the British administrators who drew the boundary line in 1834, and long before independent Myanmar or India existed.

In the late 1940s, the Myanmar and Indian governments began negotiations to formally ratify the border shown on colonial maps, which had never been fully surveyed. The two former colonies formally recognized the demarcation line imposed by the British, but, sharing the belief that colonial authorities had arbitrarily divided a single ethnic group, they rejected stringent border enforcement measures. For 74 years, the India-Myanmar border was considered the most open of any between two independent nations. The Free Movement Regime (FMR) dates to 1950, when India amended its passport rules to allow members of hill tribes living within 40 kilometers of the border, whether citizens of India or Myanmar, to cross freely without documentation. In 2004, citing security concerns, India reduced this zone to 16 kilometers and limited border crossings to three designated entry points. Reconfirmed in 2018, the FMR allowed eligible crossers to stay visa-free for up to 14 days. Only ten of the border’s 1,643 kilometers were fenced. Children from Khawmawi attended schools in Zokhawthar, while hospitals in Mizoram provided health care to people from Chin State. The FMR could be read as a tacit concession to the Zo tribe and an acknowledgment by Myanmar and India that the borderland was home to one people whom the British had divided into two. The openness of this policy did not spring from corridors of power but from the villages, river crossings, and familial relationships that predated either state.

Yet the FMR was not only about righting a historical wrong; it also served India’s regional strategy. In 2018, India formalized the FMR as part of its Act East Policy, balancing two goals at once. First, India sought to cultivate cordial relations with Myanmar, its land gateway to the Association of Southeast Asian Nations, and second, to counter China’s rising influence in Naypyidaw. However, the 2021 military coup in Myanmar disrupted that balance. The junta dropped aerial bombs on villages in Chin State. Families began crossing the Tiau River into Mizoram by the thousands. By 2025, approximately 35,000 Myanmar nationals sought refuge in Mizoram, the largest concentration of Myanmar refugees anywhere in India. The Mizoram State government, under the successive administrations of the Mizo National Front and the Zoram People’s Movement since 2021, echoed the logic behind the FMR in sheltering refugees. A Rajya Sabha Member of Parliament told the press that Myanmar’s refugees were like “family.” However, the central government in Delhi held a different view. According to the Indian Home Ministry, the porous border posed a serious threat to national security. In February 2024, Amit Shah, India’s Minister for Home Affairs, announced that FMR would be terminated and that the border would be fenced. By 2025, border arrivals from Chin State were required to have special permits and were scrutinized by the Assam Rifles, India’s oldest paramilitary force, which controlled the border on the Indian side. The government of Mizoram State, in which Zokhawthar lies, protested Delhi’s decision to abandon the FMR and fence the border. “The British geographically divided the Zo ethnic people who have inhabited [present-day] Mizoram and the Chin Hills of Myanmar for centuries together, once under their own administration. We have been dreaming of reunification and cannot accept the India-Myanmar border imposed upon us,” announced K. Sapdanga, the Home Minister of Mizoram. Thousands marched through Aizawl in protest, and the irredentist Zomi Reunification Organization threatened to take up arms if any further work on the fence continued.

The Ministry also claimed that rebel groups fighting in Manipur, where Meitei-Kuki ethnic clashes killed approximately 258 people and displaced around 60,000 residents between 2023 and 2025, were exploiting weak border controls to infiltrate India with militants and weapons. Shah justified the fence as a measure to protect India’s internal security and to maintain the “demographic structure” of its northeastern states bordering Myanmar. Thus, the bond forged over centuries of British colonialism, the 1962 coup, the 1988 uprising, fifty years of military rule, and the 2021 coup was being dismantled by India, the very nation that had long regarded the border as a colonial travesty.

To a national audience, the phrase “demographic structure” signaled that India’s about-face on migration was not about clandestine border crossings or smuggling, but about the perceived threat that ethnic Chins posed to the integrity of the Indian states. Two understandings of the cultural relationship came into conflict: one that viewed shared ethnicity as a basis for sanctuary, and another that saw it as a threat to be managed by a physical border.

The Myanmar-India story shows that bilateral relations extend beyond the power of nations. India and Myanmar created the FMR, thereby legitimizing regional cultural encounters that had flourished for generations. The Mizos and Chins acted on the basis of centuries-old ethnic and familial ties, independent of directives from Delhi or Naypyidaw. Cultural cooperation thrives in villages, families, and shared rituals. Yet in the 21st century, states view these organic bonds as threatening, because they cannot easily regulate these encounters from a capital thousands of kilometers away. The role of states is to decide whether to celebrate cooperation, restrict it, or pretend it is not happening. India chose to restrict cooperation, ending the freedom of movement that allowed the Zo people to live as one community across two countries.

When BM Thangi crosses the river, she is not making a statement about her citizenship. She is fulfilling her duty as an aunt. But the thousands who marched through Aizawl were making a statement. The conventional account holds that global citizenship replaces, or at least supersedes, national loyalties in favor of a cosmopolitan one. The Mizo protesters refused to choose between the two identities. Sapdanga rejected the border decision, not his nation. He asked the Mizos to remain Indians while refusing to enforce a colonial border that separates them from their kin. Being a global citizen does not require denying the importance of one’s nation. Global citizenship may instead mean strengthening the human ties that existed before nations.

For global citizenship, Myanmar-India border ties offer some hope, but the lesson about international cooperation is far bleaker. The FMR survived for 74 years because the arrangement suited Delhi, and when India’s priorities shifted to security, the open border was among the first casualties. The uncomfortable truth is that grassroots cooperation survives only as long as states find it useful. Grassroots, cross-border cooperation is rarely threatened by a falling-out between neighbors, but almost always by a government seeking power through nationalism, militarism, and a fence that purportedly advances state interests.

Currently, roughly 30 kilometers of border fencing are under construction. People continue to cross the river, but must apply for a border permit, pass a background check, and limit their stay to seven days. Many find the process too slow or costly and instead cross the unmonitored jungle.

Vanlalchaka continues to receive refugees. His niece still battles cancer. Some aspects of cultural cooperation may endure forever, quietly and steadily, through families and religious groups. Borders do not stop people from burying their dead. But the fence, when completed, will likely outlast the people who once knew the border’s permeability and witnessed the rapid decline of an era of relative openness in the 2020s.

Vanlalchaka still hopes his niece will survive. However, if she dies, the family intends to take the funeral procession across the river, following ancestral traditions. Whether they will be allowed to approach the opposite bank, for the first time in living memory, remains the question.

References

Featured/Headline Image Caption and Citation: Indo-Burmese Border | Image sourced from Wikimedia Commons | CC License, no changes made

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Chakraborty, Sushovan, and Riya Sinha. “Fencing, Security and Border Management: The Indian Experience.” Centre for Social and Economic Progress (blog), August 19, 2025. https://csep.org/blog/fencing-security-and-border-management-the-indian-experience/.

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Translation Policy 

As a Kanaka ʻŌiwi (Native Hawaiian) scholar, I follow the critical scholarship of Noenoe Silva on translating Indigenous words and phrases into the English language. In her groundbreaking work, Aloha Betrayed: Native Hawaiian Resistance to American Colonialism, Silva decides not to italicize words in ʻōlelo Hawaiʻi (Hawaiian language) to “resist making the native tongue appear foreign in writing produced in and about a native land and people.” For this reason, I choose not to italicize words from the many Indigenous languages of Papuans and Alifuru. 

Introduction 

In October 2017, Benny Wenda—spokesperson of the United Liberation Movement for West Papua (ULMWP)—submitted the West Papuan People’s Petition to the United Nations Special Committee on Decolonization. The petition, signed by over 1.8 million Papuans, called for a plebiscite on self-determination in West Papua, a demand that has echoed since Indonesia’s invasion of the island in 1961. Wenda, in a speech delivered at the UN in New York, mobilized the language of historic injustice, mass violence, and grievance inflicted on Indigenous West Papuans to justify the petition and its demands for Papuan self-determination: 

“Today, we hand over the bones of the people of West Papua to the United Nations and the world. After decades of suffering, decades of genocide, decades of occupation, today we open up the voice of the West Papuan people which lives inside this petition.” 

Seven years prior, Alexander Manuputty—then-executive chairman of the in-exile Republik Maluku Selatan (RMS)—submitted a petition to the UN Commission on Human Rights, demanding a plebiscite for the South Malukan people. Declaring that Indonesia was actively “annihilating the Moluccan people,” the petition situated Malukan calls for independence within a broader history of human rights violations perpetrated by the Indonesian government in the islands. In addition to their calls for a plebiscite, Manuputty requested that South Maluku be placed under UN trusteeship and that a UN-sponsored investigation of Indonesian repression in South Maluku be initiated. 

While neither Wenda nor Manuputty’s petitions would gain traction on the international stage, contemporary calls for West Papuan and Malukan independence extend a longer history of self-determination movements in the occupied territories of Indonesia. Since Indonesian independence, self-determination movements in both West Papua and the Maluku Islands have appealed to identity as a mobilizing factor in their demands. West Papuan self-determination activists, however, have been more successful in mobilizing international support for their calls, through inclusion in a variety of international political forums and statements of solidarity issued by seven UN member states. By contrast, the Malukan independence cause has gone largely unrecognized in international forums, with the exception of some organizations advocating for Indigenous Alifuru rights at the UN. Despite a shared history and political present of colonization by the Indonesian state, this divergence in the outcome of West Papuan and Malukan independence calls raises several questions about mobilization tactics for self-determination: What strategies for collective action accounted for the differences in outcome between West Papuan and Malukan calls for self-determination? How did deployments of identity in these independence movements shape their ability to mobilize support both within and beyond their borders? How did these framing strategies impact the forms of repression exacted by the Indonesian state? 

In this paper, I argue that independence movements in West Papua and South Maluku primarily diverge through their framings of identity. My findings suggest that West Papuan ascriptions to Melanesian and global Black identities enable a more defined claim to participation in international institutions and recognition by decolonizing states across the Third World, whereas South Malukan ascriptions to a Malukan Christian identity could not engage with such claims. I contend that the Indonesian state contests these divergent framings of identity through discourses of sovereignty and multiculturalism, a repression strategy that sought to characterize Papuan and Malukan claims as conflicts internal to Indonesia. 

To situate this comparative analysis of independence movements in the occupied territories of Indonesia, this paper begins with an overview of the literature on ethnic conflict and self-determination. I then provide an overview of both cases, focusing on the post-World War II history of self-determination movements in West Papua and the Maluku Islands. By engaging with the digital archives of West Papuan and South Malukan independence organizations, United Nations documents, and semi-structured interviews with Alifuru community members from the Maluku Islands, I compare discourses of identity in both self-determination cases and their ability to mobilize external support in the international community. With these divergent and overlapping identity framings as a backdrop, I engage the Melanesian Culture and Arts Festival (MACFEST) as a limited site of Indonesian repression through the language and aesthetics of multicultural inclusion. At its core, this essay contributes to a growing literature that seriously considers the impact of identity politics on self-determination movements in securing internal and external support for, while generating state repression against, Indigenous claims to land and governance. 

Drivers of Self-Determination 

Scholars of ethnic conflict have long debated which factors most reliably produce demands for self-determination. Economic explanations have emphasized regional wealth disparities, state administrative capacity, and the exploitability of natural resources as primary drivers of secessionism. Sambanis and Milanovic, for instance, find that higher regional per capita income is associated with greater observed sovereignty in decentralized states, reasoning that richer regions face fewer trade-offs in pursuing greater autonomy. These economic accounts, however, rest on an underlying political assumption—that policy independence is inherently desirable—without fully accounting for the drivers of group mobilization. As Monica Toft argues, proponents of purely economic frameworks “fail to explain why some groups are willing to risk death, internment, or mass deportation for seemingly worthless territory.” Economic conditions may reduce the opportunity cost of secession, but they do not generate the grievance required to sustain a movement. From this framing, economic factors function as enablers of self-determination, rather than its root cause. 

Political factors, and particularly a group’s relationship to state power, more reliably account for the onset of self-determination movements. Cederman, Wimmer, and Min find that rebellions mounted in the name of excluded groups are significantly more likely than conflicts among included groups As excluded groups move from powerless to discriminated to separatist, the association with violent conflict deepens. Threats to territory amplify these dynamics: control over land is tied to physical security and the capacity for self-governance free from state-sanctioned violence. In this context, ethnic identity makes political demands more legible and gives movements a collective basis for mobilization when prompted by state discrimination or exclusion. Successful mobilization, as Cederman, Wimmer, and Min contend, requires both motivation and organizational capacity—rooted in grievance and shaped by framing strategies around identity. This paper engages with both dimensions, examining how identity is strategically deployed to sustain and expand self-determination movements beyond their immediate constituencies. 

The salience of ethnic or Indigenous identity in self-determination movements is actively produced by conditions of political exclusion. Kanchan Chandra argues that ethnic identity, grounded in descent-based attributes that resist fluidity and carry high visibility, becomes more politically salient under conditions of state discrimination. Mashail Malik further finds that when states target specific ethnic groups through structural violence—whether through police mistreatment, bureaucratic exclusion, or deliberate denial of political representation—individuals within those groups develop a defiant pride in their collective identity. This dynamic is particularly pronounced among working-class or economically marginalized communities, whose disadvantages are compounded by political exclusion, intensifying allegiance to co-ethnic communities as hubs of collective resistance. Ethnic identity, then, provides a coherent framework for grievance, enables coalition-building within communities, and, crucially, offers a language through which demands can be articulated on the international stage. 

State responses to identity-based movements further shape their trajectory. Harris Mylonas argues that the interaction between host states and external powers determines the nation-building policies a state pursues toward non-core groups, yielding strategies of assimilation, accommodation, or exclusion depending on the type of third-party support a movement receives. Katharine Adeney’s discussion of Indian multiculturalism as a state strategy illustrates how the recognition of identity in the public sphere—through polyethnic and self-governing rights—can dampen secessionist demands, while segregationist or exclusionary policies, as in the Pakistani case, can intensify them. These findings situate state responses to self-determination movements as deeply intertwined with the identity frameworks movements themselves adopt: the way a group frames its collective identity shapes both the international recognition it can access and the repressive or accommodating strategies the state deploys in return. 

This paper builds on these insights to examine how divergent framings of identity in West Papua and the Maluku Islands produced asymmetric outcomes in international support and in the forms of repression exerted by the Indonesian state. In both cases, discourses of identity formed crucial components of West Papuan and Malukan claims to self-determination, cleaving along ethnic and ethno-religious lines. These identity formations—Melanesian and Black identities in West Papua, and Malukan Christian and Alifuru identities in Maluku—were mediated by each group’s relationship to Dutch and Indonesian state power, particularly as colonial encroachment threatened their social and political standing. While motivating a defiant pride in the collective identities of West Papuans and Malukans, Indigenous and race-based identities proved more salient in mobilizing external support for self-determination claims than ethno-religious affiliation. To contend with these divergent outcomes, the following section briefly traces the rise of self-determination movements in West Papua and South Maluku, beginning with Indonesian independence in 1945. 

West Papua and South Maluku, 1945-present 

West Papua 

West Papua’s modern political struggle began with the collapse of Dutch colonial rule after World War II. While Indonesia declared independence in 1945, the Dutch retained control over West Papua by emphasizing the region’s cultural and geographic distinctiveness from Indonesia. Under Dutch administration, Papuans began building a distinct national identity through pan-Melanesian solidarity networks and international appeals. In 1961, an elected Papuan National Committee declared independence from the Dutch. The burgeoning independence movement, however, was swiftly undermined by Indonesia’s invasion of West Papua, launched as Operation Trikora under President Sukarno. American intervention in the ‘West Irian issue’ on the side of Sukarno intensified Indonesian claims to the Papuan homeland, precipitating the proposal and signing of the 1962 New York Agreement. This agreement, signed between the Netherlands and Indonesia, first transferred West Papua to UN trusteeship and then to Indonesian control, with an expressed commitment from the Indonesian government to provide a self-determination plebiscite for West Papuans. In 1969, the Indonesians held the “Act of Free Choice,” in which only 1,026 hand-picked voters, coerced under threat of death, unanimously voted for Indonesian integration.

Since integration, West Papua has experienced systematic dispossession, military violence, and demographic transformation. The Indonesian military killed and imprisoned thousands throughout the late 1960s and 1970s, governed the region as a military operation zone from 1977 to 1988, and assassinated key independence leaders like Theys Eluay. Freeport’s American-owned gold and copper mining operations, conducted without Indigenous consultation, displaced Native communities and caused severe environmental destruction. Suharto’s transmigration policy reshaped the region’s demographics so thoroughly that Indigenous Papuans became a minority in their own homeland. Despite periodic waves of protest—including the massive 2019 uprising across dozens of cities—Indonesia has continued to suppress self-determination claims.

South Maluku 

Contrary to the continued Dutch administration of West Papua, the Maluku Islands fell under the State of East Indonesia (NIT) after World War II. Following the Dutch-Indonesian Round Table Conference of 1949, pro-Indonesian nationalist groups demanded the reintegration of NIT into a unitary Indonesian nation-state, which some non-Muslim groups—constituting over 38% of Maluku’s population currently—opposed. The threat of integration pushed Malukan elites to proclaim the independent Republik Selatan Maluku (RMS) in April 1950, a formation driven by the economic instability inherited from Dutch and Japanese rule and fears of Javanese Muslim political dominance over the islands’ Alifuru, or Indigenous Malukan, and Christian populations. On July 13, 1950, the Indonesian government invaded the South Malukan island of Buru, beginning a sustained state campaign against the RMS. The abolition of Indonesia’s federal structure in August 1950 criminalized the RMS movement, with thousands of Malukan soldiers who refused to integrate into the Indonesian army forcibly removed to the Netherlands. Back in the islands, any public expression of RMS identity—flag-raising, symbolic speech, or cultural memory—was prosecuted as treason under the Suharto Regime.

The most violent chapter came in 1999–2004, when ethno-religious conflict between Javanese Muslim and Malukan Christian communities erupted into mass violence that killed over 6,000 people and displaced upwards of 70,000. While state military and police forces were largely inactive, military soldiers tended to side with Javanese Muslims, and the local police sometimes allied with Malukan Christians. Despite its framing as a religious war, Indonesian senior officials and reporters contend that the violence “was provoked as part of a nationwide strategy of rogue military officers linked to the [Suharto] family to disrupt the forthcoming parliamentary elections in June and create the conditions for a return to military rule.” The arrival of paramilitary Islamist forces deepened the carnage. Though the 2002 Malino II Accord ended large-scale fighting, no truth-and-reconciliation process followed, and perpetrators faced no accountability. During this time, new organizations calling for self-determination—including the Front Kedaulatan Maluku (FKM)—were founded by Malukan nationalists to shed light on the human rights violations perpetrated by the Indonesian government during the conflict, which they framed as a genocide. Despite these attempts to hold the nation-state to account, Indonesia continues to politically pacify the region, primarily through infrastructure development and economic integration, while exiled Malukan nationalists in the Netherlands keep the self-determination movement alive. Nonviolent, symbolic support for Malukan independence, however, remains a criminal offense in Indonesia. 

Comparing Discourses of Identity 

Across both self-determination movements, identity cleavages formed a foundational mobilization factor for pro-independence supporters in West Papua and South Maluku. In the Papuan case, the emergence of an Indigenous and race-based national identity distinguished Melanesian Papuans from the Indonesian polity. For South Maluku, the persistence of a Malukan Christian identity in the islands drove calls for independence from a nation-state increasingly dominated by Javanese Muslims. This section discusses the differences in these identity-based cleavages—Indigeneity and ethno-religious affiliation—and the ways they shaped the mobilization strategies deployed by pro-independence activists. My findings suggest that identity-based mobilization was relatively successful internally in both cases, but Papuan framings of self-determination through the language of Indigeneity and race were able to curry greater favor on the international stage than those of South Malukans. 

From the Black Pacific to the Third World 

European explorers and anthropologists arriving in West Papua in the nineteenth century brought discourses of race and power to the islands. Distinguishing Papuans from lighter-skinned Malays of the Malay Archipelago, Papuans were often described as “savages,” “pigmy,” and “Oceanic Negro” to encapsulate European conceptions of Papuan moral and intellectual capacities. In mapping anti-Indigenous and anti-Black discourses onto the Papuan people, Europeans arriving on the island linked West Papua to a broader race-making project in the Pacific. Kanaka ʻŌiwi scholar Maile Arvin argues that Westerners divided Oceania into three distinct, racialized regions—Polynesia, Micronesia, and Melanesia—which constitute colonial projects rather than stable places. West Papua was folded into the Melanesian project, demarcated by Black populations that anthropologists reasoned would make the region unsuitable for white settlement (melas means “black” in Greek). This racial logic underwrote Dutch colonial governance in West Papua, which positioned Papuans at the lowest rung of colonial society. 

At the end of World War II, Papuan intellectuals and activists began reclaiming Melanesian identity while under continued Dutch administration, primarily through international forums. In 1947, six Western powers—the U.S., U.K., France, the Netherlands, Australia, and New Zealand—established the South Pacific Commission, framing it as a body for coordinating development among Indigenous Pacific populations, while carefully excluding political matters that might threaten those states’ ongoing occupation of the region. West Papua was included in this forum by Dutch officials; the Papuans used the forum as a medium to culturally link themselves to other nations and peoples across Melanesia. In addition to building solidarity networks across the Pacific, West Papua’s post-war organizing around Melanesian identity also functioned to sharpen “the racial differences between Papuans and Indonesians, or Melanesians and Malays.” Pan-Melanesian identity, while initially mobilized by Dutch colonizers to mark Papuan inferiority to Malays, became a rhetorical tool that West Papuans mobilized to advance their claims to self-determination. 

Following West Papua’s declaration of independence from Indonesia, Papuan leaders began mobilizing articulations of Blackness associated with Melanesian identity in support of their claims to self-governance. While Papuans bifurcated Indonesia and Melanesia, the idea of Melanesia was insufficient to curry international support for their cause, leading Papuan nationalists to expand their “nationalist mental map” to Africa. In 1962, the Papuan National Committee—the governing body of the West Papuan independence movement—published a series of booklets, reports, and articles to appeal to African nations for support in its claims to self-determination. One of those booklets, Voice of the Negroids in the Pacific to the Negroids throughout the World, argued that “New Guinea was not a borderland of Indonesia, but of Oceania,” with Papuans ethnically originating from “the Negro Race.” These ascriptions to a global Black identity functioned to not only articulate a shared experience of racism, colonialism, and imperialism with Africans and African-Americans, but also to dissuade African nations from siding with Indonesian claims to the region. In the booklet, the PNC included letters to the elected leaders of Ethiopia, Liberia, Nigeria, Ghana, the Congo, Guinea, and Sierra Leone, asking them to stand against Indonesian propaganda that sloganized freedom and human rights in the name of imperialism. Ascriptions to a global Black identity proved successful for Papuan claims to independence at the UN in the late-60s, with 14 countries, primarily African nations, and the NAACP vocalizing support for West Papuan self-determination. 

In addition to the rhetorical calls for Black solidarity mobilized by the Papuan National Committee, Voice of the Negroids in the Pacific to the Negroids throughout the World effectively leveraged visual elements to generate support for self-determination. Figure 1 shows a map of Indonesia, New Guinea, and Australia as provided by the pamphlet’s authors. In this mapping of the region, Indonesia was grouped with the Asian continent, while West Papua was visually incorporated into both New Guinea and Australia. This intentional division of West Papua from Indonesia is further captured by the map’s layout—the region is bisected across two pages, creating a visual split that emphasizes West Papua’s proximity to Oceania and Indonesia’s proximity to Asia. Interestingly, the map excludes several occupied regions of Indonesia—including the Maluku Islands and Timor-Leste—from the Asian grouping, likely reflecting Papuan solidarity with other Indigenous groups calling for self-determination. Through its visual iconography, the PNC’s pamphlet framed Papuan Blackness in geographic terms, a choice that underscored the colonial undercurrents of Indonesian claims to the region. 

Figure 1. Map of Indonesia, New Guinea, and Australia in Voice of the Negroids in the Pacific to the Negroids Throughout the World, 1962. 

Contemporarily, these identifications with a global Black identity remain salient, evidenced by the formation of the #PapuanLivesMatter movement in the wake of George Floyd’s murder. Papuan activists have consciously adopted the aesthetics of global Black movements, repurposing them for their specific anti-colonial struggle under Indonesian occupation. The #PapuanLivesMatter hashtag directly mirrors the structure and iconography of #BlackLivesMatter, circulating through digital platforms to connect Papuan grievances to a globally legible framework of anti-Black racism. Papuan youth organized protests in which they described themselves as “Indonesia’s George Floyd,” drawing an explicit parallel between American police violence and Indonesian state violence. For Papuans, this aesthetic borrowing is a form of “scale-making”—framing local conditions of occupation and racism within a globally recognizable language of Black suffering and resistance. In drawing on the aesthetics of American movements, Papuan discourses reached audiences, including Indonesians, who had previously remained indifferent to West Papuan claims.

West Papuan amplifications of a global Black identity have emerged in tandem with the continued mobilization of Melanesian identity on the global stage. In 1986, decolonizing Melanesian states in the South Pacific Commission formed the Melanesian Spearhead Group (MSG), comprising Fiji, Papua New Guinea, the Solomon Islands, Vanuatu, and the Kanak of French-occupied New Caledonia. In 2015, the United Liberation Movement for West Papua (ULMWP), a coalition of West Papuan independence organizations, petitioned the MSG for full membership, on the basis that membership was offered to other Indigenous Pacific groups under occupation. While Indonesia, an associate member of the MSG, swiftly moved to block West Papua’s ability to become an official member, the MSG granted West Papua observer status. ULMWP’s bid was supported by a petition of over 150,000 signatures, urging the government of Vanuatu to support the coalition’s membership. Although observer status does not grant the ULMWP engagement capabilities akin to full members, West Papuan independence leaders frame observer status as a recognition of the organization as “the representative body of the people of West Papua,” while countering “Indonesia’s argument that the West Papuan independence groups are divided and undemocratic.” The relegation of the ULMWP to observer status, however, demonstrates the tension between Indonesian assertions of their international legal right to non-interference in the internal affairs of a sovereign state and West Papuan rights to self-determination in regional forums. 

Despite the salience of Indonesian political blockades against West Papuan recognition, the ULMWP’s regional networks have secured several allies for West Papua within the United Nations. In 2016, Nauru, the Marshall Islands, Tuvalu, Vanuatu, the Solomon Islands, Tonga, and Palau called on the UN to intervene in Indonesian human rights abuses in West Papua. These calls were reaffirmed in 2025, when the Pacific Islands Forum issued a communique calling on the UN High Commissioner for Human Rights to visit West Papua, in consultation with the MSG. Benny Wenda, president of the ULMWP, framed the communique as a moment in which “the Pacific stood up with one voice and demanded that Indonesia [open] West Papua – the ‘festering human rights sore’ of our region – to the eyes of the world.” Through the language of regional unity, the ULWMP effectively leveraged its affiliation with Melanesian nations to advance both self-determination and claims of human rights abuses on the international stage. Ascriptions to pan-Melanesian and Black identities made these claims legible to a global audience, situating the West Papuan cause within anti-colonial and anti-racist frameworks that propelled independence movements across the Third World. 

Religion, Violence, and the Making of an Alifuru Nation 

Prior to the arrival of the Dutch, the Maluku Islands were primarily inhabited by the Alifuru—the Indigenous Melanesian peoples of Maluku —who operated a decentralized, egalitarian form of governance. Alifuru situate their existence in adat, embedding people in relation to the land and the cosmos, a worldview that characterizes a custodial obligation to saka lede, the earth. This ethic of responsibility shaped the structure of Alifuru governance, which intentionally dispersed power across various federations through the Siwa-Lima dual alliance system. Muslim and Dutch incursions into the islands, however, unsettled this egalitarian order. From the late fifteenth century, the Sultanates of Ternate and Tidore imposed taxes, forced labor, and slave raiding on Alifuru communities, while the Dutch established a clove monopoly in the islands in the mid-nineteenth century. Dutch traders and missionaries, in particular, characterized Alifuru as “undisciplined, wild and barbaric people” ripe for conversion to Christianity. Despite the salience of Indigenous identity and cosmologies in structuring politics in the Maluku Islands, external impositions both destabilized these practices and led to the formation of new ethno-religious identities, which underlie contemporary calls for South Malukan independence. 

Figure 2. Map of the Maluku Islands. 

While West Papuan self-determination movements grounded their claims in Melanesian identity and pan-African solidarity, South Malukan independence claims emerged from a Malukan Christian identity forged through Dutch missionary activity. During the Dutch colonial administration of the Maluku Islands, the KNIL (Royal Netherlands Indies Army) recruited heavily from the Alifuru population in Ambon, an island in South Maluku. This process generated a distinct Malukan Christian identity through tangsi, the barracks subculture. While serving in the KNIL, Malukan recruits were subjected to a Protestant missionary education and instilled with loyalties to the Dutch crown, producing a conception of identity which “saw themselves as superior to the rest of Ambonese society.” Indeed, the authority of raja, traditional village leaders, progressively eroded as colonial administrative changes stripped them of labor obligations and harvest revenues. Dutch influence in the formation of a Malukan Christian identity extended beyond the colonial military, with the Dutch channeling educational and economic opportunities specifically toward Christian groups in Ambon. This history of preferential inclusion produced structural advantages for Malukan Christians at the expense of Malukan Muslims and, later, Javanese settlers, situating the identity as a marker of social position within the colonial hierarchy rather than spiritual affiliation. 

Indonesian independence threatened to unsettle the colonial hierarchies that privileged Malukan Christians, driving émigré Christian politicians to create the RMS and to declare South Malukan independence. An elite, educated, and urbanized class of Malukan Christians—including politicians, a stratum of raja, and over 2,000 KNIL veterans—formed the foundation of RMS membership, rooted in fears of the material losses that would emanate from absorption into a polity dominated by Javanese Muslims. Indeed, the formation of the unitary Indonesian nation-state resulted in sweeping reforms that enabled Malukan Muslims, constituting about half of the islands’ population at the time, to access educational institutions and government positions previously dominated by Christians. President Suharto’s transmigration policies intensified this dynamic, bringing predominantly Javanese Muslim and Butonese settlers into the Maluku Islands, which shifted economic power toward settler communities. For Malukan Christian elites, unification was registered as a threat to their community’s standing and survival. That grievance was channeled into the symbolic language of kinship, homeland, and ancestral belonging, fundamentally framing the Indonesian state as an occupying entity. 

Within the Maluku Islands, ethno-religious identity proved to be a powerful but limited mobilizing force. Networks of village churches and educational institutions built by Protestant missionaries provided ready-made organizational channels for communal solidarity and resource mobilization. Indeed, even in the most violent phase of the 1999-2004 conflict, some Christian church leaders were able to organize effective peacebuilding initiatives through the institutional infrastructure the churches provided. Importantly, many Indigenous traditions—like pela gandong, a historic intervillage alliance system—continued despite the accumulation of grievances between Christian and Muslim communities at the elite level, emphasizing Indigenous identity as the connective tissue that extended beyond religion. Many of these local structures of governance, however, were drastically changed under the New Order regime, with President Suharto suppressing local political figures and maintaining interreligious conflict to preserve the Indonesian state’s power. While Christian identity served as a mobilizing factor for some Alifuru in their demands for independence, these claims were most salient among elites disgruntled by the dissolution of colonial society. Evident in the continuation of pela gandong, however, Alifuru identity transcended the sectarian divides that ethno-religious conflict brought for most of the Indigenous population. 

Successive iterations of Malukan self-determination organizations would, in turn, demonstrate the ineffectiveness of the RMS’s claims to independence based on ethno-religious identity. During the 1999-2004 period of mass violence, several pro-independence Alifuru leaders formed the Front Kedaulatan Maluku (FKM), rooted in demands for sovereignty on the basis of an “Alifuru nation,” an invocation of Indigenous ancestry. This rhetorical shift, offered by FKM spokesperson Agnus Wattimena, deliberately shifted Malukan claims away from religious affiliation toward Indigenous self-determination, partly inspired by a peace process negotiated in the neighboring Kai Islands. This shift represented the limitation of the RMS’s attachments to Malukan Christian identity, while doubling as a framing response to the Indonesian state’s characterization of the violence as a religious civil war. Indeed, when the Indonesian government held Alex Manuputty—the FKM’s leader—on trial in Jakarta, prominent news sources characterized him as a “Christian separatist leader,” rather than an Indigenous organizer seeking self-determination for his people. Similarly, in Ambon, Muslim leaders blamed the RMS for inflaming the period of mass violence, while some Christian leaders disavowed the independence movement. While Manuputty and other FKM leaders may have been more closely aligned with Alifuru views in South Maluku, the RMS’s longstanding attachments to class-based incentives and ethno-religious identity limited the FKM’s ability to adopt the aesthetics of an anti-colonial movement and to detach from its predecessor’s legacy. 

Despite these limitations, the FKM and other Alifuru-led groups continued to advance South Malukan independence claims in international forums on the basis of Indigeneity. On April 22, 2004, the FKM released a letter to the international community calling for UN intervention to quell the mass violence, characterizing it as a genocide perpetrated by the Indonesian state against the Alifuru people. Highlighting state-sponsored attacks on churches and villages across Ambon, along with the tens of thousands of Alifuru displaced as a result, the letter’s authors contended that mass violence perpetrated by Laskar Jihad, an Islamic fundamentalist militia, and the Indonesian military were mutually reinforcing. Other Malukuan independence organizations, like the Bangsa Adat Alifuru, similarly advanced claims of Indonesian genocide against Alifuru at the UN, using that framing to call for the withdrawal of Indonesian military forces and the launch of a UN fact-finding mission on the violence. Through participating in sessions of the UN’s Human Rights Council and the Permanent Forum on Indigenous Issues, Bangsa Adat Alifuru has worked to advance a framework of Alifuru self-determination to argue for Malukan independence, breaking from initial characterizations of ethno-religious persecution. While attaching to certain critiques of the religious undercurrents of Indonesian colonialism, Alifuru independence leaders gradually shifted focus away from ethno-religious identity as a core driver of self-determination. 

Today, Alifuru activists have shifted previous calls for external self-determination toward an internal self-determination model. On the international stage, the Saniri Alifuru, a council of traditional leaders and chiefs of the Maluku Islands, has emerged as the principal voice advocating for Alifuru rights within the Indonesian state, while framing itself as a pre-colonial governing institution. In May 2017, the Saniri Alifuru submitted a Universal Periodic Review on the Republic of Indonesia to the Office of the UN High Commissioner for Human Rights (OHCHR), declaring that the Indonesian state was actively suppressing Alifuru culture, exploiting their lands and resources, and subjecting Indigenous youth to an education system that encourages social conformity and discourages Alifuru practices. Using the UN Declaration on the Rights of Indigenous Peoples as its basis, the council recommended that the Indonesian state support Alifuru initiatives toward internal self-governance and end the political perseuction of the RMS and other pro-independence activists. 

Despite these rhetorical shifts toward an Indigenous and human rights framework, no UN member state has formally expressed support for Alifuru self-determination and South Malukan independence. 

Inclusion as Repression: The Melanesian Arts and Culture Festival 

As West Papuan and South Malukan claims to independence were quelled by explicit forms of violence, contemporary repression efforts have shifted toward the deployment of multiculturalism as a strategy to quell identity-based separatism. Following Indonesian independence in 1945, the emerging government engaged in a nation-building project that attempted to bridge the nation’s multiple 

identity cleavages through a unifying national language—Bahasa Indonesia—and an ideology of multicultural inclusion—Pancasila. With hundreds of ethnic groups, religious groups, and a diversity of sects within the nation’s Muslim majority, the construction of a unifying Indonesian identity sought to “reduce the salience of subnational identity […] and to subsume them within a broader national identity.” However, scholars have argued that Indonesian nation-building through multicultural inclusion has worked to simultaneously appropriate the identity of the nation’s subgroups—particularly Melanesians—while suppressing the political demands emanating from them. Despite the sociopolitical salience of inclusion as a nation-building tactic, in the Indonesian case, the strategy works to deny the political undercurrents of marginalized groups. 

For the Indigenous peoples of West Papua and the Maluku Islands, these forms of repression are most visible through Indonesia’s participation in the Melanesian Arts and Culture Festival (MACFEST). Originating from the MSG in 1995, MACFESTs were conceived as a platform to celebrate traditional and contemporary arts from nations across Melanesia. In October 2015, the Indonesian state hosted MACFEST for the first time, holding the celebration in Kupang, East Nusa Tenggara Barat. For Kacung Marjian, Indonesia’s Director General of Culture at the Ministry of Education and Culture, the rationale for Indonesia’s hosting arose from the “fact that majority of Melanesian population, about 80 percent, live in Indonesia.” At the 2015 MACFEST, representatives from predominantly-Melanesian regions of Indonesia—including East Musa Tenggara, Maluku, North Maluku, Papua, and West Papua—were invited to attend the festival, alongside delegations from Fiji, Papua New Guinea, the Solomon Islands, Timor-Leste, Vanuatu, and New Caledonia. The Indonesian state framed the festival as an alliance-building mechanism with other Melanesian states, particularly in economic cooperation. For populations internal to the Indonesian state, Anies Baswedan, Indonesian Education and Culture Minister, contended that “diversity must not hinder unity,” and that the festival offers an opportunity to “achieve a common dream of a peaceful, just, and prosperous world.” From these framings, Indonesia’s participation in and hosting of MACFEST functioned as a nation-building strategy through celebrating ethnic identities subordinate to the prevailing identity and incentives of the Indonesian state. 

With its primary focus on Melanesian arts and culture, MACFESTs have become sites of repression for political mobilizations of Melanesian identity, particularly for the occupied territories of Indonesia. At the 2018 MACFEST in the Solomon Islands, police and state officials prohibited the raising of the West Papuan flag. The rule precipitated a confrontation between an Indonesian official and Ben Didiomea, a Solomon Islander wearing a Free West Papua shirt and carrying the West Papua flag. As Didiomea attempted to unfurl the West Papua flag outside the Indonesian tent, the official attempted to confiscate it—a move swiftly blocked by onlookers who intervened in Didiomea’s defense. The incident prompted one anonymous Indonesian citizen to submit a comment to the Free West Papua Campaign, arguing, “Could the actions of this Indonesian abroad be the way my country shows its iron grip in Melanesia, without actually valuing Melanesian culture?” This seeming contradiction in Indonesian attendance, as pointed out by the concerned citizen, speaks to the broader repressive strategy deployed by the Indonesian nation-state through MACFEST—the depoliticization of Melanesian regions demanding independence from Indonesia through uplifting their culture. 

Figure 3. West Papua and Republik Maluku Selatan flags at the opening parade of the 7th Melanesian Arts and Culture Festival, July 19, 2023. 

Despite Indonesian attempts to frame Melanesian identity as a culture internal to the nation-state, other Melanesian nations denied Indonesian narratives of inclusion. At the 2023 MACFEST, the government of Vanuatu invited ULMWP to formally participate as a special guest, a development that coincided with West Papua’s bid for full membership to the MSG. The flags of West Papua and the RMS were waved by the ULMWP delegation at the festival’s opening parade, displayed in Figure 2. The inclusion of RMS flags demonstrates the solidarity between the self-determination movements in West Papua and South Maluku, bound by a shared identity and experience shaped by Indonesian occupation. For Anna Naupa, the presence of flags from the occupied regions of Indonesia, alongside other states from across the Pacific, rendered the cultural dimension of the festival through a political lens—as she contends, “culture is not a politically neutral category.” Despite attempts by the Indonesian state to channel Papuan and Malukan claims to self-determination through multiculturalism, MACFEST enabled a multiplicity of Melanesian political expressions to emerge, unbounded by the statist politics that precede and follow the festival. 

With contemporary West Papuan and South Malukan claims to self-determination rooted in Melanesian identity, the Indonesian government attempted to frame Indigeneity as a cultural sub-group subordinate to the nation-state through MACFEST. These framings of Indigeneity mirror the legal arguments advanced by Indonesia on the international stage, which stake Papuan and Malukan self-determination claims as conflicts internal to the state. The construction of these claims as internal insulates the Indonesian state from external intervention under the international system, since state sovereignty is maintained through the principle of non-intervention. Indigenous scholars have argued that policies and institutions advancing multiculturalism function as new forms of colonialism in the age of neoliberalism. In the Indonesian context, multiculturalism functioned as a core component of nation-building and anti-secessionist repression, containing Indigenous claims to the boundaries of the nation-state. Like Pancasila, MACFESTs operated as the vehicle through which the Indonesian state attempted to strip the political dimensions of Papuan and Malukan identity, an attempt that had limited success in regional spaces dominated by their Melanesian allies. 

Discussion and Conclusion 

Across the self-determination movements in West Papua and South Maluku, identity functioned as the core mobilizing factor and framing strategy deployed to stake claims to independence from the Indonesian state. While both contemporary formulations of the movements—ULMWP and the Saniri Alifuru—root their claims to self-determination in Indigenous identity, West Papuan nationalists initially reclaimed both pan-Melanesian and global Black identities to distinguish from Indonesians, while South Malukan groups emerged from an ethno-religious identity forged within colonial society. These differences in identity formation resulted in divergent outcomes in international support, with Indigenous-based claims finding greater success in alliance-building. West Papuan ascriptions to Indigenous, Melanesian, and Black identities enabled access to international forums and statements of support from UN member states with overlapping identity attachments. Initial claims from the RMS, however, were disregarded as sectarian politics internal to the Indonesian nation-state. Building on the extant literature on ethnicity and self-determination movements, in the cases discussed, Indigenous identity provided both a framework for co-ethnics to channel grievance and a more perceptually legitimate basis for self-governance and land reclamation claims globally. 

The international legibility of Indigeneity emerges from a distinct legal and political tradition that undergirds the source of state sovereignty in the West. Enlightenment thinkers, like Thomas Hobbes, and the Treaties of Westphalia constructed a conception of sovereignty rooted in a state’s “unfettered control over persons and objects within their respective territories.” This centralization of authority in the state structures the modern international system, with states emerging as the “basic units” of global politics, and guided by principles of formal equality, exclusive territorial jurisdiction, non-intervention, and the supremacy of state consent. While non-state actors—like Indigenous groups internal to the borders of a nation-state—are relegated to unequal political bodies that lack recognition and decision-making authority, Indigeneity provides the basis for a variety of state-like rights on the international stage. The United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), for example, declares that Indigenous peoples have the right to “self-determination, have the right to autonomy or self-government in matters relating to their internal and local affairs, as well as ways and means for financing their autonomous functions.” Importantly, UNDRIP articulates a right to land reclamation, a provision that has complicated state support for the resolution, but closely mirrors Westphalian conceptions of territorial sovereignty. 

In both West Papua and South Maluku, UNDRIP and other international Indigenous rights frameworks form the basis for their claims to independence from Indonesia. Despite the state voting in favor of UNDRIP in 2007, Indonesia does not fully accept the concept of Indigenous peoples in national law. Indonesian officials argue that almost all Indonesians are Indigenous, and thus deserve equal rights—an extension of Pancasila and the creation of a superordinate national identity. This strategic universalization of Indigeneity coincides with the state’s amplification of ethnic and religious diversity, which frames Indigenous groups, such as Papuans and Alifuru, as Indonesian nationals with distinct, subordinate cultural backgrounds. The Indonesian state’s flattening of Indigeneity mirrors the rhetorical strategies it deployed to frame mass violence in the Maluku Islands as a purely sectarian conflict, an articulation that allowed it to stave off external intervention into its borders. Despite the salience of Indigeneity as a basis for self-determination claims among actors on the global stage, including Indonesia itself, the state has effectively mobilized its sovereign authority to foreclose self-determined futures for Indigenous peoples vying for independence. The continued occupation of West Papua and South Maluku, as such, demonstrates the limits of international bodies as a mechanism for advancing self-determination claims. 

These limitations of state sovereignty have led Indigenous scholars and activists across Oceania to advance visions of an otherwise beyond Westphalia. Kanaka ʻŌiwi scholar Jamaica Osorio, rooted in a genealogy of Indigenous scholars critiquing state sovereignty, argues that Native peoples should abandon colonial political structures in favor of liberatory styles of governance that predated, and continue to live alongside, the Western world. Examples of these styles of governance permeate the cases at-hand—from the diffusion of centralized authority under Maluku’s Siwa-Lima system to the coalition-based organizing of the ULMWP. Despite the state-centric objectives and divergent identity mobilizations of the West Papuan and South Malukan self-determination movements, the community-based structures that sustain their calls for independence should be given equal scholarly attention. As Papuans and Alifuru confront genocides against their communities perpetrated by the Indonesian nation-state, the framing tactics deployed by these Indigenous peoples should not be understood solely as a political mobilization strategy, but an affirmation of place and identity in the face of elimination. 

In these continued calls for independence, the ongoing conditions of Indonesian occupation have fostered solidarity among West Papuan and South Malukan nationalists. On Feburary 3, 2026, activists from West Papua, Maluku, and Aceh gathered at the Indonesian Embassy in The Hague, Netherlands, to protest Indonesian colonialism. Importantly, Indonesian ambassador Sidharto Reza Suyodipuro was elected president of the UN Human Rights Council by member states for that year, a development that activists contended would provide ample grounds to demand self-determination. Benny Wenda, speaking on a megaphone, chanted “once proclaimed, remains proclaimed,” a refrain underscoring the ongoing and unceded rights to self-determination that Papuans and Malukans hold. Across divergent framings of identity, self-determination movement leaders from West Papua and South Maluku find unity in the shared project of liberation, articulating a form of collective identity quite different from those constructed by the Indonesian state. In a Facebook post highlighting the rally, Wenda grounds this unity in a shared commitment to hope: 

“Free West Papua. Free Aceh. Free Maluku. We stand united in one spirit, with one voice, and one shared determination to liberate our lands from Indonesian colonial rule. Across our islands and mountains, from forest to coast, our peoples continue to resist injustice, defend our ancestral lands, and uphold our right to self-determination, dignity, and freedom. Our struggle is not divided by geography. It is connected by history, by suffering, by hope. In unity, we remain strong. In solidarity, we continue the path toward freedom.” 

Through imagining an otherwise beyond the conditions of occupation, shared history, suffering, and hope have emerged as the underlying ties that bind the occupied regions of Indonesia together. Across the variety of identity formations that generated internal grievances and external support, the self-determination movements of West Papua and South Maluku persist, both in their homelands and in exile. The persistence of those movements speak to the depth of Indigenous demands for self-determination, and the frailty of colonial political regimes that arbitrarily divide and unify. In an essay re-published by the Moluccan International Campaign for Human Rights, George Aditijondro contends that Indonesian independence did not sanction unfettered expansionism, but affirmed that the colonial borders established by the Dutch “can continuously be re-negotiated and determined in accordance with the wishes of the people who live within those borders.” In an unyielding demand for merdeka, freedom, West Papuan and South Malukan re-negotiations of the borders, sovereignties, and violences that confine them open generative futures for liberation. 

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Featured/Headline Image Caption and Citation: Free West Papua, Photo by Matt Brown | Image sourced from Flickr | CC License, no changes made

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Introduction

In 1978, an American researcher Linda Gail Arrigo sat across from RCA’s personnel manager at the company’s Taoyuan plant. The manager described how RCA had called on the KMT party-state’s martial law authority to suppress a factory strike, and how the company had deliberately structured its wage package to push unwanted workers into quitting voluntarily. Arrigo documented these conditions in her field notebooks, which the Taiwan Garrison Command secret police soon seized. Arrigo eventually demanded her notebooks back. But the workers whose conditions she had documented, the tens of thousands of young women handling chlorinated solvents without adequate protection on twelve-hour shifts, would wait decades before anyone recorded their story. By then, thousands had developed breast, liver, cervical, colorectal, and ovarian cancers (Teng 2007).

These events belong to a history that Taiwan’s semiconductor historiography has consistently told as two separate stories. One takes place on the shop floor and in the dormitory. Semiconductor firms recruited young Taiwanese women from rural areas and placed them into export-oriented electronics production lines. They rewarded these young women for their speed, dexterity, and obedience. The other occurs in conference rooms and breakfast shops. Technocrats, engineers, and corporate interlocutors plotted Taiwan’s leap from low-tech export manufacturing to high-tech semiconductor production, particularly through the 1976 Radio Corporation of America (RCA) Project (ITRI 2023). Within Taiwan’s semiconductor industry historiography, the second dimension of state strategy and technology transfer has too often eclipsed the first.

Contemporary discourse reinforces this imbalance. Government and policy narratives routinely foreground Taiwan’s dominance in leading-edge manufacturing and the strategic significance of its firms. After all, Taiwan produces over 90% of the world’s most advanced chips and over 60% of all semiconductor foundry revenue (USITA 2025). Popular works like Chip War likewise privilege top-down technological development and capital investment (Miller 2022). Many Taiwanese regard the industry as 保國聖山, “a sacred mountain that protects the country” (Hsiao 2025). Such strategic framing can make labour harm appear politically inconvenient or even risky to acknowledge.

There is nothing inherently wrong with describing Taiwan’s semiconductor industry as strategically critical. But when such narratives become the default historiography, they risk reproducing a familiar erasure. The marginalised women and migrant workers who made the “strategic” sector possible disappear, and the authoritarian governance that oppressed them becomes invisible.

The scene that opens this paper illustrates what that erasure concealed. In the late 1960s, the authoritarian Kuomintang (KMT) regime invited RCA to build some of Taiwan’s first semiconductor assembly, testing, and packaging (ATP) facilities. The young women whom Arrigo encountered at RCA’s Taoyuan plant worked twelve-hour shifts handling chlorinated solvents like trichloroethylene, tetrachloroethylene, and trichloroethane without adequate ventilation or protective equipment. They lived in company dormitories enclosed behind checkpoints, often guarded by KMT military police. Their enterprise unions had no real independence. Decades later, thousands of these women developed cancers. The litigation that followed would expose not only the toxic contamination but also a systematic pattern of corporate evasion, manufactured scientific doubt, and regulatory complicity that the martial law regime had made possible.

This paper argues that these are not two separate stories about technological triumph and labour exploitation. They are a single history. The same institutional architecture that enabled the celebrated 1976 RCA technology transfer also governed the shop floors where women assembled transistors under coercive conditions. The same martial law apparatus that promised multinational firms “political stability” suppressed the worker organising that might have revealed toxic hazards in real time. The nineteen engineers who trained at RCA’s U.S. facilities and returned to build Taiwan’s first integrated circuit demonstration factory did not work in isolation from the labour regime that recruited, housed, disciplined, and ultimately poisoned the women on RCA’s production lines.  They worked atop it.

Yet existing accounts consistently separate these dimensions. The technology transfer literature treats labour as a factor endowment. Labour history treats semiconductor upgrading as a separate institutional story. Taiwan’s transitional justice framework largely sidelines state-enabled corporate violence against factory workers. Why has Taiwan’s semiconductor historiography reproduced this separation? What did the KMT’s martial law apparatus do inside export electronics factories to shape recruitment, dormitory life, wage discipline, and occupational risk? And if the labour regime was integral rather than incidental to Taiwan’s technological ascent, what does that imply for the vast public investments now justified through similar “national interest” framings?

Historiography and Methods

This divide reveals itself in existing scholarship. Linda Gail Arrigo’s 1985 analysis of women workers in Taiwan’s multinational electronics factories remains the most important contemporaneous account of how martial law shaped factory life (Arrigo 1985). Based on late 1970s fieldwork, Arrigo linked piece-rate incentives, dormitory surveillance, and KMT military police to the broader structure of export-oriented industrial policy. But Arrigo was writing in real time. She could not trace the regime’s toxic consequences, its legal afterlife, or its relationship to the semiconductor upgrading story that had barely begun. Paul Jobin’s recent work addresses what Arrigo could not: the decades-long trauma of RCA’s former workers, the epistemic violence of contested causation, and the psychological toll of protracted litigation (Jobin 2025). Jobin explicitly connects RCA’s offshoring to Taiwan’s later semiconductor dominance. Yet his analysis, grounded in medical sociology, does not reconstruct the institutional machinery that made toxic exposure systematic rather than incidental. Together, Arrigo and Jobin supply this paper’s two essential poles. What neither does, and what no existing work has attempted, is to show how the same martial law apparatus that enabled celebrated technology transfer also foreclosed the worker voices who might have identified occupational hazards in real time.

Three additional bodies of scholarship fill out the analytical frame. Ming-sho Ho’s work on Leninist party-state control and labour federation politics documents how the KMT embedded its organisational apparatus within factories (Ho 2006), though it does not extend this analysis to occupational health or semiconductor upgrading. Contemporary World Bank reports reveal the de jure incentives offered to foreign investors while naturalising “political stability” and “cheap and industrious labour” as development inputs (IBRD et al. 1967). Taiwan’s transitional justice scholarship, focused largely on White Terror killings and imprisonments (Executive Yuan 2024), has not recognised how authoritarian infrastructure functioned as labour control within export factories. The RCA case illustrates why labour regimes deserve recognition as a distinct site of transitional justice reckoning.

Theoretically, the paper draws on: developmental state theory to frame how the KMT courted and constrained industry (Wade 2003; Amsden 1992), global value chain theory to examine how lead firms’ standards shaped local labour practices (Gereffi 2018), labour process theory to interpret piece-rate discipline and manufacturing consent (Braverman 1974; Burawoy 1982), feminist political economy to foreground gendered recruitment and dormitory governance (Arrigo 1985; Hsiung 1996; Kung 1995), and postcolonial critical theory to interrogate how institutional frameworks exploit workers and their bodies (Spivak 1988; Ricaurte 2022). These frameworks guide the primary source analysis.

The paper’s methodology relies extensively on primary sources that exist only because the regime’s concealment was imperfect. A post-martial law Taipei District Court verdict concerning RCA Taiwan documents toxic solvent use, groundwater pollution, and differential access to safe drinking water (Sung and Chen 2015). Thirty-five semi-structured interviews from research trips to Taiwan, South Korea, and the Philippines in 2024 and 2025 provide direct recollections from former RCA workers, migrant labourers in contemporary ATP supply chains, lawyers, labour organisers, NGO supporters, and scholars. Collected oral history records further document factory labour norms in 1960s-1970s industrial Taiwan, highlighting long shifts, forced overtime, workplace deaths, and the absence of recourse (沈德盛 2023).

A final point concerns scale. Numerous multinational and domestic actors shaped Taiwan’s ATP labour regime, but RCA is analytically central for two reasons. It was both a foundational company in Taiwan’s semiconductor origin story and a source of toxic contamination whose legal afterlife produced unusually rich documentation. That documentation retroactively illuminates workplace practices otherwise concealed by corporate and martial law secrecy. RCA thus serves simultaneously as a case of authoritarian-era multinational offshoring and as a window into the broader characteristics of early ATP labour regimes.

Building the Institutional Preconditions for Electronics Export

Martial law fundamentally conditioned Taiwan’s Cold War labour regime. During the White Terror period from 1947 to 1987, the KMT kept Taiwan under an official state of emergency, curtailing political rights, stifling opposition, and suspending many civil liberties (國家人權博物館 2017). These included the regime’s political killings, imprisonment, and torture of an estimated 140,000-200,000 dissidents, and broader persecution of ethnic Taiwanese intellectual elites (Cheung et al. 2022). The KMT’s rule extended into the workplace, where the authoritarian government effectively banned independent labour organising and treated worker dissent as a communist security threat (Jamison 2022). Even after martial law was lifted in 1987, the idea of “labour-capital harmony” continued to pervade Taiwanese politics (Huang 2001). But the labour regime that RCA and similar foreign firms would exploit did not emerge from martial law alone. It was built through a sequence of interlocking institutional developments: economic reforms designed to attract foreign capital, spatially bounded export zones that concentrated and governed production, a legal architecture that fragmented worker power, and a coercive security apparatus that backstopped the entire system.

Constructing the Investment Architecture

Taiwan’s ATP labour regime did not come from “culture” or market pressures alone (Deyo 2003). It arose from a martial law-era institutional environment built to facilitate export industrialisation in the late 1950s and 1960s. Incentivised by promises of further U.S. aid and ambitions of integrating Taiwan into global manufacturing networks, Taiwan pursued market liberalisation. By August 1960, KMT officials finalised a “Plan for Accelerated Development” that reduced tax burdens and removed industrial expansion constraints (Irwin 2021). These policy changes, paired with currency devaluation, significantly increased export-focused foreign and domestic investment.

The KMT’s reform package was comprehensive and deliberately sequenced (Wade 2003). Exchange-rate adjustments, tariff liberalisation, and a 1960 investment statute offering tax incentives and foreign exchange entitlements collectively constructed what contemporary economists recognised as an explicitly FDI-oriented policy architecture. As Yu Ching Jao observed at the time, these measures were designed for the “encouragement of foreign investment” (Jao 1976), a framing that treated foreign capital not as a byproduct of growth but as growth’s prerequisite. Export processing zones (EPZs) extended this logic spatially, bundling cheap land, infrastructure, and reduced bureaucracy into physically bounded zones optimised for multinational entry.

International development institutions reinforced this framing. A 1967 World Bank appraisal of the China Development Corporation catalogued Taiwan’s investment incentives, including tax holidays, customs duty deferrals, and duty-free import provisions. It attributed the island’s rapid growth to “political stability, appropriate Government policies, heavy American aid and the diligence of the economically active population” (IBRD et al. 1967). That language normalised repression as stability and managed low wages as diligence. By rendering authoritarian labour control legible as a technocratic input, such appraisals lent institutional legitimacy to a development model whose profitability rested on foreclosing worker agency.

Two features of export electronics made this particularly consequential for labour regimes. First, ATP depended on large numbers of low-paid workers rapidly performing repetitive tasks, requiring not merely low wages but wage discipline. This required a workforce whose compensation could be held below productivity gains without triggering collective action. Second, the EPZ framework of processing imported materials for re-export meant that Taiwanese labour was the primary site of value creation within the zone. Yet the governance structure ensured workers captured the smallest share of that value. Cold War geopolitics, economic reform, and labour control thus converged in a single developmental logic that made Taiwan particularly attractive to foreign electronics firms due to its authoritarian labour structure.

Export orientation evolved from a purely economic idea into an administrative form. Later Taiwanese semiconductor narratives often celebrate research and training organisations (Hsiao 2025). The earlier story of how the KMT built export-oriented industrial spaces and politically managed labour within them is equally important.

Export Processing Zones and the Spatialisation of “Industrial Peace”

EPZs were one of the most consequential spatial tools within Taiwan’s export strategy. KT Li, Taiwan’s “godfather of technology” (Saxon 2001), visited the free port city of Trieste in 1962 (Irwin 2021). Soon after, Li opened one of the world’s first EPZs in Kaohsiung in March 1965 (NYT 1967). The Kaohsiung EPZ offered firms tax and duty exemptions alongside purpose-built infrastructure for electronics, precision machinery, and related sectors (外交部 2022).

The Kaohsiung EPZ and its successors in Taoyuan, Taichung, and elsewhere by the early 1970s are typically narrated as investment promotion instruments (Haggard and Zheng 2013). They were also labour governance instruments, concentrating over 100,000 women at peak employment within bounded spaces where the state could regulate customs flows and human mobility (Kuo 2010). Some workers were underage girls who borrowed other people’s ID cards to gain entry (王諺玫 2009), likely hazardous child labour given the hours and chemical exposure (勞動部 2024). EPZ gates, dormitories, and checkpoints enclosed a workforce whose mobility could be monitored. Police classified EPZ employees as “special surveillance objects” (Chang 2023), collapsing industrial management into security enforcement. Workers were pushed into extensive overtime and chronic solvent exposure with little recourse (Jobin 2010). The EPZ administration’s dual mandate compounded the problem: the same authorities that promoted foreign investment also adjudicated labour disputes (Taiwan Panor. 1980), systematically favouring corporate interests over worker protections. Taiwan’s Control Yuan later criticised EPZs for courting investment while running their own labour inspection centres (高涌誠 and 王幼玲 2024).

While global value chain scholarship highlights how lead firms govern production networks by setting supplier standards (Gereffi 2018), the KMT state itself helped Taiwan’s EPZs institutionalise those requirements. The KMT state did not just invite multinationals, but it embedded their operational logic into local governance. The state was deeply responsive to and integrated with corporate priorities, yet it maintained just enough autonomy to enforce industrial priorities (Evans 1995). Taiwan’s Ministry of Economic Affairs and EPZ authorities embodied this duality, being highly responsive to multinational investment and production requirements yet also steering firms toward export targets and technology transfer goals. While institutions like the World Bank narrated EPZs as technical policy innovations (IBRD et al. 1967), they also functioned as authoritarian governance laboratories. Within these zones, the authoritarian state could refine labour control mechanisms while maintaining a facade of modernisation.

Corporatist Law and the Fragmentation of Worker Power

EPZs provided the spatial framework for Taiwan’s labour regime, but the legal system provided its structural scaffolding. While labour unions formally existed, they were legally constrained in a corporatist manner that fragmented worker power while preserving a veneer of representation. Taiwan’s Labor Union Law limited unions to individual plants and stipulated mandatory membership (S.-J. Chen et al. 2003). The law also required factories to have at least 30 workers for unionisation and divided legal unions into categories that limited sectoral bargaining powers (勞動部 2022). Industry-wide or independent unions, along with the right to strike, were banned outright. From 1947 until 1987, no legal strikes occurred in Taiwan, and KMT authorities swiftly crushed or defused any collective worker actions (Winn 1987). As a Taiwanese commentator put it, “Totalitarian rulers do not adhere to [the right to strike]. They regard strikes as rebellions to be suppressed. Taiwan’s former regime was no exception” (Huang 2001). Even within permitted single-factory unions, management or KMT loyalists often occupied leadership roles, earning these organisations the moniker 閹雞工會, “castrated chicken unions” (Huang 2001), for their lack of real bargaining power. During the martial law era, unions served as “auxiliary institutions of industrial peace… [and] administrative arms of the government for the implementation of national policies.” Some even helped the KMT mobilise workers to win sham elections (S.-J. Chen et al. 2003).

Administrative mechanisms further constrained workers’ voices. When ministries disagreed over worker protections, the Ministry of Economic Affairs’ export promotion priorities often took precedence over labour reform. The Ministry of Interior sometimes made superficial gestures for “internal reform and protection of workers,” suggesting that women workers should get mandatory breastfeeding time in 1978 (Arrigo 1985). But in practice, these policies would hardly help Taiwan’s largely unmarried young factory women. The KMT even set up a special organ within the Ministry of Economic Affairs to arbitrate foreign corporate disputes separately from public litigation within the Ministry of Justice, making labour disputes less visible and publicly contestable (Arrigo 1985). Single enterprise unionism thus fragmented worker power, while administrative channels diverted grievances from public arenas where they might have gained traction.

Leninist Discipline on the Shop Floor

To implement their labour control regime, the KMT ironically built a Leninist party-state apparatus in workplaces (Ho 2007). Despite their purported opposition to communism, the KMT’s Bureau of Labor and the official Chinese Federation of Labor embedded KMT party cell representatives and secret police within large factories (Ho 2006). These secret police officers from the Taiwan Garrison Command served as 安全室主任, “chief of security” (Hsin-Hsiang Chen 2025). Such extrajudicial processes surveilled and quelled unrest often before worker organising efforts became public. Workers were expected to resolve grievances through state-approved channels, if at all. For example, a worker might complain to a company welfare officer or at a labour-management meeting, but these mechanisms had no real power independent of management. Any attempt to organise outside the official structure risked severe punishment. The KMT brutally killed all who tried to form independent committees or protest. After all, on February 28, 1947 alone, the KMT killed up to 28,000 Taiwanese over a government tobacco monopoly dispute (Forsythe 2015). This repression extended to dissenting foreign academics and journalists as well, some of whom the KMT even murdered extraterritorially (J. Pan 2021).

The state’s enforcement of occupational safety and health regulations followed the same logic of performative governance. Martial law allowed foreign firms like RCA to draw on a remarkably compliant workforce. The legal architecture constrained workers de jure. The enforcement and security apparatus ensured their de facto subordination (Minns and Tierney 2004). Even after Taiwan enacted its first weak industrial labour code, the government “did not strongly require employers to comply,” so even state-owned enterprises often failed to correct violations (何明修 2021).

Only crisis compelled the KMT to legislate. In 1972, roughly a dozen workers at a Philco plant in Tamsui, which assembled electronic components for Ford, died agonising deaths from liver diseases caused by inhaling industrial poisons (國立歷史博物館 2020). The incident compelled the KMT to enact the 1974 Labour Safety and Health Act (林宜平 2011), Taiwan’s first major occupational safety statute. Yet penalties were so minimal that employers learned it was cheaper to ignore the law than to comply (Winn 1987). As RCA’s own inspection record would later demonstrate, meaningful enforcement never followed.

In Taiwan’s export electronics sector, “industrial peace” meant far more than the absence of strikes. It rested on interlocking mechanisms of spatial enclosure, legal fragmentation, administrative diversion, coercive surveillance, and performative regulation that together made refusal costly and collective action nearly impossible. Taiwan’s industrial relations encompassed more than simply employer-worker relations. They were state-mediated relations designed to reduce publicity, delay resolution, and constrain the arenas in which workers could speak.

“If the Prosecutor is Too Annoying, We’ll Just Change Him:” Factory Life in the 1960s

Oral histories from Taiwan’s broader industrial milieu confirm that workers felt these institutional weaknesses on the factory floor. In an interview record, Shen Desheng recalls that in the 1960s, factory work often ran on a two-shift system from 8 a.m. to 8 p.m. and 8 p.m. to 8 a.m. Base wages were low, making overtime pay indispensable, and factories provided inadequate industrial safety protections. Given these circumstances, Shen recounts a fatal elevator accident that occurred under “normal” conditions. Then still a young manager, Shen personally held the bleeding worker and transported him to Mackay Hospital in a three-wheeled cargo cart. No ambulance came, and no emergency protocol existed. The company did not initially regard itself as responsible, and Shen recalls that “there was not yet labour consciousness and labour rights” at the time. Next, when a prosecutor arrived to investigate the safety failure, the managers said 檢察官如果太囉唆，就換一位, “If the prosecutor is too annoying, we’ll just change him” (沈德盛 2023). Capital was insulated not merely by weak enforcement or toothless statutes but by the capacity to override the judicial process itself. 

If Shen’s account illustrates how individual firms avoided regulatory scrutiny, Arrigo’s account of a sit-down strike at General Instruments Taiwan reveals how the state enforced that impunity at scale. After the factory manager failed to issue a customary Autumn Festival bonus, thousands of Taiwanese workers sat idle and refused to work (Arrigo 1985). The American manager soon called the KMT military police to suppress the strike. Under martial law, leading labour disturbances was a capital crime. This episode illustrates that for multinationals, Taiwan’s promise of “political stability” meant not only minimal protests, but also access to a state apparatus capable of quickly extinguishing emergent dissent.

These accounts are not specifically about RCA, but they establish the operative conditions in which RCA built its ATP labour regime. By the late 1960s, Taiwan’s factory life was already characterised by long hours, minimal safety protections, and managerial authority reinforced by social hierarchy and state coercion. The authoritarian regime had scaffolded investment incentives, concentrated export zones, and cultivated the “stable” political environment that constrained collective bargaining. RCA is significant not only because it used these conditions, but because it consolidated them into labour structures that outlasted both the company and martial law.

U.S. Trade Policy, Geopolitics, and RCA’s Turn to Taiwan

RCA’s Taiwan expansion in the late 1960s emerged from U.S. trade policy, Cold War geopolitics, and domestic labour instability. These forces helped craft a transnational production network in which companies offloaded coercive labour discipline to authoritarian governments.

The U.S. tariff code’s offshore assembly provisions were critical to this system. By allowing firms to export components for overseas assembly and pay reimport duties only on foreign value added, these provisions did not merely accommodate global production networks. They actively constructed them as economically rational (Feenstra et al. 2000). By 1970, as U.S. Tariff Commission data confirm, substantial shares of American semiconductor imports by value had already entered under offshore assembly provisions (Sutton et al. 1971), evidence that production fragmentation was not a corporate improvisation but a legally structured outcome. Taiwan had become one of the principal destinations within this architecture, receiving U.S. components for assembly and shipping finished goods back under preferential duty treatment. Offshoring, in other words, was not simply something firms chose to do in response to wage differentials. It was embedded in trade law, statistical categories, and formal policy channels that made the dispersion of production across sovereign borders a codified feature of American industrial strategy.

Such U.S. policy architecture complicates narratives that reduce offshoring simply to cheap foreign labour. Cost differentials mattered, but they operated within legal and tariff infrastructures that made global assembly legible and profitable. Successive rounds of GATT negotiations reinforced these dynamics. The Kennedy Round in the 1960s and the Tokyo Round in the 1970s lowered trade barriers on finished electronics (Kageenu 2022), further incentivising U.S. firms to shift labour-intensive assembly to locations where they could arbitrage wage differentials against tariff reductions.

Domestic conditions sharpened these incentives. U.S. electronics manufacturing wages rose nearly ten percent per year through the 1970s, (DeSilver 2018) and the politics of labour recruitment grew increasingly contentious. American chip firms had experimented with recruiting feminised and racialised workforces that they thought were inherently suited to delicate assembly. But this framing fell apart when workers organised. The American Indian Movement’s occupation and shutdown of Fairchild’s Navajo reservation plant illustrated how U.S. production sites were vulnerable to political disruption (Nakamura 2014). Thus, electronics companies relocated their facilities offshore to places with “political stability,” lower wages, and less militant workers. For RCA specifically, this began first by hiring Eastern European immigrants in Camden, New Jersey, followed by Scotch-Irish Americans in rural Indiana, then African Americans in Memphis (Cowie 1999). Only after RCA had exhausted “desirable” sources of labour in the United States did it offshore to places like Mexico and Taiwan (Nakamura 2014).

Underwritten by authoritarian governance, Taiwan offered such stability. The U.S. government actively encouraged offshoring to Taiwan. As the KMT regime was representative of “Free China,” significant American aid already went to Taiwan. Private American investment would further serve U.S. Cold War priorities by stabilising Taiwan’s anti-communist regime through export-led growth (CFR 2025). Therefore, American aid officials and Taiwanese planners collaborated to establish export processing zones and attract U.S. firms. Declassified U.S. cables confirm Washington’s interest in Taiwan’s EPZ experiment as a replicable model (US Embassy ROC 1973). For firms like RCA, Taiwan’s appeal lay not only in low wages or export incentives, but also in a U.S.-backed authoritarian KMT regime that reduced labour disruption risk.

RCA’s Labour Regime on the Shop Floor

Authoritarian labour laws and export-oriented institutions established the preconditions for Taiwan’s electronics labour regime, but RCA and similar multinationals made that regime concrete on the shop floor. Their practices operated across three registers of control: spatial and demographic governance over recruitment, housing, and movement; economic and organisational discipline through wage structures and corporatist unionism; and epistemic control through performative regulation and suppressed accountability. RCA’s Taiwan operations are especially revealing because of the company’s foundational role in Taiwan’s semiconductor story and the unusually rich evidentiary record left by its later litigation.

Dormitories, Checkpoints, and the Gendered Workforce

Managers controlled almost all aspects of workers’ lives, spanning recruitment, training, housing, incentives, and time management. Employers consciously used martial law to secure control over the factory workforce. Arrigo details how unions, media, military police, and personnel office hierarchies facilitated such control (Arrigo 1985).

Gender was a key element of managerial recruitment. RCA specifically sought young women, valued across the export electronics sector for their supposed dexterity and docility (Nakamura 2014; Jobin 2025). However, Taiwan’s particular configuration was shaped by migration, dormitories, and authoritarian labour governance, evolving into an ATP labour regime with distinct disciplinary mechanisms.

Gendered recruitment intersected with family and rural-urban migration patterns. Patriarchal family structure often permeated factory women’s lives. Although young factory women typically worked temporarily before marriage, their earnings played a crucial role in sustaining family livelihoods and financing the education of younger siblings (Arrigo 1985). Such temporality reduced the likelihood that these factory women would organise and bolstered managerial power over a constantly rotating workforce. Many young women who got jobs at one of RCA’s “model factories” were often privileged 外省人, “waishengren/mainlanders,” who fled with the KMT and considered themselves lucky (Former RCA Worker 2026, 2). KMT-affiliated youth programmes had conditioned them to follow authority. If anyone stepped out of line, covert agents, informants, or police would quickly harass or blacklist her (Y. Chen et al. 2019).

Dormitories extended managerial control beyond the factory confines. Managers misleadingly narrated dormitory housing as a benevolent employee “benefit.” Arrigo initially describes the RCA dormitories as “model” facilities with airy halls, clean bathrooms, and house mothers (Arrigo 1985). But this welfare “perk” disguised constant surveillance, curfew enforcement, and social control. The dormitories were “enclosed in a compound next to the factory, with a single gate and checkpoint [often guarded by KMT military police] where all must sign in and out” (Former RCA Worker 2026, 2). Given their low wages, many women workers had scarce alternative urban housing options. Panoptical dormitories thus became factory extensions, allowing managers to secure punctuality, normalise long shifts, constrain collective organising, and continue supervising workers. Managers justified dormitories through paternalistic rhetoric of “care” and protection of women’s virtue (Kung 1995). The “meager dormitory environment and lack of privacy” became a severe strain over time (Arrigo 1985).

State and corporate actors also presented the factory-dormitory complex as an extension of the family and school, summed up in the slogan 以廠為家，以廠為校, “take the factory as your home, the factory as your school” (陳信行 2006). This ideology treated factory women as those in need of discipline and uplift, legitimising their tight regulation in company housing (Hsiung 1996). Materially, these measures served to limit factory women’s autonomy. The KMT’s ideology of moral order dovetailed neatly with employers’ need for a disciplined, trouble-free labour force.

Figure 1. A Taiwan factory dormitory during Arrigo’s late-1970s fieldwork (Arrigo 2025). Bunk beds at close quarters with no partitions and a single entry point made every occupant visible to house mothers and security officers.

But the “model” dormitory benefits were temporary. Following the 1974 oil crisis, multinationals shifted toward cheaper, more provisional dormitory arrangements (Arrigo 1985). Having already established a framework of residential control and surveillance, managers cut back on the expensive benefits while retaining the disciplinary infrastructure.

Wage Design as Coercion

Managers did not merely rely on walls. They also converted wage structures into instruments of compliance and punishment. Managers often attached substantial “bonuses” to base wages, which workers forfeited for “offenses” like being five minutes late, taking sick leave, or refusing overtime (Arrigo 1985). Because overtime pay was calculated on the no-bonus base wage alone, the effective overtime rate was far lower than the multiplier implied. Further piece-rate pay frameworks, along with speed and quality output targets, allowed RCA managers to exploit workers without overtly appearing coercive. This is where labour process theory is particularly applicable (Braverman 1974). Gamified production, quotas, and performance pay bonuses enabled workers to discipline themselves.

An RCA personnel manager even explicitly admitted to Arrigo that he had invoked the KMT party-state’s martial law authority to suppress a factory strike (Arrigo 2025). The manager also proudly described how RCA deliberately designed its wage package to coerce overtime compliance. If workers refused overtime, the resulting pay reduction was structured to “piss the workers off” enough that they would quit voluntarily. This psychological manipulation served a precise fiscal purpose. By inducing voluntary departures rather than issuing dismissals, RCA avoided paying severance and could arbitrarily lower its labour costs by approximately six percent (Arrigo 2025). The manager’s candour transforms the structural account of state-corporate alignment into a documented management strategy in which KMT martial law enforcement and wage design operated as complementary instruments to optimise labour cost.

Wage structures that individualised punishment and reward also fragmented solidarity, particularly when combined with dormitory governance that isolated workers from family and subjected them to surveillance. With collective action foreclosed, workers’ primary coping strategies tended toward keeping bonuses, individual bargaining, quitting, or other informal tactics rather than collective disruption. When individual grievances did surface, often regarding excessive overtime or harsh dorm rules, they usually led to minor concessions or dismissal. Workers perceived as troublemakers were fired (賴建寰 2012). Such heavy-handed governance caused union and strike rates to remain very low even after they became legal following Taiwan’s democratic transition (Congju 2019).

Rather than serve workers, RCA’s enterprise union furthered this corporatist control. One particularly telling anecdote concerns RCA workers discovering that their managers deducted union dues from their already low wages. Several women subsequently submitted their resignations, prompting an American manager to respond, “You want to organise a union, not me” (Hsin-Hsiang Chen 2025). The exchange demonstrates that unions could categorically exist but remain opaque and imposed upon workers, revealing the precise condition of enterprise-level unionism under authoritarian corporatist frameworks. In interviews decades later, former RCA workers recall that during the 1970s, they could not speak up and that there were “not really” unions or support structures available (Former RCA Worker 2024). One worker noted that she had to express discontent through RCA’s internal hierarchy “or face severe punishment” (Former RCA Worker 2024).

Performative Regulation and Knowledge Suppression

Beyond helping suppress labour movements, the KMT’s regulatory enforcement regime also served foreign capital. When RCA was later found to have repeatedly violated the Labour Safety and Health Act, the general manager was convicted but fined only NT$6,000 (Hsin-Hsiang Chen 2025), roughly US$150 (UPenn 2026). The fine was so insignificant relative to the cost of compliance that it amounted not to deterrence, but to tacit permission.

The inspection record at RCA’s Taoyuan plant confirms this pattern. Between 1975 and 1991, government agencies conducted nine inspections and documented 53 violations (Sung and Chen 2015), including failures to install local ventilation, label toxic organic solvents, and provide legally mandated health examinations. Yet 16 years of documented noncompliance produced no meaningful remediation. The violations were recorded and left unaddressed, creating an appearance of oversight while production continued. RCA’s management knew its groundwater was contaminated, purchased distilled water for executives but not workers, and repeatedly failed to remediate violations after formal notice. Such choices only made economic sense where noncompliance carried no real consequences.

The same logic of performative oversight extended to how the KMT suppressed external documentation. The U.S. Embassy told researchers like Arrigo to stop investigating labour conditions and engaging with the tangwai (anti-KMT opposition) (Arrigo 2025). Despite holding U.S. citizenship, Arrigo had her field notes on RCA factory conditions seized by the Taiwan Garrison Command secret police. Agents reviewed and stamped every page before returning the materials.

Figure 2. Arrigo’s field notebook, seized and stamped page by page by Taiwan Garrison Command, with seal visible at bottom left (Arrigo 2025). Handwritten entries record company names including RCA, General Instruments, and Texas Instruments, wage figures, and references to “double accounting.”

The suppression of labour discourse extended beyond individual researchers to academic institutions. In 1978, Arrigo helped organise a labour conference at Tunghai University where RCA’s personnel manager and other industry figures described worker discontent and managerial strategy (Arrigo 2025). The department chairman intended to publish the proceedings, one of the few contemporaneous records of multinational labour practices under martial law. The publication never appeared. The government soon installed former Central Police University president Meiko Wong as Tunghai University president (Tunghai Univ. 2016), and the proceedings were buried. Arrigo was then “shut out” by the U.S. Embassy that had already urged her to stop the research. The resulting archival silence was not neutral. It was produced by the same state-corporate alignment that operated on the shop floor.

Feminisation, dormitory governance, enterprise unionism, and performative regulation enabled Taiwan’s electronics export sector to maintain a stable labour supply, constrain bargaining, normalise intense work rhythms, and externalise occupational risk. RCA’s Taiwan presence benefited from, and depended on, this hierarchy of discipline and risk distribution. The U.S. tariff regime, Cold War security posture, and Taiwan’s managed labour force served as complementary infrastructures. The United States provided the legal pathway for fragmented production. Taiwan provided a politically disciplined and gendered workforce. And both states collaborated in ensuring that the conditions under which that workforce laboured remained difficult to study, publish, or contest.

Figure 3. Women assembling television components at an RCA Taiwan factory (Teng 2007). No gloves, masks, or ventilation hoods are visible. Originally published in Taiwan Panorama to project industrial modernity.

The RCA Project and the “Technology Transfer” Labour Regime

Yet to characterise RCA as simply an exploitative extractor would be as misleading as celebrating it solely as a modernisation vector. RCA was both a pioneering foreign investor that helped Taiwan build its industrial base and a company whose labour control mechanisms and poor occupational safety practices left lasting physical and mental scars on its former employees. This duality is constitutive of how authoritarian developmental regimes legitimised themselves. The KMT’s claim to legitimacy required economic modernisation through modern facilities, increased exports, and employment. But maximising profitability required RCA to control costs, discipline workers, and externalise risk. The canonical story of Taiwan’s semiconductor ascent, centred on the 1976 RCA technology transfer project, was built atop this labour regime rather than apart from it.

Nineteen Engineers and a Founding Myth

Taiwan’s semiconductor history is often structured around a mid-1970s shift from labour-intensive assembly to higher-value production, with the “RCA Project” as its central milestone. The canonical account describes a four-year, roughly US$10 million initiative led by Minister of Economic Affairs Sun Yun-suan to transfer RCA chip technology to Taiwan (Patterson 2015). A retrospective from the Industrial Technology Research Institute (ITRI) highlights a 1974 meeting at which seven men, including Sun and RCA Laboratories Director Pan Wen-yuan, planned Taiwan’s semiconductor development (ITRI 2023). In 1976, ITRI signed a technology transfer and licensing contract with RCA, then sent 19 Taiwanese engineers to RCA facilities in the United States for integrated circuit design and manufacturing training. On returning in 1977, they helped build Taiwan’s first IC demonstration factory, whose 70% yield surpassed RCA’s roughly 50% yield in New Jersey (ITRI 2023). The project helped produce Taiwan’s first local chip company, United Microelectronics Corporation, spun off in 1980. Yet as these engineers absorbed RCA’s expertise, they also encountered and adapted its labour control techniques, which later travelled into indigenous chip firms (Hsiao 2025).

What the Pilot Line Required

But the pilot line’s success depended on institutional conditions the canonical narrative leaves unexamined. Three specific dependencies make this concrete. First, the RCA Project’s pilot IC fabrication line required a workforce already habituated to the exacting procedural discipline of electronics production. This work required contamination protocols, microscopic component handling, time-sequenced process steps, and quality inspection routines. That workforce did not materialise spontaneously. It was produced over the preceding decade through the KMT-RCA labour regime. The EPZ-based electronics sector, organised through feminised recruitment, piece-rate incentive systems, and dormitory governance, trained tens of thousands of young women in precisely these capacities. Their daily work assembling and testing transistors, capacitors, and television components under RCA and similar multinationals constituted a vast, informal training infrastructure in standardised precision manufacturing. When the 19 ITRI engineers returned from RCA’s U.S. facilities in 1977, they did not build the demonstration factory alone. They staffed it with workers drawn from this existing labour pool, operators whose compliance with procedural standards had been shaped not by semiconductor-specific education but by years of managed factory discipline. The pilot line’s celebrated 70% yield was thus not simply a triumph of transferred engineering knowledge. It also reflected the quality of a workforce whose precision and obedience had been institutionally produced through martial law labour structures.

Second, the RCA Project required political predictability across a multi-year timeline, a condition that technology transfer’s substantial upfront costs and delayed returns make especially sensitive to disruption. RCA and the KMT state had to guarantee that training investments, intellectual property transfers, and pilot-line construction would not be jeopardised by labour conflict, political instability, or public controversy over working conditions (S.-J. Chen et al. 2003). Authoritarian labour governance directly supplied this guarantee. The interlocking mechanisms of union control, security surveillance, and strike prohibition ensured that the labour disruptions, which had plagued RCA’s domestic operations from Camden to Memphis to the Navajo reservation, were structurally precluded in Taiwan. This insulation from shop floor conflict constituted a subsidy to technology transfer that never appeared in fiscal accounts but was no less consequential for the RCA Project’s success. It is difficult to imagine RCA committing proprietary IC manufacturing processes to a country where those processes might be interrupted by the very workforce executing them.

Third, the canonical narrative implicitly treats the RCA Project as an upward trajectory away from labour-intensive production toward a high-skill national economy, as though technology transfer and labour exploitation occupy different historical phases. But semiconductor production has never shed its dependence on labour-intensive ATP. Even as the ITRI pilot line demonstrated Taiwan’s capacity for front-end wafer fabrication, the island’s electronics sector continued to expand its back-end assembly, testing, and packaging operations. The RCA Project did not eliminate the need for a controlled, low-cost ATP workforce. It added a new layer of high-value production on top of it. The same institutional architecture that governed ATP, including EPZ spatial enclosure, dormitory housing, constrained unionisation, and administrative mediation, continued to operate alongside and beneath the new semiconductor fabrication facilities. Indeed, as Taiwan spun off UMC in 1980 and later established TSMC, these firms replicated many of the managerial techniques their founders had absorbed during the RCA era. Those techniques encompassed not only IC process engineering but also the labour governance practices that had made RCA’s Taiwan operations profitable. The layered division of labour between capital-intensive fabrication and labour-intensive ATP was not a transitional phase but a structural feature of semiconductor production (Warf 2020), one that the RCA Project’s institutional descendants inherited and perpetuated.

The RCA Project sat atop the labour regime, drawing on a disciplined workforce the regime had produced, a political stability the regime enforced, and a layered production structure the regime sustained. In turn, its success legitimised the very state-capital alignment that had made ATP exploitation profitable.

Afterlives: Toxicity, Litigation, and the Persistence of Managed Labour

What Democratisation Made Contestable

Taiwan’s democratisation, along with the growth of environmental and labour NGOs, shifted what could be publicly contested. Jobin’s study of hazards and protest in Taiwan describes how rapid industrial development under authoritarian KMT rule was effectively a “slash and burn” policy, and it treats electronics hazards as emblematic of the paradox of “clean” industry (Jobin 2010). Dramatic catastrophes often affect public image much more than chronic pollution and health risks. The same study explicitly frames RCA’s Taoyuan plant pollution and worker cancers as part of the larger story of Taiwan’s electronics boom and the struggle for visibility. From this perspective, the RCA case illustrates how invisibility sustained earlier labour regimes. It also shows how coalitions of workers, activists, and experts have redefined the legal and scientific contestation of toxicity for a renewed labour struggle (Hsin-Hsing Chen 2023).

RCA’s Toxic Legacy and Contested Causation

Structural labour violence is not always immediately visible. In electronics, chemical exposure is one of the most consequential and insidious forms. Throughout its decades of operation in Taiwan, RCA used chlorinated solvents like trichloroethylene (TCE), tetrachloroethylene (PCE), trichloroethane (TCA), and methylene chloride as degreasers and cleansers on its production lines (Sung and Chen 2015). Workers absorbed these chemicals through inhalation, skin contact, and contaminated drinking water, while the solvents leached into surrounding soil and groundwater. These solvent concentrations exceeded legal limits, and the soil contamination reached extreme multiples of remediation standards. More than 80,000 workers, mostly young women, passed through RCA’s Taiwan factories during the three decades before the company shifted to water-based cleaning methods in the early 1990s (Jobin 2025). For the entirety of that period, the labour regime’s discipline, speed requirements, and dormitory containment kept production flowing without meaningful interruption or scrutiny.

Figure 4. A remediation notice at RCA’s former Taoyuan site, photographed during a January 2026 field visit (Former RCA Worker 2026). The sign designates an active groundwater pollution remediation project, ongoing more than 30 years after RCA’s closure in 1992.

RCA’s handling of these hazards followed a pattern of substitution rather than elimination (Sung and Chen 2015). TCE served as the main degreaser, later replaced by PCE, then by TCA. Each swap exchanged one toxic compound for another. The company knew its groundwater was contaminated and that activated carbon filters in shop floor drinking fountains could not remove hazardous pollutants. RCA purchased distilled water for management but not for “common workers.” The industrial risk distribution thus mapped onto occupational hierarchies: workers bore significant toxic exposure while management insulated itself. Corporate paternalism and internal messaging in the RCA Home Magazine, the company’s factory publication, celebrated welfare and modernity while obscuring such risks (Hsin-Hsiang Chen 2025). Interviews with former RCA women factory workers confirm that, at the time of their employment, they had no idea their workplace was contaminated (Former RCA Worker 2024, 1).

Evidence of contamination first surfaced through an unlikely channel. Around the end of 1986, Taiwan’s Investment Commission was notified that RCA’s parent company had changed hands through a U.S. merger, transferring ownership to General Electric (GE) (Li 2025). GE subsequently sold the operations to Thomson. Ironically, this corporate succession triggered the first pollution investigations, as environmental consulting firms conducted site contamination assessments as standard due diligence during mergers and acquisitions. Public evidence suggesting RCA had used toxic contaminants in its former factory therefore emerged at the very end of Taiwan’s martial law era, three decades too late for many factory women (Jobin 2025). RCA’s Taiwan factories closed in 1992, but the contamination they left behind was only beginning to become publicly visible.

The litigation that followed proved extraordinarily difficult. Former RCA workers filed suit in 2004, but proving disease causality decades after exposure posed immense evidentiary challenges (Jobin 2025). RCA’s Taiwan successors claimed that “we don’t have anything at all—we have no data because everything was burned down” (Hsin-Hsiang Chen 2025), and the company itself no longer existed in its original form. Anticipating liability from the emerging pollution revelations, RCA Taiwan colluded with its parent entities, Technicolor and Thomson, to remit over NT$3.2 billion, roughly US$80 million (UPenn 2026), in company assets to banks in France and other foreign jurisdictions between July 1998 and January 1999. The Taipei District Court later identified this transfer as a “fraudulent transfer of assets and malicious evasion of debt” (Sung and Chen 2015), deliberately designed to decrease the company’s capitalisation below its anticipated liabilities to the poisoned workers. The same transnational corporate architecture that facilitated offshore production was repurposed to offshore accountability. Global value chains, in this light, are not merely mechanisms for optimising labour arbitrage but structures through which corporations can disaggregate legal liability across jurisdictions.

RCA’s litigation strategy extended beyond jurisdictional complexity to manufacturing scientific doubt (Sung and Chen 2015). Its legal team retained Dr. Steve Lee, an oncological radiologist, to testify on causation. The court found him unqualified in epidemiology and toxicology, the fields relevant to chemical exposure and disease. Despite the International Agency for Research on Cancer classifying trichloroethylene as a Group 1 carcinogen, Lee claimed RCA’s operations did not cause the workers’ cancers. The judges condemned his testimony as an “attempt to confuse and mislead” the court, made with the “obvious intention to deceive.” The episode shows how corporations can weaponise credentialed expertise against sick workers. What Jobin calls “epistemic and psychological violence” operated through a specialist whose credentials lent superficial authority to claims outside his competence (Jobin 2025). Workers denied safety information and collective voice could not produce contemporaneous exposure records that would have simplified causation decades later. The epistemic violence of the courtroom thus extended the epistemic closure of the shop floor. Despite hundreds of plaintiffs, multiple lawsuits, and more than a decade of litigation (Li 2025), the former RCA workers ultimately secured compensation.

After years of hearings, the Taipei District Court ruled in favour of hundreds of RCA worker-plaintiffs and ordered compensation on April 17, 2015, in what became Taiwan’s first class-action labour lawsuit (Sung and Chen 2015). Court decisions from 2015 onward recognised multicausal links between the chemicals and diverse cancers and illnesses, culminating in a 2022 Supreme Court decision recognising the psychological stress caused by past exposure (Jobin 2025). A Taiwan High Court ruling in January 2025 ordered further compensation (BHRC 2025). The RCA case forced courts to confront corporate liability for long-latency disease amid missing records and contested epidemiology. The legal struggle became bound up with martial law transitional justice debates over what it means to prove harm with decades-long causal chains.

Figure 5. Former RCA workers outside the Taipei District Court after the April 2015 ruling (H.-H. “Indy” Liu and Chu 2015). The banner reads 勝訴, “victory,” but the placards bear photographs of deceased former workers who did not survive the litigation.

The Transitional Justice Gap

Yet the transitional justice framework within which that legal struggle unfolded was not designed to accommodate cases like RCA’s. Taiwan’s post-democratisation reckoning with the White Terror has overwhelmingly centred on discrete acts of state violence. These include the execution and imprisonment of political dissidents, the persecution of Taiwanese cultural and intellectual elites, and the ethnic dimensions of mainlander-dominated authoritarian rule. The 2018 Transitional Justice Commission focused on rehabilitating political victims, declassifying political archives, and removing authoritarian symbols (Executive Yuan 2024). These were necessary interventions. But they defined authoritarian harm primarily through a political persecution lens that renders labour suppression largely invisible.

The RCA case exposes a category of martial law violence that does not fit this template. It was not a single act of state terror but a slow, cumulative, corporate-statist co-production. The state security apparatus enabled RCA to expose workers to toxic chemicals for decades. The specific underlying mechanisms include Garrison Command secret police quietly embedded in factories, corporatist unions that neutralised worker voice, and administrative mediation channels that shielded corporate liability from public scrutiny. But the women who absorbed chlorinated solvents on RCA’s production lines were not political dissidents. They were workers whose capacity to identify, contest, or even understand occupational hazards was systematically foreclosed by the same authoritarian infrastructure that imprisoned democracy activists. Their cancers and chronic illnesses represent an embodied archive of martial law governance that conventional transitional justice categories struggle to recognise. The framework’s categorical design reproduces the epistemic exclusion Spivak identifies (Spivak 1988). The vocabulary of recognition structurally cannot accommodate cumulative, corporate-mediated, and embodied harm.

Compounding this analytical challenge, many police and military records concerning factory-level surveillance, labour informant networks, and corporate-security coordination remain classified or were destroyed during Taiwan’s political transition (Su 2025). Despite lifting martial law in 1987, the KMT only allowed direct presidential elections in 1996, giving them ample time to destroy evidence of their more insidious and less visible abuses (總統府 2026). The absence of these records is not simply an evidentiary gap, but it is itself a product of the regime’s logic of concealment. Reconstructing how the secret police operated within export electronics factories thus requires archival triangulation. This paper thus combines surviving field notes seized and stamped by the Garrison Command, court documents produced decades later through litigation, oral histories from former workers and researchers, and corporate materials that inadvertently document workplace conditions. Such fragmentary reconstruction is methodologically imperfect, but it is the only available means to render visible a form of authoritarian harm that was designed to leave no trace.

Contemporary political dynamics further constrain accountability. The KMT, which administered the martial law apparatus documented in this paper, controls Taiwan’s Legislative Yuan following its 2024 electoral gains (Dotson and Levine 2024). That institutional continuity helps explain why Taiwan’s transitional justice process has not extended to labour dimensions of authoritarian governance and why archival disclosure concerning factory-level surveillance remains limited. Cases like RCA’s, where the state co-produced with multinational capital an enduring regime of toxic exposure and labour exploitation, demand an expanded conception of transitional justice.

For historians, the RCA litigation is not merely an epilogue. It reveals the hidden premises of earlier developmental narratives. When corporate statist structures disciplined workers through dormitory enclosure and constrained voice, they could neither identify nor contest toxic risks in real time. Toxicity was not a byproduct but a structured risk externalisation, which the labour regime’s compliance architecture helped conceal. Decades later, coalitions of workers, activists, and experts carried that struggle into courts, epidemiological studies, and public campaigns, redefining the terms of contestation. Even today, under the auspices of the Taoyuan County Original RCA Corporation Employees Caring Association, former RCA factory women are fighting to clean RCA’s contaminated Taoyuan factory site and turn it into a workers’ rights museum (Former RCA Worker 2026).

RCA’s role, then, cannot be reduced to either “technology transfer” or “exploitation.” It was both an institutional partner in upgrading narratives and an exemplar of how export electronics production could be organised under authoritarian governance through feminised labour, limited voice, and risk externalisation. These two dimensions operated simultaneously, not sequentially. Separating them, as existing historiography has done, reproduces analytically the very concealment that the martial law regime enforced politically.

Modern Continuities: The Labour Regime Beyond Martial Law

If the labour regime described above was only an effect of authoritarian rule, democratisation should have dismantled it. Martial law ended in 1987, independent unions became legal, and direct presidential elections followed in 1996. Yet the regime’s logic survived in two directions: within Taiwan, where Southeast Asian migrant labourers increasingly filled assembly, testing, and packaging (ATP) roles once occupied by young Taiwanese women, and across the broader semiconductor geography, where value-chain pressures reproduced comparable labour outcomes without direct martial law. RCA was not an isolated episode. It was an early template for offloading risk onto workers with the least political leverage.

From Factory Women to Migrant Workers

The workers who now fill many of these roles come primarily from the Philippines, Vietnam, Thailand, and Indonesia (勞動部 2026), though many more remain undocumented (Beltran 2025). Interviews from 2024 show the persistence of long shifts, dormitory dependency, broker control, and constrained mobility. A Filipino migrant worker at a TSMC supplier in Hsinchu described a twelve-hour evening-shift rotation, six days per week, employer-provided dormitory housing, and monthly pay of about NT$35,000 (Migrant Worker 2024a). Her broker controlled her bank account, deducted wages, confiscated her passport, and prevented her from switching jobs (僑務委員會 2026). Another migrant worker reported comparable hours and continued dormitory-fee deductions even after moving into external housing (Migrant Worker 2024b; Niece 2024). Brokerage endures because it transfers recruitment, documentation, housing, and dispute-management costs from employers onto workers (Transparentem 2025). Democratisation did not abolish coercive labour discipline. It marketised it.

The COVID-19 pandemic exposed how dormitory governance could intensify into explicit confinement. During Taiwan’s 2021 outbreak, the KMT-controlled Miaoli County restricted migrant workers to travel only between dormitories and factories while others moved freely (Templeman 2018; Davidson 2021). Migrant worker advocates described the result as workers being “locked up” in dormitories (Van Hung 2024). When workers objected, Miaoli’s KMT magistrate asked, “You tested positive, and even died because of the virus. Why talk about human rights now?” (Chien and Qin 2021). The party that constructed Taiwan’s corporatist labour and EPZ governance apparatus still administers the inspection, mediation, and dormitory oversight machinery through which migrant workers must seek recourse (臺北市政府全球資訊網 2025).

Gendered bodily discipline also persists. At Compal Electronics, a major Apple and Google contractor, thousands of Vietnamese workers protested extreme overwork, illegal pay deductions, and inhumane rules (吳睿騏 2020). One rule reportedly fined pregnant workers US$6,000-7,000, roughly a year’s wages (Van Hung 2024; Electronics Watch 2024). Where martial-law managers justified dormitory surveillance as protection of women’s “virtue,” contemporary subcontractors directly penalise reproduction itself. In both cases, the female body is governed as productive capacity whose pregnancy, illness, or fatigue becomes a violation of the labour regime’s terms.

Migrant workers also lack the democratic leverage that might force enforcement. Non-citizen workers cannot vote or engage in election-related work in Taiwan (Everington 2023). Although they formally possess labour rights, broker-mediated employment, employer-tied visas, language barriers, and deportation risk constrain collective action (A. R. Pan 2023; Tseng 2025). Official discourse can also naturalise this instrumentalisation. In 2024, Labour Minister Hsu Ming-chun justified plans to recruit workers from northeast India by noting their “similar skin color and diets,” Christianity, and aptitude for manufacturing (Madhok and Chang 2024). As Nakamura shows in her study of Fairchild’s recruitment of Navajo women, firms and states routinely recast whichever vulnerable population is cheapest and most captive as naturally suited to electronic assembly (Nakamura 2014).

The New Southbound Policy (NSP) extends this brokerage function into foreign policy. Under industry-academia programmes, Southeast Asian students have been recruited to Taiwanese universities and then channelled into electronics and semiconductor factory shifts, while brokers extract fees and schools depend on student-worker revenue (H. Liu 2025). The 2024 U.S. Trafficking in Persons Report found that traffickers exploited relaxed NSP visa rules to subject Southeast Asian students to forced labour (AIT 2024), and Taiwan’s National Human Rights Commission concluded that weak oversight enabled disguised labour importation (高華謙 2025). The KMT once recruited rural Taiwanese women through promises of wages and mobility. The NSP recruits foreign students through promises of education. In both cases, intermediaries convert aspiration into disciplined industrial labour.

Semiconductor interests often outweigh these workers’ claims. Taiwan’s chip industry has acquired “sacred mountain” national security status (Hsiao 2025), generated more than US$165 billion in 2024 revenue, and accounted for 20.7% of GDP and 60% of exports (USITA 2025; G. Chen 2025). Migrant workers report that local labour authorities prioritise operational continuity over complaints about hours, dormitories, and brokers (Niece 2024). The justification has shifted from anti-communist stability to national security. For workers, the effect is similar.

Value Chains as Labour Discipline

The same logic has travelled beyond Taiwan through semiconductor value chains. Buyer-driven production networks allow lead firms to govern suppliers through standards, pricing pressure, and the credible threat of relocation rather than ownership (Gereffi 2018). When a few dominant buyers command advanced chip orders, specialised suppliers face quasi-monopsony. Margin pressure then flows downward into wages, hours, safety investment, and recruitment practices. No actor needs to consciously reproduce RCA-era labour control. The value chain only needs to reward the same cost-minimising practices that authoritarian institutions once enforced directly.

South Korea illustrates this continuity within a democratised political economy. Samsung and SK Hynix dominate global memory production through subcontracting regimes that mirror Taiwan’s supplier hierarchies (Y. Lee and Cha 2026). Korean chaebol firms historically suppressed independent labour organising with state support, and Samsung did not permit an enterprise union until 2019 (Seol 2024), after activists had exposed hundreds of cancers, chronic illnesses, and deaths among semiconductor workers (SHARPS 2018). Even reforms such as Korea’s 52-hour workweek cap and new subcontractor-bargaining legislation have not undone the underlying incentives (Jang et al. 2025). Smaller suppliers employing undocumented workers from China and Southeast Asia use piecework frameworks that encourage excessive hours and circumvent legal limits (Chun 2025). Lead firms need not suppress unions directly when pricing power ensures that the subcontractors employing the most vulnerable workers cannot easily tolerate them.

The Philippines reveals a spatial and administrative version of the same mechanism. Philippine export zones, modelled partly on Taiwan’s Kaohsiung EPZ, concentrate electronics ATP production under the Philippine Economic Zone Authority (UNIDO Vietnam 2015; PEZA 2020). Despite constitutional labour protections, union density in electronics remains around six percent (PSA 2016). When workers at one Metro Manila ATP plant organised, the subcontractor closed the facility and relocated nearby with a non-union workforce (Philippine Supreme Court 1999). Electronics organisers also face police visits, red-tagging, and violence, including the murder of organiser Dandy Miguel near a Nexperia ATP plant in Laguna (CTUHR 2022; Nexperia Union 2025; Human Rights Watch 2024; Stephanie 2023). Contractualisation fragments solidarity further: seven in ten Philippine electronics workers are temporary agency hires despite years at the same plant (Oliquino 2016). A 2017 factory fire prompted passage of the Occupational Safety and Health Standards Act, but inspections remain rare and fines weak (Salamat 2017; EILER 2018; CTUHR/IOHSAD 2025).

These cases do not replicate Taiwan’s martial law regime. They show how its labour outcomes can be reproduced through different institutional routes. PEZA’s investment-first mandate, subcontractor flight after unionisation, Korean supplier piecework, and Taiwan’s broker-mediated migrant labour all serve a similar structural function: they reduce the capacity of workers at the bottom of the value chain to contest risk. The foundational architecture of semiconductor profitability, first consolidated in Taiwan under authoritarian conditions, remains durable because it has been embedded in markets, contracts, and production networks.

Counter-Archives and Transnational Solidarity

These shared patterns have also generated transnational counter-movements. Taiwan’s TAVOI, which helped organise the RCA litigation, built ties with South Korea’s Supporters for Health and Rights of People in the Semiconductor Industry (SHARPS) (Former RCA Worker 2024, 1; Wang 2025). SHARPS emerged after Hwang Yu-mi’s 2007 leukaemia death at a Samsung fabrication plant and campaigned for more than a decade over occupational cancers and fatalities (SHARPS 2025). In the Philippines, the Institute for Occupational Health and Safety Development (IOHSAD), the Metal Workers Alliance of the Philippines, and the GoodElectronics Network have documented chemical exposure and built worker-led safety committees (CTUHR/IOHSAD 2025).

GoodElectronics has become the main transnational platform linking these struggles. In 2025, it moved its global secretariat to a Philippine-based coalition, shifting the network’s centre of gravity toward the Global South (GoodElectronics 2025a). That year, GoodElectronics, IOHSAD, and the Asian Network for the Rights of Occupational and Environmental Victims convened a Manila session where organisers from Korea, Taiwan, Thailand, Indonesia, and the Philippines exchanged testimony on chemical poisoning and strategised around ILO Convention 170 ratification (GoodElectronics 2025b).

Artistic work has extended these counter-archives beyond labour circles. At the Manila session, organisers screened Eunhee Lee’s Colorless, Odorless (2024), which combines leaked clean-room footage, archives, and testimonies from Korean and Taiwanese semiconductor workers to make invisible hazards visible (GoodElectronics 2025b; E. Lee 2024). The film has since circulated through institutions in Barcelona, Taipei, Copenhagen, Kuala Lumpur, and Beijing.

Such coalitional and cultural work embodies TAVOI’s insistence that “our bodies are our only evidence” (GoodElectronics 2025b; Ricaurte 2022). These networks do more than protest. They build alternative archives, scientific literacies, and public narratives that challenge the industry’s image as clean, efficient, and progressive. RCA thus leaves a double legacy: it helped legitimate Taiwan’s semiconductor upgrading, but it also anchors a counter-history of industrial hazard and labour exploitation that continues across East and Southeast Asian supply chains.

Conclusion

This paper has argued that RCA and the KMT developmental state co-produced Taiwan’s electronics labour regime, and that this regime was not incidental to Taiwan’s semiconductor ascent but constitutive of it. The same institutional preconditions that enabled technology transfer also enabled labour exploitation. The canonical story of the 1976 RCA Project as a triumph of technocrats and engineers obscures the gendered, coerced, and chemically poisoned workforce upon which that project depended.

The implications extend beyond historiography. More than US$500 billion in semiconductor subsidies announced since 2020 rest on the premise that chip production serves the national interest (Ravi 2022). Yet national-interest framings repeatedly subordinate worker welfare to production targets. Public subsidy programmes still do not sufficiently condition funding on enforceable occupational safety standards or organising protections, and chemical exposure rules cover only a fraction of substances used in fabrication (Rodrigo 2024). When governments invoke “national security” to shield chip firms from scrutiny, they echo the KMT’s earlier use of anti-communist stability to suppress labour contestation (OECD 2025).

For Taiwan, this history also raises unresolved transitional justice questions. The official framework has focused primarily on political persecution, leaving state-sanctioned labour exploitation at the margins. Recognising the poisoned women on RCA’s lines as victims of authoritarian governance would not diminish political persecution cases. It would reveal how martial law operated not only through spectacular repression, but also through the ordinary reproduction of factory discipline that made export growth profitable.

Finally, this paper challenges how societies narrate technological achievement. Taiwan’s semiconductor achievement and its labour costs are not competing narratives. They are one integrated history. The engineers who built TSMC and the women who assembled RCA’s transistors inhabited the same political economy. Acknowledging the latter does not diminish the former. It shows what technological achievement required, and at whose expense.

That acknowledgement is urgent because the evidence is disappearing. Former RCA workers are now in their sixties and seventies; some died during litigation. Researchers’ seized notes remain largely unpublished, surveillance records remain classified or destroyed, and migrant worker organisers document contemporary reproduction without secure preservation. Counter-archives built by TAVOI, SHARPS, GoodElectronics, and allied organisers show that workers already know what dominant narratives obscure. The task is to ensure that their evidence is not, once again, seized, stamped, and filed away.

Acknowledgements

The author thanks the former RCA workers, labour organisers, legal advocates, scholars, archivists, and mentors who made this research possible.

Funding

This research received support from the Yale Brady-Johnson Grand Strategy Program, the Yale Blue Center for Global Strategic Assessment, the Yale Council on East Asian Studies, the Yale Council on Southeast Asian Studies, the Yale Jackson School of Global Affairs, the Yale History Department, Grace Hopper College, the Yale Institution for Social and Policy Studies, and the Obama Foundation.

CRediT author statement

Ethan Chiu: Conceptualisation, data curation, formal analysis, investigation, methodology, writing – original draft, and writing – review and editing.

Declaration of interest

The author reports no competing interests to declare.

Ethics and consent statement

This research involving human participants was reviewed by Yale University’s Institutional Review Board and determined exempt under IRB Protocol No. 2000037477. Interview participants were adults who voluntarily agreed to participate after receiving study information about purpose, risks, confidentiality protections, and the right to withdraw. Participants gave informed consent before interviews. Interview material is anonymised or described by role where identification could compromise privacy, confidentiality, or safety. No directly identifying interview material is published without consent.

Data availability statement

Most interview data supporting this article are not publicly available because disclosure could compromise participant privacy and confidentiality. Publicly available sources are cited in the references.

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Introduction

On January 1, 1959, dictator Fulgencio Batista fled Cuba, leaving Fidel Castro’s 26th of July Movement in power. This marked the end of years of guerrilla warfare and popular uprising against the violent oppression of the Batista regime. In a matter of days, Castro entered Havana and began to establish a provisional government. In the four years to come, Havana and the island at large would undergo a series of agricultural, educational, and urban reforms. Castro’s government was in search of a way to materialize the revolution in Cubans’ daily lives; it was in that moment that housing and the built environment acquired political significance. In the immediate aftermath of the Revolution, not many understood that “in a matter of months and in the context of the Cold War, the Soviet Union would displace the United States as Cuba’s main political ally and trading partner.”¹ And so, Cuba rapidly bore witness to the importation of Soviet urban planning principles like standardization and collective services, the transfer of institutional planning to the Ministry of Construction of Cuba (MICONS), and the adoption of Soviet housing infrastructure and neighborhood layouts.² Determining the effectiveness of early Soviet urban planning in Havana after the revolution requires the examination of Soviet development precedents from 1922 to the Khrushchev era alongside an exploration of Havana’s urban design inspirations before and after 1959. It is also essential to study the progression of Havana’s newly acquired structures as Soviet influence and financial aid increased as a means of arriving at a measure of success in a client-state context. While Soviet urban planning in post-1959 Havana offered a framework for socialist engineering, its selective adaptation to Cuban conditions produced an uneven and ultimately unstable built environment that revealed as much about the limits of Soviet transfer and economic constraint as it did about the island’s revolutionary ambition.

Early Soviet Urban Planning

From the perspective of Cubans observing these transformations, Soviet principles were inextricably linked to socialism. After a more careful analysis of the historiography of mass affordable housing, this connection becomes less evident. What came to be known as the Soviet concrete panel housing system in client states like Cuba was not necessarily uniquely “socialist”. In the United States, for instance, Levittowns were built as early as 1947. These constructions were a post-World War II remedy; when veterans returned to American soil, “adequate housing was almost non-existent, so the government turned to developer William Levitt, who created this country’s first large-scale suburban housing complex on New York’s Long Island, christening it ‘Levittown’.”³ Like the mikrorayony, Levittowns were composed of rapidly constructed and simply designed identical affordable living spaces. Similarly, Western Europe was faced with the need for reconstruction of towns virtually destroyed and rendered permanently uninhabitable. In 1950, the First Housing Act was passed in West Germany, which “established the concept of ‘social housing’ and laid out a program of construction of 300,000 dwelling units each year up to 1956.”⁴ The speed, standardization, and affordability we associate with Soviet mass housing were well in existence before Khrushchev. The distinction between these earlier versions of centralized urban planning in capitalist cities and their Soviet counterparts, therefore, lies in the state purpose and social programming attached to it. Soviet construction was meant to integrate collectivist services and identity, redefining communal living as well as family life.

Early Soviet existence was centered around the idea of striving to build a new world. The material reimagining of the country’s landscape was tied to the idealism of revolutionizing and altering everything else. Soviet citizens saw themselves as “participants in a historic process of transformation, their enthusiasm for what was called “the building of socialism.”⁵ Construction plans were not just for the purpose of their utility. Instead, the Soviet Union characterized building through its relationship with lived space: privacy, communal services, queues, childcare, domestic labor. These goals were rooted in events that preceded the existence of the Soviet Union. Richard Stites notes, “In the Russian Revolution, architects and town planners had visions of reshaping an entire nation, of aligning the structures and anti-structures with high-speed economic development plans, of providing “social condensers” for the nurturing of a new socialist race of people.”⁶ This process involved the consideration of distance, in both a physical sense (population density) and a communal one (privacy and time spent in the home).  

The success of this vision had a symbolic element, as the foundations for the Soviet model were being conceived in the 1930s. The “General Plan for the Reconstruction of Moscow” was intended to set a precedent, and “provide a model of the socialist capital for foreigners and Soviet citizens to marvel at.”⁷ And, indeed, the Soviet urban planning model came to be an example for aspiring socialist countries like Cuba.⁸ “By 1963, almost every aspect of Cuba— including its political system, social structure, foreign relations, trading partners, and cultural production— had been transformed profoundly,…[reflecting] a period of heroic idealism.”⁹

But these ideals were soon met with the reality of different conditions on the ground, including the need to accommodate intergenerational family living—customary in Cuba—and access to communal services like groceries and personal items. At the onset of adopting socialist planning strategies on the island, the state of urban development revealed the remnants of the American presence that had been dominant just a few years earlier.  

Havana, being the capital of Cuba, was naturally in the midst of a modernizing urban project before the Revolution. At the time, the goal was to develop in order to accumulate capital and increase profit from the tourism sector.¹⁰ Plan Piloto (Pilot Plan) was overseen by Town Planning Associates, a design firm in New York City. It detailed the renovation of space in a modernist context, such as recommending that “a web of streets and green spaces must tie together the distant parts of Havana’s center.”¹² This direct context of innovative planning (1955-1958) prevents us from simply attributing modernist intervention in Havana as a product of “Sovietization”. That being the case, the years of 1959-61 encompassed rapid deviations from previous plans to reflect socialist policies. Felipe J. Prestamo became the first director of the Department of Physical Planning, which was established in 1960 to oversee city planning processes.¹³ In a paper he wrote years after immigrating to the United States, Prestamo recounts that “it became evident that the main concern of the government was to modify the dominant role of the city of La Habana”, essentially decentralizing the country and redirecting resources away from the capital.¹⁴ Beyond departing from the pre-revolutionary, market-oriented planning, this shift laid the institutional groundwork through which Soviet models of spatial organization would later be selectively adopted or resisted within the Cuban context. 

Figure 1. Urban comparison map from Plan piloto de La Habana.¹¹

Tracing the development of key Soviet urban planning principles requires visiting the places in which they were first tested, before being formulated and exported during the mid-twentieth century. These visions of standardization, zoning, and community living were tested and tried under the New Economic Policy (NEP). Baku, Azerbaijan, for instance, was a formerly capitalist city whose urban landscape transformed from 1924-1927.¹⁵ In her book Spatial revolution: architecture and planning in the early Soviet Union, author and professor Christina E. Crawford argues: “Although the 1935 General Plan for Moscow has been cited as the working model for the Soviet city, Baku in the mid to late 1920s was its proving grounds… [they included] provision of housing, walkability, and collective services.”¹⁶ Crawford’s assessment positions Baku as not just a precursor to later Soviet plans, but an experimental testing ground in which planners began to confront the challenge of translating socialist ideology into spatial form. Their material aspirations advanced under real economic and social constraints.

Figure 2. Baku Plan, 1927.¹⁷ 

Under the guidance of Aleksandr Ivanitskii, a professor and engineer by training, the 1927 General Plan for Baku came to fruition. It advocated regionalism, housing and industry were recognized as inextricable, linkages across urban space and into the periphery were crucial, public institutions and services were evenly distributed, planting plan to ensure quality of life.¹⁸

These early Soviet experiments revealed both the ambitions and limits of socialist urbanism; during the postwar period, these principles were actually consolidated into a standardized and transferable model. In the Khrushchev era, much like other post-WWII countries, the USSR faced the need for reconstruction at an unprecedented pace. Nikita Khrushchev came to power in 1953, after Stalin’s death. Although his ascendancy to power came eight years after the end of the war, there remained a severe housing crisis. Under his leadership, the Soviet Union embarked on a process of modernization. “‘Khrushchev modern’ signified grand transformations in both the form and meaning of Soviet dwelling.”¹⁹ Even thirty years after Baku, the Soviet identity and its building blocks continued to be altered. “Standardized designs (tipovye proekty) dating from the early 1950s that kept buildings to a minimum of four to five floors so that elevators were not required, and stipulated that kitchens be small and ceilings low, also enabled construction workers to erect buildings more quickly and inexpensively—two key aims of housing construction.”²⁰ Khrushchev’s campaign to perfect industrialized buildings expanded the availability of rapid, cheap, and replicable housing.

In addition to these structural components, the Soviet envisioning of an urban model accounted for the planning of space and communal services. These strategies were overseen by Gosplan, the Soviet government agency responsible for central economic planning. L. M. Sabsovich, a prominent urbanist during the first five-year plan, was responsible for the most ambitious urbanist scheme. He envisioned “the coordination of all food producing operations in order to transform raw food products into complete meals, deliverable to the population in urban cafeterias, communal dining rooms, and the workplace.”²¹ This transformative political project also became a heavily social one. Sabsovich and other Urbanists wanted to free women of domestic labor—cooking, childcare, education—and therefore redefine longstanding gender norms. The pursuit of social equality as part of a collective welfare pushed previous restrictions on the private household and cultural life. The doctrine of the “social condenser” was meant to do away with “excessive privatization, hoarding, inwardness, egoism, and coziness” characteristic of the bourgeois domestic way of life.²² During Khrushchev’s reforms, the proposed “microdistrict… grew out of similar ideas in the 1920s and early 1930s for the socialization of everyday life in the designs for the dom-kommuna (house commune).²³ Although physical structures evolved to reflect technology and demand, the idea of shared social space was a core component of Soviet planning. 

A fundamental component of these plans was their search for the fulfillment of a utopian environment, an ambition that repeatedly collided with economic constraints and material shortages. As Sheila Fitzpatrick notes, “the utopian vision of the 1930s was of a human and natural world transformed through industrialization and modern technology.”²⁴ Unfortunately, the conditions necessary to realize this were largely absent. Bureaucratic inefficiencies, limited resources, and shifting state priorities led to the neglect of residential housing construction and manufacture of consumer goods. The industrialized future that Soviet citizens were promised was only partially attainable, a fact that did not stop the heirs of revolutionary utopianism from trying. Stites expresses their fervor, stating “those who took utopia down from the light blue skies of Russian fantasy into living experimentalism enriched the revolutionary process… they attempted to bring the theory alive in a physical setting.”²⁵ The drive to design socialist life encompassed the encountering of a persistent tension between conviction and material realities.

An integration of economics and politics emerged at the core of Soviet state planning beginning with the New Economic Policy (NEP), a series of measures that brought developments that were hard to reconcile with Bolshevik visions.²⁶ Under NEP, capitalist concepts of profit were introduced to the planned economy model of the Soviet Union, a necessary making of concessions to kickstart policy-making. These constraints persisted, eventually shaping the USSR’s Cold War economic strategy. Professor and historian Oscar Sanchez-Sibony found that Soviet global influence during this period depended not only on ideology but also on what the USSR could practically finance, supply, and sustain abroad; “exporting” the Soviet models was inseparable from economic capacity.²⁷ These limits were correct in the Cuban case, where the merging relationship between both countries was based on the USSR’s “economic limitations” and “political objectives”.²⁸ Planning functioned as a negotiated process based on contingency, in which ideological ambition was continually recalibrated against material capacity, geopolitical priorities, and economic constraint. What the Soviet Union could transfer to Cuba, therefore, was not a fully realized socialist blueprint, but a selective assemblage of planning practices shaped as much by necessity as by doctrine.

Havana after 1959

It is therefore important to understand the context in which the Cuban Revolution emerged and its ambitious promises of change through reform for the Cuban people. Nationalism on the island is rooted in a long history of colonial struggle. In 1902, when the country finally gained independence from Spain, it was met with another reality: a dependence on the United States and its market to sell its sugar.²⁹ Shortly after, the Platt Amendment was signed alongside the new constitution, leasing a portion of Cuban land known as Guantánamo Bay to the U.S. indefinitely, which has since become infamous for its role as a U.S. naval base, former CIA black site, and detention center.³⁰ Both symbolically and physically, the U.S.’s imperialism was evident, as it wielded the power to “intervene in Cuban affairs whenever order was threatened.”³¹It was based on the subsequent societal dynamics that developed over the course of six decades that the Castro-led revolution triumphed. In the search for affirming their national sovereignty against the United States, the support of the Soviet Union became crucial. The USSR provided material support as well as an alternative to capitalism.

One of the major methods of enacting this shift in political theory and international alliances was an extensive plan for national development, especially the transformation of the urban landscape. In 1961, mass organizations like the Committees for the Defense of the Revolution (CDR) were established and tasked with overseeing the reparation of individual homes, thereby creating “‘increased participation among the people in all activities related to public matters.’”³² The first plans for urban reform combined the economic and social aspects of revolutionary Cuba, sometimes even exaggerating the role of centralized programs to actualize socialism into everyday urban life.³³ This first stage of development was put into effect after a consolidation of power by the Revolutionary Movement, culminating in the first socialist master plan for Havana (1963-64).³⁴ The plan, meant to decrease the population growth rate, included the diffusion of certain industries to other parts of Cuba. It also accounted for a need to increase green space and is credited with the idea of the Metropolitan Park (Parque Metropolitano).³⁵

During this time, Cuba had been sending engineers to the Soviet Union to adopt their infrastructure practices. Victor O’Reilly, for instance, was a Cuban engineer who was in Moscow in 1963 “taking a course on prefabrication”.³⁶ After the natural disaster of Hurricane Flora that year, “Khrushchev proposed to donate a factory to produce housing, with a production rate between 1400 and 1700 dwellings per year—which was the I-464 system.”³⁷ Issues quickly arose, however, as the design of the housing was intended to suit Russian conditions. And so, a selective implementation of the Soviet KPD large concrete panel housing system was set in motion with the help of a Cuban commission.³⁸ This was just one of many ways in which the Soviet Union and Fidel’s Cuba were becoming inextricably linked to one another. Cuban architects and engineers engaged in a process to modify panels to their own social contexts.

While some initiatives were born out of Cuban revolutionary priorities, others came as a result of direct Soviet instruction. Regardless, they reflected an emerging affinity with socialist spatial thinking that would only deepen in the years that followed. These efforts led to the much more socially ambitious Master Plan of 1971. Prepared by architects in the Institute of Physical Planning, the plan was centered around making improvements to the 1963-64 version, including “location of housing zones near production, teaching, and research centers.”³⁹ This reinforced the construction of apartment buildings through centers of work and the national urbanization project.

Figure 3. Map insert from The 1971 Master Plan.⁴⁰ 

The 1971 plan worked with a greater awareness of Havana’s problems and attempted to give special planning attention to areas that needed it, emphasizing “both shopping areas and services as well as workplaces and housing.”⁴¹ Havana’s planning logic was increasingly mirroring socialist aspirations of urban integration, where residence, labor, and everyday life would become linked. The division of districts into “cells and productive units,” an approach with origins in 1966, was derived from Stalinist plans for the USSR before World War II.⁴² Not only was this aimed at reorganizing the country’s capital city, but also at testing how socialist ideology could be embedded in lived space. 

The final stage of the transition from a market economy to a socialist model was evident with the passing of Cuba’s first Five-Year Plan in 1975. As noted by Prestamo, “this plan included the organization of local authorities, Poder Popular (Popular Power), modelled after the Soviet reforms of 1965.”⁴³ This move formalized a Soviet-style administrative logic in Cuba, embedding centralized planning into local governance and institutionalizing mass participation as a mechanism of socialist legitimacy. Simultaneously, the delegates of the Cuban congress approved a platform stating “that socialism in Cuba is irreversible” and that Cuba would “strengthen its ties with the Soviet Union and the Socialist world.”⁴⁴ These declarations crystallized both ideological alignment and material dependency, confirming that Cuba’s urban and economic future was being shaped through the frameworks and expectations of the Soviet bloc. However, the Cuban government also inherited the problems of the Soviet model, including an incompatibility between socioeconomic development plans and urban design programs.

Havana’s post-1959 trajectory reveals how anti-imperial sentiment and socialist internationalism converged to create a revolutionary built environment. In seeking an alternative to U.S. dependence, the Cuban leadership turned to the Soviet Union for support that ranged from credit and trade to prefabricated mass housing, neighborhood units organized around work and services, and comprehensive master planning. But these models never materialized as a simple blueprint. Cuban planners selectively adopted, adapted, and sometimes resisted Soviet techniques in order to accommodate local family structures, climate, and existing urban fabric. By the mid-1970s, an imported model had been forged, while the contradictions and limits that accompanied it had only begun to surface.

Soviet Transfer: Havana on the Ground

From the early 1960s onward, Havana’s landscape was reshaped in materially visible and socially transformative ways. Its residents witnessed the construction of completely new communities like Cojímar and Alamar in the city’s eastern outskirts. These physical changes were accompanied by social reforms, particularly in education and childhood development. Across the city, círculos infantiles (state-run early childhood centers) were set up to promote structured child development. The founding of the Lenin College Preparatory School in Havana (IPVCE) in 1972 bolstered a technocratic socialist elite; conceived as “a prestigious leadership-training boarding school… specialising in science and technology,” it trained many of the country’s professionals in the decades that followed.⁴⁵ Meanwhile, Tarará, a once gated town in east Havana, was repurposed at first into a children’s pioneer camp for primary school students, subsequently, in the aftermath of the 1986 Chornobyl disaster, into a medical complex for children impacted by the nuclear accident.⁴⁶ These reforms were symptoms of a Soviet partnership in Havana’s spaces and institutions. 

Beyond a political alignment, Soviet-Cuban relations took on a tangible dimension through the physical presence of Soviet power on Cuban soil. Almost immediately after the establishment of relations with the USSR, Cuba’s affinity for the Soviet Union took on a concrete strategic dimension, as it housed a number of Soviet military bases and intelligence installations. Among the most significant was the Lourdes SIGINT facility, an “electronic intelligence listening post at Lourdes on the outskirts of Havana” that was fully operational by the late 1960s.⁴⁷ This relationship was further cemented by visits to Havana from senior Soviet officials. In February 1960, Soviet Deputy Prime Minister Anastas Mikoyan visited Cuba, an event that “marked the first official state visit by a high-ranking Soviet representative to Cuba.”⁴⁸ His presence formalized the alliance and also underscored how rapidly Soviet influence became embedded in Cuba’s physical landscape.

In the meantime, Cubans continued to endure housing crises and an alarming gap between the ambitious plans set forth by the revolutionary government and their unlikely realization. As mentioned, the efforts to modernize living conditions inspired by Soviet-style planning led to the construction of multi-family, multi-storey concrete housing meant to embody progress. Yet these developments frequently disrupted existing social and environmental relationships in Cubans’ livelihoods. As architect from the José Antonio Echeverría Technological University (CUJAE) Dania González Couret notes, “the rural population were accommodated in multi-family, multi-storey concrete buildings, losing their connection with the land, animals and nature.”⁴⁹ Additionally, the new settlements failed to deliver the necessary social services promised by modernization. Residents “lacked the benefits of urban services and facilities, so experienced the negative aspects of both urban and rural life,” revealing a lived contradiction between ideological aspiration and material reality.⁵⁰ The projects that emerged after socialist influence served to further compound housing inequality.

Along with these spatial and military transformations, Havana’s public service infrastructure was also reshaped under socialist planning. The revolutionary government, often drawing upon Soviet models of centralized provisioning, sought to expand and rationalize access to electricity, potable water, sanitation, and other essential urban services as tangible markers of socialist progress. In reality, while selected neighborhoods benefitted from infrastructural improvements, many others faced persistent shortages, unreliable water supply, intermittent electricity, and deteriorating hygiene conditions. Barrios insalubres (shantytowns) were characterized by having “flood plains and under high-voltage power lines.”⁵¹ These inconsistencies revealed the inherent fragility of state-led modernization and the strain placed upon Havana’s networks by rapid expansion and limited resources. In the years to come, albergues (transitional homeless shelters on the streets) would be the only refuge for those whose dwellings had serious structural issues, reinforcing patterns of scarcity that would continue to fashion Havana’s urban experience well beyond the Cold War period.

Today, Havana stands as a reflection of the once-aspirational—and soon thereafter abandoned—hopes of Cuban socialism. Citizens continue to live in the Soviet apartments of the 1960s, except now they are stripped of their original paint. The once-modified facade panels from Soviet-inspired panel factories, carrying “Cuban design adaptations,” are no longer noticeable.⁵² Several buildings across the city have either been repurposed or abandoned. Recreational community spaces, such as parks, are marked by rusted benches and peeling playground equipment. Public institutions, too, struggle to function under their current conditions. Since the collapse of the Soviet Union and the Periodo Especial (Special Period; period of economic crisis in Cuba beginning in 1991), they operate within reduced spaces. Even the Lenin Vocational Pre-University Institute of Exact Sciences is a symbol of structural decay; only two of the six institutional buildings remain functional.

The remnants of these urban plans are reflective of the disillusionment at large among the Cubans who envisioned the reconstruction of the very fabric of their society through the fulfillment of socialism. Their path to building a new world akin to that of Soviet citizens has been riddled with many practical setbacks and economic underpinnings. The undertaking of a national planning project, informed by Soviet spatial ideals, eventually clashed with Cuba’s reality. In most of these buildings, the exterior peeling facades coincide with intermittent water and power supply; these inconveniences have become an ordinary part of a Cuban’s everyday experience. For many Habaneros (the people of Havana), a tension has emerged between their nostalgia for the early period after revolutionary triumph and the endless frustrations in the years to follow. 

Conclusion

When analyzing the phenomenon of Soviet influence in a decolonial world, Mervyn Bain, a senior lecturer in International Relations at the University of Aberdeen, observes: 

Many countries in the developing world that had newly gained their independence were attracted to Moscow because the Soviet development model from the 1930s had brought about rapid modernization and industrialization; and in the Western Hemisphere, Russia lacked a colonial past in the traditional sense, unlike other European powers like France, Portugal, Spain, and the United Kingdom, among others.⁵³ 

Cuba’s post-1959 trajectory reveals precisely the kind of ambivalent relationship Bain describes. Havana, a country deeply entrenched in its colonial past, did not simply imitate Soviet planning out of ideological devotion. Instead, the revolutionary state, in need of a development model capable of materializing social change at a pace that matched its political ambition, turned to the Soviet Union. This new partner distinguished itself from former colonial rulers that had long taken advantage of populations in the Caribbean and Latin America. The Soviet Union was positioned as a power that actually understood the Cuban struggle and followed through on its solidarity with newly decolonizing nations. Throughout the course of this relationship, urban planning principles transferred from the USSR to Cuba were much more than technical; they became a way to signal sovereignty and effectively distance Cuba from its North American past.

The built environment was the physical embodiment of the terrain on which post-revolutionary aspiration and geopolitical alignment converged. Soviet precedents with roots in the New Economic Policy of the 1920s brought with them a distinctive understanding of space as something that could be engineered to reshape social life. Castro and his revolutionary leadership were also intent on creating a new kind of citizen and society; on this shared goal did the ideas of the Soviets strongly resonate. In Cuba, the prospect of housing blocks represented environments in which collective identity could be fostered, and socialist belonging could be ultimately lived. The establishment of schools, early childhood centers, new neighborhoods on Havana’s outskirts, and vast administrative projects reinforced a sense that the future could be planned and inhabited in advance. Nonetheless, the very qualities that made Soviet urban planning appear attractive—its scale, speed, and alleged efficiency—also contributed to the struggle that later emerged when attempting to execute Soviet practices. Cuba’s adoption of Soviet-inspired planning had to work with existing modernization plans and was constrained by the island’s persistent economic fragility. The process of “transfer” was never linear. To account for the actual differences in the Cuban society and economy, the assumption of Soviet principles was adaptive and negotiated: Cuban engineers modified imported prefabrications to suit local conditions; state planners mediated between imported models and the city’s existing urban fabric; and residents continuously molded the spaces they inhabited through their everyday practices.

The failures of Soviet-style planning in Havana were rooted in broader structural conditions: the economic strains of the Cold War, Cuba’s dependency on Soviet aid, the fragility of central planning under scarcity, and the mismatch between abstract urban theory and lived experience. The Soviet Union promised industrial capacity and ideological solidarity without being capable of fully providing the sustained economic support required to maintain the massive infrastructural plans it helped set in motion. After the end of the Cold War and the ensuing collapse of Soviet backing, Havana’s project was left without the means to materially sustain itself. The city’s Soviet-era neighborhoods, decaying institutional buildings, and compromised infrastructure remain ingrained as part of the island’s physical landscape as active, lived environments. These structures bear witness to a moment when architecture and planning were expected to transform society, and when socialist alignment appeared to offer a path to modernization that deviated from capitalism and empire. But the reality of Havana’s post-1959 built environment stands as both testimony and warning, and planned utopias like it leave material legacies that outlive their first political projects as well as continue to shape the social conditions of the people who must live within them.

References

Featured/Headline Image Caption and Citation: Havana, Photo by Pedro Szekely | Image sourced from Flickr | CC License, no changes made

¹ Luis Martínez-Fernández, Revolutionary Cuba: A History (University Press of Florida, 2014), 46.

² Roberto Segre, “Medio siglo de arquitectura cubana (1953-2003): Variaciones sobre el tema del Comunismo,” Revista de historia y teoría de la arquitectura, 7-28.

³ John Petrakis, “Wonderland’ Surveys Levittown, the Prototypical Postwar Suburb: North Sports Final, CN Edition,” Chicago Tribune (1963), October 4, 1998.

⁴ Robert G. Wertheimer, “The Miracle of German Housing in the Postwar Period,” Land Economics 34, no. 4 (1958): 340.

⁵ Sheila Fitzpatrick, Everyday Stalinism: Ordinary Life in Extraordinary Times: Soviet Russia in the 1930s (New York: Oxford University Press, 1999), 68.

⁶ Richard Stites, Revolutionary Dreams: Utopian Vision and Experimental Life in the Russian Revolution, (New York: Oxford University Press, 1989), 190. 

⁷ Sheila Fitzpatrick, Everyday Stalinism, 69. 

⁸ Pedro Ignacio Alonso, “How a Soviet Concrete Panel Housing System Came to Cuba and Chile,” Journeys and Translations, no. 14 (2016). 

⁹ Luis Martínez-Fernández, Revolutionary Cuba, 46.

¹⁰ Paul Lester Wiener, José Luis Sert, and Paul Schultz, Plan piloto de La Habana: directivas generales, diseños preliminares, soluciones tipo (Havana: Town Planning Associates, 1959), 32.

¹¹ Paul Lester Wiener, José Luis Sert, and Paul Schultz, Plan piloto de La Habana, 34. 

¹² Paul Lester Wiener, José Luis Sert, and Paul Schultz, “Plan for Havana, Cuba,” Ekistics 8, no. 45 (1959): 9–15.

¹³ Felipe J. Prestamo, “City Planning in a Revolution: Cuba, 1959-61,” Planning Perspectives 9, (1993): 191.

¹⁴ Felipe J. Prestamo, “City Planning in a Revolution,” 192. 

¹⁵ Christina A. Crawford, Spatial revolution: architecture and planning in the early Soviet Union. (New York: Cornell University Press, 2022), 17-18. 

¹⁶ Christina A. Crawford, Spatial Revolution, 83.

¹⁷ Christina A. Crawford, Spatial revolution, 102.

¹⁸ Christina A. Crawford, Spatial revolution, 117.

¹⁹ Christine Varga-Harris, Stories of house and home: Soviet apartment life during the Khrushchev years, (London: Cornell University Press, 2015), 28.

²⁰ Christine Varga-Harris, Stories of house and home, 31. 

²¹ Richard Stites, Revolutionary Dreams, 199.

²² Richard Stites, Revolutionary Dreams, 201.

²³ Steven Harris, Communism on tomorrow street: mass housing and everyday life after Stalin, (Washington, D.C.: Woodrow Wilson Center Press, 2013), 193. 

²⁴ Sheila Fitzpatrick, Everyday Stalinism, 67. 

²⁵ Richard Stites, Revolutionary Dreams, 10.

²⁶ Alan Ball, “Building a new state and society: NEP, 1921–1928,” in The Cambridge History of Russia, ed. Ronald Grigor Suny, (Cambridge: Cambridge University Press, 2006), 171.

²⁷ Oscar Sanchez-Sibony, Red globalization: the political economy of the Soviet Cold War from Stalin to Khrushchev, (Cambridge: Cambridge University Press, 2014), 65-80. 

²⁸ Radoslav Yordanov, “The Long Misunderstanding: Cuba’s Economic Ties with the Soviet Bloc,” Journal of Cold War Studies 25, no. 4 (2023): 24. 

²⁹ Marifeli Pérez-Stable, The Cuban revolution: origins, course, and legacy, (New York: Oxford University Press, 1999), 3. 

³⁰ Ada Ferrer and ProQuest, Cuba: An American History, (New York: Scribner, 2021), chapter 14.

³¹ Marifeli Pérez-Stable, The Cuban Revolution, 4. 

³² William Thomas Kelly, “Revolución Es Reconstruir: Housing, Everyday Life, and Revolution in Cuba, 1959-1988,” (Rutgers University, The State University of New Jersey, School of Graduate Studies, 2021), 67.

³³ Joseph L. Scarpaci, Roberto Segre, and Mario Coyula, Havana: Two Faces of the Antillean Metropolis (Chapel Hill: University of North Carolina Press, 2002), 131. 

³⁴ Joseph L. Scarpaci, Roberto Segre, and Mario Coyula, Havana, 146. 

³⁵ Joseph L. Scarpaci, Roberto Segre, and Mario Coyula, Havana, 147.

³⁶ Pedro Ignacio Alonso, “How a Soviet Concrete Panel Housing System Came to Cuba and Chile,” para. 2.

³⁷ Pedro Ignacio Alonso, “How a Soviet Concrete Panel Housing System Came to Cuba and Chile,” para. 3.

³⁸ Pedro Ignacio Alonso, “How a Soviet Concrete Panel Housing System Came to Cuba and Chile,” para. 4.

³⁹ Joseph L. Scarpaci, Roberto Segre, and Mario Coyula, Havana, 151.

⁴⁰ Joseph L. Scarpaci, Roberto Segre, and Mario Coyula, Havana, 150.

⁴¹ Joseph L. Scarpaci, Roberto Segre, and Mario Coyula, Havana, 151. 

⁴² Felipe J. Prestamo, “City Planning in a Revolution,” 204.

⁴³ Felipe J. Prestamo, “City Planning in a Revolution,” 207.

⁴⁴ “Cuban Communist Party Votes Guidelines of First 5-Year Plan,” New York Times, December 22, 1975, 14.

⁴⁵ “La Lenin Transnational: Schooling and the Reproduction of Elites in Socialist Cuba,” COMPAS, 2014.

⁴⁶ Alin Ulloa, civil engineer and graduate of the Lenin School and CUJAE, interview by the author, Miami, Florida, December 15, 2025. 

⁴⁷ Mervyn J. Bain, “Havana and Moscow, 1959–2009: The Enduring Relationship?” Cuban Studies 41, no. 1 (2010): 133.

⁴⁸ Radoslav Yordanov, “The Long Misunderstanding,” 28.

⁴⁹ Dania González Couret, “Sustainable urban development. Cuban challenges,” International Journal of Urban Sustainable Development 14, no. 1 (2022): 410. 

⁵⁰ Dania González Couret, “Sustainable Urban Development,” 410.

⁵¹ Mario Coyula and Jill Hamberg, “Havana, Cuba,” The Challenge of Slums: Case Studies for the Global Report on Human Settlements, 2003: 11.

⁵² Hugo Palmarola and Pedro Ignacio Alonso, “Tropical assemblage: The soviet large panel in Cuba,” Beyond imported magic: Essays on science, technology, and society in Latin America (2014): 166.

⁵³ Mervyn J. Bain, “Havana and Moscow, 1959–2009: The Enduring Relationship?” Cuban Studies 41, no. 1 (2010): 128.

On December 5, 2025, in a Washington ballroom draped in the flags of nations, FIFA President Gianni Infantino stepped to the podium and handed the President of the United States- Donald Trump a golden trophy the size of the World Cup itself, as requested by the White House. “This is what we want from a leader,” Infantino told the room, bestowing upon Trump the inaugural FIFA Peace Prize, an award invented weeks earlier after Trump was passed over for the Nobel Peace Prize, and which the White House had reportedly demanded be literally as large as the real thing. No nomination process, no independent committee, no transparency. FIFA’s Human Rights Advisory Board was not consulted. FIFA’s own governing council had not been informed. The world’s most powerful sports body had, in a single ceremony, collapsed the distance between a self-professed champion of global unity and an administration that, within months, would bar the fans of four qualifying World Cup nations from entering the host country. 

This is a prime example of democratic sportswashing, a phenomenon for which international law has even fewer answers than it has for the authoritarian kind. 

The Asymmetry of Accountability 

The concept of sportswashing entered the global lexicon through the Gulf: Saudi Arabia’s purchase of Newcastle United, the LIV Golf merge, and Formula 1 in Jeddah and Bahrain. The logic was straightforward:– authoritarian states exploiting sport’s apolitical aura to launder reputations-stained executions, torture and the occasional assassination. The critique is coherent: authoritarian states exploit the apolitical prestige of sport to launder their image before a global audience that would rather watch a race than read a human rights report. The legal problem is equally coherent: because sports federations like FIFA are private bodies registered in Switzerland, they sit outside the reach of binding international human rights law and can do as they please. The 2026 World Cup in the United States asks a harder question: what happens when the “sportswasher” is a democracy? 

The discomfort is structural. The international human rights accountability framework-such as the UN Guiding Principles on Business and Human Rights (UNGPs), the Universal Declaration, the ICCPR, the Convention Against Torture was architected to constrain states and, increasingly, corporations from abusing the vulnerable. It was not designed to reckon with a scenario where a rights-violating host government is simultaneously a P5 Security Council member, the world’s largest economy, and the nominal guardian of the liberal international order. When Bahrain hosts an F1 race, human rights organizations can pressure the FIA, the FOM, and their European corporate sponsors under nascent mandatory human rights due diligence (HRDD) frameworks. When the United States hosts the World Cup, the pressure has nowhere to go because the United States writes, funds, and, when convenient, defunds those very frameworks. 

The World Cup Brought to You by the Travel Ban 

The facts are not in dispute. The US State Department has imposed full or partial travel bans on 39 countries, suspending visa issuance entirely for 19 of them. Four of those countries namely Iran, Haiti, Ivory Coast, and Senegal qualified for the 2026 World Cup on merit. Fans from Iran and Haiti are categorically barred from entering the United States, even with valid match tickets. For five African nations whose teams qualified, Algeria, Cape Verde, Ivory Coast, Senegal, and Tunisia, the administration imposed a $15,000 visa bond requirement, reversed only in May 2026, weeks before the June 11 kickoff, and only for those who could produce a match ticket. Jordanian fans, though not under a blanket ban, found their visa appointments cancelled after the US Embassy in Amman shuttered. 

FIFA’s response has been consistently breathtaking in its inadequacy: “Such things are outside its remit.” This formulation is worth examining. FIFA, which generated over $11 billion in revenue from the 2026 World Cup cycle, which required host countries to submit human rights strategies as part of the bidding process for the very first time and embedded UNGP compliance obligations into its host city contracts, now claims that the exclusion of qualifying fans based on their nationality falls beyond its institutional mandate. One hundred and twenty civil society organizations, led by the ACLU, Amnesty International, Human Rights Watch, the NAACP, and Reporters Without Borders have called this precisely what it is: FIFA “paying lip service to human rights while cozying up with the Trump administration.” 

When the Guardian Becomes the Problem 

There is a particular irony in FIFA’s predicament that its leaders appear constitutionally unable to acknowledge. The 2026 World Cup is the first FIFA tournament in which human rights criteria were woven into the bidding architecture, a reform championed, in part, as a response to the catastrophe of Qatar 2022 and the deaths of migrant workers in stadium construction. FIFA’s FWC26 Human Rights Framework explicitly protects migrant workers and vulnerable populations regardless of immigration status. The framework commits FIFA to “constructively engaging with relevant authorities” when human rights commitments are at risk. Instead, Infantino attended Trump’s inauguration, shared Instagram posts proclaiming that Trump “def deserves” the Nobel Peace Prize and told an American business forum that the world “should support” what the Trump administration was doing. 

This is not mere personal eccentricity. It is institutionally significant. FairSquare, a human rights organization, filed a formal complaint with FIFA’s ethics committee identifying four distinct violations of FIFA’s own political neutrality obligations. The complaint found no traction. Meanwhile, FIFA cancelled anti-discrimination messaging campaigns ahead of the tournament, an act that combined with the Peace Prize affair led Amnesty International to characterize the organization as “normalizing an increasingly authoritarian US government.” An internal FIFA source told The Guardian in January 2026 that senior officials felt “deep embarrassment” but no one would act because Infantino controlled the institutional machinery. 

The structural parallel here is instructive: just as Saudi Arabia’s sportswashing operates through the FIA’s financial dependence on Gulf hosting fees, American democratic sportswashing operates through FIFA’s financial dependence on US hosting revenue and its president’s political alignment with the sitting administration. The mechanism is the same; a private international sports federation captured by its most powerful host, but the democratic packaging makes accountability harder to demand and easier to dismiss. 

Iran Plays in Los Angeles; Its Fans Watch in Tehran 

There is an image that captures this World Cup’s central contradiction more sharply than any policy document. On March 20, 2026, Iran’s national team secured a place in the tournament, becoming the second team to qualify for the 2026 World Cup. As the players celebrated on the pitch, the fans who had watched them from Tehran knew they would not be able to follow. Iran’s first match, against New Zealand, was scheduled for June 15 in Los Angeles, home to the largest Iranian diaspora outside Iran. As of May 21, 2026, the Iranian squad was photographed outside the US Embassy in Ankara, applying for visas in Turkey because the US Embassy in Tehran no longer operates. Players and coaches are technically exempt from the travel ban, but even this exemption rested on the fragile goodwill of an administration that had authorized military strikes on Iran in February 2026. 

The fans, of course, needed no appointment. They simply needed to not be Iranian. Fans from Iran and Haiti are categorically barred from attending any match on US soil, regardless of their possession of valid tickets. FIFA PASS, the priority visa appointment system FIFA designed in coordination with the White House, is functionally useless for citizens of countries that have been refused visa issuance entirely. The $15,000 bond waiver, hailed by FIFA as evidence of “continued cooperation with the White House,” was announced three weeks before the tournament and applied only to fans who had already bought tickets, they could not previously guarantee entry to use. As the ACLU’s Jamil Dakwar put it: “FIFA has unique leverage right now to pressure the U.S. government to respect the fundamental human rights of every person visiting and attending the games. FIFA has yet to offer meaningful assurances.” 

The Accountability Gap and Its Democratic Cover 

The legal vacuum here is identical to the one that shields F1 in Bahrain, and its existence in a democratic context is both more damning and harder to remedy. The UNGPs impose a corporate responsibility to respect human rights on FIFA as a non-state actor. As a non-binding instrument, the UNGPs generate no enforceable obligation before any court. The ICCPR’s non-discrimination provisions in Articles 2 and 26 bind state parties, not sports federations. FIFA, registered in Switzerland, is subject to Swiss private law and the jurisdiction of the Court of Arbitration for Sport, neither of which has developed meaningful doctrine on the exclusion of fans by nationality.federations. FIFA, registered in Switzerland, is subject to Swiss private law and the jurisdiction of the Court of Arbitration for Sport, neither of which has developed meaningful doctrine on the exclusion of fans by nationality. 

What distinguishes the democratic sportswashing case is this: in authoritarian contexts, the state and the rights-violating actor are the same entity. The demand that the FIA or FIFA refuse to hold events in Saudi Arabia or Bahrain is at least conceptually coherent as it asks a private body to exercise leverage against a foreign government. In the 2026 World Cup context, the demand that FIFA exercise leverage against the United States requires a private Swiss association to confront the most powerful government on earth, with which it has just co-produced a peace prize ceremony on live television. There is no body of international law, no enforcement mechanism, and no institutional appetite for it. 

For communities already living with the consequences, this is not a theoretical gap. Latino communities in all eleven US host cities Los Angeles, Miami, New York, Atlanta, Seattle, Dallas, San Francisco, Kansas City, Philadelphia, Houston, and Boston have reported that fear of ICE operations is suppressing their participation in the event. In a country where 11 million undocumented people reside, many of them forming the backbone of the hospitality, construction, and service sectors that the World Cup infrastructure depends on, the human rights question is not only about foreign fans. It is about the people who will build the venues, clean the stadiums, and serve the food and who have no recourse under the FWC26 Human Rights Framework if detained. 

Conclusion: The Flag, the Trophy, and the Question 

In July 2026, the final will be played in New Jersey. Billions will watch. The production values will be extraordinary. The football, as one expects, will be thrilling. Anad the lesson the 2026 World Cup will have taught international human rights law is an uncomfortable one: that the architecture of accountability which took the post-war world eighty years to build has a very large blind spot, and the blind spot is shaped exactly like a democratic superpower. Authoritarian sportswashing is a cynical exploitation of law’s gaps. Democratic sportswashing is something slightly worse, it is those gaps being enforced by the actor that wrote them. 

FIFA’s first-ever human rights bidding requirements, the FWC26 Framework, the UNGP commitments in the host city contracts were not meant to be empty promises. They were genuine reforms, won through years of pressure by people who believed institutions could be made better. They were also, faced with a travel ban, a $15,000 bond, and a peace prize ceremony, entirely unequal to the task. The game has always promised that on the pitch, the only thing that matters is what you can do with a ball. Off it, in 2026, what matters is the colour of your passport. FIFA got a trophy for that. The fans of Iran and Haiti got a livestream.  It is, in the end, a very American kind of welcome: boundless in its rhetoric, precise in its exceptions. 

Featured/Headline Image Caption and Citation: “England-Ghana World Cup 2026 Boston 04,” Image Sourced from Wikimedia Commons | CC License, no changes made

Rethinking the matter of autonomous vessels in International Maritime Law

In the spring of 2022, a vessel slipped quietly out of a Norwegian port carrying a cargo of mineral fertilizer. No captain stood at the helm. No crew walked the decks. The Yara Birkeland, the world’s first fully electric, zero emissions, autonomous container ship, had entered into operation. Developed by Yara International and Kongsberg Maritime, the vessel was designed to eventually operate entirely without crew, replacing 40,000 annual diesel truck journeys.

This ship is not a singular instance of such inquisitiveness. Alongside it, many research projects have emerged, such as the MUNIN (Maritime Unmanned Navigation Through Intelligence in Networks), DNV GL’s Revolt, and Nippon Yusen Kaisha’s autonomous vessels trials, which test the technical feasibility of autonomous ships. They signal a shift towards how goods and people are going to move across the world and across oceans. The question is no longer whether autonomous ships can sail internationally, it is whether international law is prepared for them when they do.

The current legal landscape

International Maritime Law is one of the oldest and most developed bodies of Public International Law. It has several instruments which make up the current architecture of governance, these include: United Nations Convention on the Law of the Sea (UNCLOS), the Safety of Life at Sea (SOLAS) Convention, the International Regulations for Preventing Collisions at Sea (COLREGs), the Standards of Training, Certification and Watchkeeping for Seafarers (STCW) Convention, and the Maritime Labour Convention (MLC).

Despite the development in this field, there is a stark challenge that maritime law faces with autonomous vessels. Every one of these instruments was built on a single assumption: that a human being would always be on board and would bear ultimate responsibility for the vessel.

The Mass Code: A roadmap not a rulebook yet

Maritime Autonomous Surface Ships (“MASS”) are vessels that operate independent of human action to varying degrees. The International Maritime Organization (IMO), has a taxonomy of degrees of autonomy for MASS vessels. This framework is essential to establish the ambit of the existing regulatory framework and includes 4 degrees of automation, with degree 1 having the most human involvement and degree 4 being fully autonomous.

An IMO scoping exercise, concluded in May 2021, aimed at mapping the adequacy of existing conventions, the need for amendments, and the conventions/provisions, which had gaps, in dealing with autonomous vessels. The diagnosis of this exercise was sobering. Most major conventions need significant amendments to accommodate these developments.

Subsequently, a joint working group developed a goal-aligned MASS code. At the 109th session of the Maritime Safety Committee (MSC 109), the IMO agreed to a revised roadmap which involved a non-mandatory MASS code to be finalized and adopted by May 2026. This would be followed by an experience building phase till 2028, leading to a finalized mandatory code to be adopted by 1^st July 2030 that will enter into force on January 1st, 2032.

This roadmap is significant, but pertinent in understanding what the MASS code will and will not do. The code will be goal-based instead of prescriptive. It will provide a framework “against which a vessel using autonomous technologies can be assessed and certified for commercial operations within IMO’s structure,” but will not mandate specific technical methods. The responsibility for developing a compliance stratagem falls largely on industry, flag states, and classification societies.

It is pertinent to note that autonomous shipping is currently not fully regulated by the International Association of Classification Societies (IACS) or the IMO. This means that individual flag states must decide how to regulate MASS within their own jurisdictions, creating a fragmented, uneven global picture.

Where the law falls overboard

The scoping exercise identified gaps across virtually every major international maritime instrument; they cluster into five critical areas, each having legal challenges. Liability and accountability are the largest challenges. Thus the question remains: Who is responsible when an autonomous vessel causes a collision; the owner, the software developer, the remote operator, or the algorithm itself? Collision regulations (COLREGS compliance) require human judgement. Thus, we extend our question further, asking if artificial intelligence will be able to exercise the ‘ordinary practice of seamen?’

The status of seafarers is a further question as well. SOLAS, STCW and MLC all presuppose crew on board. Remote operators have no clear legal status under existing conventions. UNCLOS requires a genuine link between a vessel and its flag state, developing this concept around the presence of human nationals.

Fully networked autonomous vessels face new threat vectors. A possible hijacked navigation system could become a weapon scaled at the volume of a ship with no crew to intervene. Furthermore, search and rescue and salvaging are heavily impacted by the duty to render assistance at sea, as enshrined in UNCLOS Article 98 and SOLAS Reg. V/33. How does an unmanned ship fulfil this duty of helping other people in peril at sea?

The liability labyrinth

There is a particularly troubling dimension: the “black box” nature of AI decision-making. If a neural-network navigates a vessel into a collision, recovering the sequence of decisions that led to the incident and attributing fault becomes technically impossible. Evidence-gathering in maritime litigation already depends on voyage data recorders (VDRs); the opacity of the machine learning and decision making process significantly compounds the difficulty in tackling this challenge enormously.

Traditional maritime law assigns ultimate responsibility to the master, who is the human being commanding the vessel. When something goes wrong at sea, the legal chain involves the master, the shipowner, and the insurer. Autonomous vessels introduce multiple new parties into play: manufacturers, AI software developers, remote operators, and algorithmic decision-making systems that may act in ways their creators did not anticipate them to.

In the United States, this problem has been recognized to have taken a legal form by the identification of the “Pennsylvania Rule.” The Pennsylvania rule is a federal maritime doctrine under which a party in a collision, who has violated a regulation intended to prevent that type of collision, is presumed liable. The rule presents unique challenges for cases involving autonomous ships because causation for these collisions or other incidents may be difficult to attribute. Principles like the Pennsylvania Rule, are now increasingly pushed to be incorporated in maritime liability allocation as seen in recent allisions and collisions cases. 

The COLREGs problem

The 1972 Convention on the International Regulations for Preventing Collisions at Sea (COLREGs) is the “road code” of the ocean. Every collision case before an admiralty court is ultimately measured against it. Rule 2(a) holds that no vessel, owner, master, or crew can be absolved from the consequences of neglecting the rules. Rule 5 mandates a “proper look-out by sight and hearing.” Rule 8 requires that any action taken to avoid collision be “large enough to be readily apparent to another vessel observing visually.”

These rules presuppose human perception, judgment, and moral responsibility. The COLREGs contain subjective requirements and deviations from the written rules may be required by “the ordinary practice of seamen, or by the special circumstances of the case.” This rule sets a standard for professional wisdom and contextual reasoning. We can conclude that the 1972 COLREGs require amending, for the rules that are presently laid forth are not compatible with the operation of fully autonomous vessels. 

Remote operators in the legal web

Whether the ship is operated from the shores or operates independently without any crew, as is the case for Degree 3 and Degree 4 MASS ships, the question of the legal position of the “master” is spectral. SOLAS defines a master as a person in command of a ship. STCW requires specific training, certification, and watchkeeping standards for officers on board. The MLC defines a seafarer as “any person who is employed or engaged or works in any capacity on board a ship.” None of these instruments contemplate someone sitting in an office in Oslo, overseeing the movement of a container ship passing through the Malacca Strait.

There are suggestions that remote operators should be treated as masters, “by perpetuating the notion of the master, retaining their status as the final entity of responsibility for the ship,” but these are merely suggestions and are not the law just yet. IMO’s own working groups have begun differentiating between “MASS crew/seafarers” and “remote operators,” but no clear legal regime for remote operator qualifications, duties, or liabilities currently exists under international law.

Cybersecurity: another crew member

“Ships are now interconnected with many devices and the shore. The communication and devices used have cyber vulnerabilities.” For a conventionally crewed vessel that experiences  a cyberattack, a crew can respond, improvise, and override the attack. For a degree 4 autonomous vessel with no crew on board, the same attack could result in total loss of control with no human recourse available.

The IMO’s MSC resolution 428 on Maritime Cyber Risk Management in Safety Management Systems provides a starting point to addressing cybersecurity concerns, but it is noted that the IACS has identified “the human element and careless habit of employees” as the weakest link in cyber security, This forms a factor that shifts dramatically in character when there is no human on board at all. 

Frameworks for a hybrid future

The question of how to close these legal gaps is not merely technical. It sits at the intersection of commercial interests, labour rights, environmental imperatives, and geopolitical competition. Any framework that hopes to succeed must “ensure that the uniform and consistent enforcement of UNCLOS provisions” is maintained while making space for technology that did not exist when these provisions were written.

The move by the IMO to adopt a goal-based approach for the development of the MASS Code, is in part an experience learnt from aviation regulations. The Chicago Convention on international civil aviation, and the standards issued by the International Civil Aviation Organization (ICAO), have successfully regulated unmanned aircraft systems (UAS) using a similar framework. Maritime lawyers and academics have pointed to the aviation precedent as an instructive, yet  imperfect, model.

A few goal-based suggestions

There are a few mechanisms that can be adopted and would aim at bridging the gap that exists at the moment between current regulations and prospective regulations that would comprehensively accommodate autonomous vessels.

First, COLREGs regulations need amending to replace anthropocentric language (“ordinary practice of seamen”) with outcome-based substitutes, such as collision avoidance that is “effective, and verifiable.” This preserves the safety objective while allowing AI navigation systems to meet the standard by any technically adequate means.

Second, ensuring increased algorithmic transparency. Existing VDR requirements should be extended to mandate logging of AI decision-making processes in a standardised, interpretable format. Without this safeguard, post-incident liability allocation is arbitrary and practically  guesswork.

Third, mandating the IMO’s existing MSC resolution on cyber risk management. The currently non-binding nature of these resolutions is evidently inadequate for fully networked autonomous vessels. A new SOLAS provision should establish minimum cybersecurity standards for MASS, including requirements for intrusion detection and fallback systems.

Charting a Course Forward 

The human cost of autonomy is not a secondary concern, the question of the maritime workforce cannot be set aside as a downstream consequence of automation; it must be addressed as a central feature of any regulatory framework. Aspects of the seafaring profession, like situational awareness, improvised engineering, and diplomatic negotiation cannot be replicated by AI yet. 

The challenge before regulatory and educational bodies is not to mourn the demise of shipping careers but to plan for a shift in focus such that the vast reservoir of knowledge within the shipping sector is utilized to fulfil new roles.

Autonomous maritime vehicles are no longer a theoretical problem: they are a commercial reality. Vessels are already in service, more are under development, and the legal framework has not yet fully adapted. The IMO deserves credit for recognizing the regulatory lacunae and taking serious steps to remedy it. But the roadmap to a mandatory code by 2032 is a decade away, and commercial pressure to deploy autonomous shipping will not wait for legal surety.

What the MASS Code must deliver is a framework that is technologically neutral in its standards, human-centred in its values, and international in its reach. It should determine whether the voyage is safe, the environment is protected, the workers are treated fairly, and someone can be held accountable when things go wrong.

The boat still needs a captain. The question is where that captain sits.

Featured/Headline Image Caption and Citation: “35th anniversary of the International Maritime Organization (IMO) International Maritime Law Institute (IMLI) at IMO Headquarters in London, England on 22 April 2024,” Image Sourced from Wikimedia Commons | CC License, no changes made

New Name, Familiar Tale

On March 7, 2026, leaders from across Latin America and the Caribbean gathered in Doral, Florida, at the invitation of U.S. President Donald Trump to inaugurate what was presented as a renewed framework for hemispheric security cooperation. Framed in the language of peace, stability, and shared prosperity, the initiative signaled the emergence of a “new” regional security architecture. Yet for Latin America, such moments rarely represent rupture as much as repetition.

Hemispheric security cooperation has historically oscillated between multilateral coordination and asymmetrical dependence, from the 1947 Rio Treaty to more recent counternarcotics partnerships such as the Mérida Initiative and Plan Colombia. The proposed “Shield of the Americas” appears less as a departure from this trajectory than its latest evolution.

Gradually, these attempts at hemispheric cooperation have eroded to give way to coercive action between relevant players in the Americas. We may think of the recent U.S. military incursion in Venezuela in January 2026 or the repeated question mark over American intervention in Mexico posited by President Trump. The game, however, is just as important as the players within it. Much like a prudent player of classic titles such as The Elder Scrolls or any other RPG, it seems the U.S. and its regional allies are investing heavily in defense, both as a principle of their foreign policy toolboxes and as justification for the creation of new multilateral regimes. After all, it is often said that “a good defense is the best offense,” and seemingly this has proven true for allowing Washington to broaden its military operations as far south as Ecuador.

Latin America now finds itself increasingly preoccupied with the offensive capabilities of its northern neighbor, compelled to reconsider how far it is willing to go to defend its people and national vision. Much the same as any prudent, yet astute, RPG player, it increasingly appears that the United States has hidden the sword behind the shield, deploying the language of defense in ways that expand the political legitimacy of intervention across the hemisphere.

The “Return” of Security: A Snake Eating Its Own Tail

The construction of security policy, as discussed by authors linked to security studies, such as Barry Buzan, Ole Wæver, or Thierry Balzacq, has rested upon a government’s ability to define what threats we should be worried about and, as such, the justification to go after them. In truth, Trump’s bid to frame Latin American criminal networks, cartels, gangs, and illegal mass migration as a mortal threat to the peace of mind of U.S. citizens and the nation has come accompanied by mechanisms designed to legitimize action, including multilateral initiatives such as the Shield of the Americas.

Would similar U.S. operations be received the same way if these threats were not collectively recognized as legitimate security concerns? Security theory suggests otherwise. Shared threat narratives allow states to gradually expand the boundary between cooperation and intervention, normalizing actions that might otherwise provoke resistance.

As such, Latin American discussions on security become even more entangled. Like a snake eating its own tail, critics argue the willingness to participate in this new security strategy will come at the cost of a new era of American interventionism, in essence, that most feared by the staunch defenders of Latin American autonomy and anti-American politics in the region. 

Is a Shield Truly Ever Without a Sword?

A shield, nevertheless, must be analyzed as a harbinger of retaliation. The United States has made the nature of “defense” quite clear, positioning itself and her hemispheric allies as clear defenders against an onslaught of illegality and criminality. This, in the eyes of the Trump administration, has remained the savage and untamed beast of the Western Hemisphere; a beast that only responds to a language of violence and heavy-handedness. Under such a framing, the region easily finds itself equating military power with social security.

“The heart of our agreement is a commitment to using lethal military force to destroy the sinister cartels and terrorist networks [in the Western Hemisphere]…”

More captivating, however, is the way in which Latin American security policy has echoed this statement and continues to do so. Ecuador’s President Noboa no doubt used this same sentiment when allowing for his country’s security gap to be filled partially by direct military cooperation with the U.S. earlier in March 2026. Likewise, El Salvador’s hard-hitting security reforms ushered in by Bukele followed this same line of action through policies of exception restricting the right to self-defense and high incarceration rates. Even my own country, Mexico, has seen its security policy fall back and forth between open war against drug trafficking networks and political reframing of security under former President López Obrador. 

Aside from the purely political nature of security policy, one thing remains constant within these cases; the general population of Latin America is increasingly frustrated by the nature of security and desperate for answers. Across the region, efforts to confront insecurity have often fallen into crisis, making reliance on the United States’ protective “shield” appear increasingly attractive, even as the protection it offers risks expanding Washington’s capacity to intervene once again, whether through its military or political recognition. All the same, the message remains explicit: cooperation is a relationship regulated by Washington for the region, rather than alongside it.

“I want to thank members of the coalition, most of whom are friends of mine… many of whom I endorsed…”

One thing has become clear: a shield, no matter how defensive, is nevertheless a weapon when used in new and creative ways. Across Latin America, worried observers find themselves increasingly on edge as the Shield of the Americas reinforces a growing inertia in regional cooperation. The region now appears to be drifting toward competing visions of hemispheric security, further widening existing fractures between states, as seen in the visible diplomatic tensions between Mexico and Ecuador, Mexico and Peru, and Argentina and Brazil.

Security’s Game: Shields, Swords, and Subordinates

If players are shaped by the games they play, then the hemispheric player operating from Washington appears to do so from a position few can truly challenge. Much like an experienced RPG player, the United States does not need to master every role when its Latin American partners are expected to fill them.

The question, then, is what role these partners are meant to play. The meeting in Doral suggests that they may remain secondary actors within a system largely defined by U.S. security protagonism, shaped by decades of sluggish cooperation and unresolved tensions. In this sense, Latin America risks becoming both the shield invoked to safeguard U.S. interests and the region most affected by its weight. 

Supporters of the Shield of the Americas may argue that it offers a concrete response to problems long addressed through softer cooperation. Yet as security once again becomes the region’s dominant political language, it remains unclear whether this new arrangement will lead to genuine partnership through the development of a unified security agenda or to the familiar return of American influence and boots on the ground.

Featured/Headline Image Caption and Citation: “LAAD Defence & Security – 2025 (54425241592),” Image Sourced from Wikimedia Commons | CC License, no changes made

When Ugandan authorities arrested two young women for sharing a Valentine’s Day kiss and charged them with offences related to homosexuality and indecency, they upheld a law written and imposed by the colonisers. When colonisers departed, they left behind legal systems that criminalised same-sex conduct, a burden the colonised were made to carry long after independence. Given the size of the empire and the height of its power, British law did not merely travel; it calcified, embedding itself into the legal DNA of nations that would later become their own tradition. A recent wave of conservatism has swept across Africa, with activists decrying an assault on LGBTQ+ rights, especially in East Africa. Half of all countries worldwide where homosexuality is outlawed can be found in Africa, according to a global review by the International Lesbian, Gay, Bisexual, Trans, and Intersex Association (ILGA), a statistic that reflects the uniformity of colonial legislation. In some countries, offenders are punished by death or lengthy prison terms, enshrined in statutes drafted in colonial capitals. 

This column traces how laws enforced by the colonisers have been weaponised into a modern instrument of oppression, and what it means for the millions living under its shadow. It does so in five parts: first, the historical origins of anti-sodomy legislation and how it travelled; second, what pre-colonial African societies actually recognised about sexuality; third, how this inheritance is being actively reinforced and expanded today; fourth, how a second and more contemporary wave of imported intolerance is compounding it; and fifth, the human cost of both.

The historical development of anti-sodomy laws

In 1534, under the reign of Henry VIII, British law took its first legislative aim at homosexual acts. The legislation punished ‘… the detestable and abominable Vice of Buggery committed with mankind or beast.’ The word ‘abominable’ was taken from Leviticus. The term buggery traces back to ‘bougre’ or ‘heretic’ in Old French, and to the Latin ‘Bulgarus’ for ‘Bulgarian’, a reference to Orthodox Christian heretics. ‘Heresy’ was a common euphemism in the Middle Ages for a group of sexual sins, so the 1534 wording was not innovative. Derived from ecclesiastical law, the religious character of this criminalisation was hardly new. A criminal law prohibition based on Leviticus travelled through early Christianity, Roman law, and ecclesiastical law to become a standard non-religious criminal offence in Europe, including Russia. The Protestant Reformation ended the church Courts in much of Europe, requiring them to be handled by secular law. This uniform pattern was broken by the Napoleonic Penal Code of 1810, which drew no distinctions between homosexual and heterosexual acts, a legal innovation adopted by the Netherlands, Belgium, Spain, Portugal, and Italy, resulting in only British colonies having inherited the prohibition. In Asia and Africa, the legacy of 1534 is now hidden behind the language of the 19^th-century Indian Penal Code (IPC), imposed on colonial India in 1861, before it travelled to parts of Africa.

The most telling illustration of colonialism’s uneven legal afterlife lies in the diverging fates of s. 377 of the IPC. Drafted by Thomas Babington Macaulay, the section stated that “whoever voluntarily has carnal intercourse against the order of nature with any man, woman or animal” would be punished with imprisonment or fines. It travelled with the empire, exported to colonies across Asia and Africa as a standardised instrument of moral policing. 

The empire that exported this moral code was slow to reckon with it on its own soil. In 1966, the year before partial discrimination through the Sexual Offences Act, 1967, some 420 men were convicted of gross indecency in Britain; by 1974, that number had surged to 1,711, a rise of over 300%. Full reform did not arrive until the Sexual Offences Act of 2003, meaning that for 470 years, England and Wales maintained a criminal code that penalised gay sexuality, the same code it had spent centuries exporting. Scotland’s anti-LGBTQ+ laws were not repealed until 2013. India, inheritor of the same provision, did not strike down s.377 until 2018, over 150 years after it was imposed. The slowness of the coloniser’s own reform is not incidental; it is precisely what made the inheritance so durable and so devastating for those on whom it was imposed. Their survival after independence reflects not only legal continuity but also the willingness of postcolonial governments to deploy them in the service of nation-building, moral politics, and claims of cultural authenticity.

Sexuality in Pre-Colonial Africa 

Colonialism shaped the archives through which Africa came to be understood: same-sex intimacies were frequently ignored, misrepresented, or relegated to the margins of colonial records, creating silences that continue to distort contemporary understandings of Africa’s sexual past.

The claim that homosexuality is ‘un-African’ collapses under the weight of the historical record. Long before colonial law arrived to declare it criminal, same-sex relationships and gender-nonconformity were documented across more than 40 pre-colonial African societies. Among the Langi of northern Uganda, effeminate males known as ‘mudoko dako’ were treated as women and could marry men. In Angola, the Chibados male diviners were believed to carry female spirits and occupied recognised spiritual roles within their communities. Woman-to-woman marriages were equally documented, a practice so perplexing to European travellers that it provoked, in the words of one Portuguese soldier writing in 1681, accusations of ‘sodomy’ and ‘filth’. What unsettled the colonisers was not deviance, but the difference they had no framework to understand. As legal scholar Sylvia Tamale of Makerere University puts it, “it is not homosexuality that is alien to Africa, but homophobia.”

The deployment of African culture as a shield against LGBTQ+ rights is not a natural outgrowth of the continent’s traditions; it is a political construction with a familiar precedent. When Mobutu Sese Seko built his decades-long dictatorship on the ideology of authenticité, he justified it by reference to African culture, ‘Democracy is not for Africa,’ he said, ‘there was only one African chief.’ Yet paradoxically, Mobutu was not recovering African tradition but deploying European colonial stereotypes about it, borrowing from colonial predecessors the very ideas he claimed to reject. The same logic is now deployed against sexual minorities, with homophobia dressed as heritage. Yet the historical record tells a different story. In ancient Egypt, same-sex intimacy was, at certain periods, legally recognised. Among the Azande of pre-colonial Sudan, male same-sex marriage was legally acknowledged, with dowry paid to boy-wives and damages awarded for infidelity. African culture was never homogeneously heterosexual; it was diverse, varied, and far more accommodating than the colonial legal code imposed upon it. What is rarely acknowledged is that the homophobic rhetoric currently rising across Africa is not organically domestic; it is funded and sustained by Western, specifically American, conservative campaigns, making it contemporarily manufactured. As historians Murray and Roscoe conclude, the colonialists did not introduce homosexuality to Africa but rather the intolerance of it, and systems of surveillance and regulation for suppressing it.

Contemporary Africa: The Inheritance Enforced 

The scale of inheritance is telling. Across Africa, 32 of 54 countries, according to ILGA, criminalise same-sex relations, a uniformity that reflects colonial standardisation. What is more alarming than the number is the direction of travel; these laws are not relics being passively retained, they are actively being reinforced, expanded, and, in several cases, made more severe. 

Uganda’s Anti-Homosexuality Act of 2023 stands as the most egregious example, imposing life imprisonment for homosexuality and the death penalty for ‘aggravated homosexuality,’ while organisations found guilty of ‘promoting homosexuality’ face fines up to USD 266,000 and permanent suspension of their licenses. Senegal amended its Penal Code as recently as March 2026, increasing prison terms for ‘acts against nature’ from one to five years to five to ten years, and separately criminalising the funding of any activity deemed to promote homosexuality. 

The Ugandan President, Yoweri Museveni, has called on African leaders to reject the promotion of homosexuality, believing it to be a real danger to humanity and a big threat to the procreation of the human race. Across Africa, so-called ‘family values’ conferences have proliferated, bringing together international organisers, local lawmakers, and faith leaders under the banner of defending traditional family life, a banner that, on closer inspection, doubles as a coordinated campaign against LGBTQ+ existence and abortion rights. In Uganda, the Catholic church has become the institutional reference point for political leaders wishing to speak against homosexuality, with government ministers publicly arguing that it is alien to Ugandan culture and a threat to the country’s traditions. What is presented as cultural sovereignty is, upon examination, a colonial inheritance, one that the coloniser quietly set down while the colonised were left to enforce it.

A Second Wave 

Ironically, what goes largely unacknowledged is that Africa is also the target of a more contemporary importation of intolerance. In 2009, American evangelical pastor Scott Lively travelled to Kampala at the invitation of the Ugandan Parliament, briefing lawmakers on how to address homosexuality, a visit widely regarded as a catalyst for the Anti-Homosexuality Act that followed. He was not an isolated actor. Family Watch International, led by Sharon Slater and “described as a hate group” by the Southern Poverty Law Centre, has sponsored trips for politicians from Kenya, Uganda, and beyond, training them on what activists “describe as an extremist anti-LGBTQ+ agenda.” In April 2023, the organisation hosted an inter-parliamentary conference in Uganda, attended by leaders from 22 African countries, after which a Kenyan MP vowed to table an anti-gay bill in parliament. “There is nothing organic about the wave of anti-homosexuality bills we are seeing,” said Muthoni Ngugi of the East Africa Legal Service Network. As Dr Kapya Kaoma concludes, these organisations are losing the culture wars at home and seeking quick gains elsewhere. 

The Human Cost 

“It is crucial to acknowledge that these challenges faced by LGBTI people in Africa extend beyond the realm of legality, encompassing a profound struggle for the hearts and minds of societies. However, the abuse of law has undoubtedly heightened their vulnerability and underlines the urgent necessity for coordinated regional and international intervention,” observed Samira Daoud, Amnesty International’s Regional Director for West and Central Africa. 

The evidence bears her out with devastating precision. In January 2011, David Kato, Uganda’s most prominent gay rights activist, was beaten to death at his home in Kampala, weeks after a local tabloid published his name and photograph under the headline ‘Hang Them.’ He had just won a court case against the publication. Kato’s murder was not an isolated act of violence but a consequence of a climate that legislation actively creates. In Burkina Faso, following the junta’s criminalisation of homosexuality in September 2025, LGBTQ+ people report living in fear of a ‘witch hunt,’ with photographs shared on social media as evidence and lists of meeting places passed to authorities. “With this law, people will feel they have a mission: to hunt down homosexuals,” testifies Quentin, a gay Burkinabe man living in Ouagadougou. 

The consequences extend beyond persecution into public health. Criminalisation drives LGBTQ+ people away from healthcare, creating conditions in which HIV thrives invisibly. Rates are estimated at 27 times higher than for other men in eastern and southern Africa and 199 times higher than for other men in western and central Africa. Anti-LGBTQ+ policies, which strengthen stigmatisation and control of people living with HIV/AIDS, undermine progress towards mitigating the epidemic. The COVID-19 pandemic compounded these vulnerabilities further, as restrictions on public gatherings, diverted resources and heightened surveillance. These laws thereby put Africa’s fight against HIV in ‘great jeopardy.’ In Uganda alone, police raided shelters for homeless LGBTQ+ youth, arresting dozens and subjecting some to forced anal examinations, a practice Human Rights Watch has “described as cruel, degrading, and constituting torture.” In August 2021, 54 civil society groups were indefinitely suspended. Sexual Minorities Uganda, which had provided education and healthcare advocacy for LGBTQ+ people since 2004, was ultimately banned entirely. Behind every statute and every amendment, a person is paying the price for someone else’s imported conviction.

Conclusion 

The two women arrested for sharing a Valentine’s Day kiss in Uganda did not violate an ancient cultural prohibition. They were caught in the machinery of a legal code drafted in a foreign capital, exported across an empire, abandoned by its authors, and then handed down as tradition. That is not heritage. That is inheritance, and inheritance, unlike tradition, can be refused.

Across the continent, some are refusing it. Namibia decriminalised same-sex relations in 2024. Botswana formally removed the colonial prohibition from its penal code in 2026. These are not concessions to Western pressure; they are corrections of a Western imposition. The demystification of homophobic pseudo-history and the detachment of homophobia from African-ness are, therefore, a necessary first step in the promotion of LGBTQ+ rights, not as a foreign agenda, but as a reclamation of what the continent’s own history has always shown to be true. In Botswana and Namibia, the government has recognised that enforcing the private moral views of a majority does not justify criminalising another’s freedom. That criminalisation itself is a public health failure, one that bars LGBTQ+ populations from accessing the treatment and care they are owed.

But for the millions still living under laws they never chose, written by hands that have long since washed themselves of them, and now reinforced by a second wave of foreign moral entrepreneurship, the weight of the inheritance remains. It is measured in raids, in bans, in bodies, and in the quiet daily cost of living under a law written for you by someone who never asked. The first wave of intolerance arrived with the coloniser’s penal code. The second arrived with the missionary’s chequebook. Both called it tradition. Neither was.

Featured/Headline Image Caption and Citation: “HarareMarch,” Image Sourced from Wikimedia Commons | CC License, no changes made