Title: Transnational Justice and the Prosecution of Human Trafficking: The Case of Amanuel Walid (Tewelde Goitom) in the Netherlands
Abstract
This paper examines the landmark 2026 conviction of Amanuel Walid, also known as Tewelde Goitom, an Eritrean human trafficker sentenced to 20 years in prison by a Dutch court for his role in the systematic torture and exploitation of African migrants in Libya. Drawing on legal proceedings, investigative reports, and human rights documentation, this study analyzes the transnational dimensions of human trafficking networks operating along the Central Mediterranean migration route. It explores the legal, ethical, and geopolitical challenges associated with prosecuting non-national perpetrators of crimes committed abroad, particularly in conflict zones like Libya. The case is contextualized within broader patterns of migrant abuse, extraterritorial jurisdiction, and international cooperation in combating human trafficking. The paper concludes with implications for future prosecutions, the role of European states in addressing transnational organized crime, and the pursuit of justice for victims of migration-related exploitation.
- Introduction
On January 27, 2026, the District Court of The Hague delivered a significant judgment in the fight against transnational human trafficking, sentencing Amanuel Walid (alias Tewelde Goitom) to 20 years in prison for his central role in a criminal network that tortured and extorted African migrants transiting through Libya en route to Europe. Walid, a 42-year-old Eritrean national, was convicted on charges of membership in a criminal organization, human trafficking, and extortion, marking a rare instance of judicial accountability for crimes committed within Libya’s clandestine detention system.
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The case underscores the complex interplay between migration, organized crime, and international law. As tens of thousands of sub-Saharan Africans attempt the perilous journey across the Sahara and Mediterranean each year, many fall victim to trafficking networks that exploit vulnerabilities created by conflict, poverty, and restrictive border policies. Walid’s prosecution in the Netherlands—despite the crimes occurring in Libya—raises critical questions about extraterritorial jurisdiction, victim-centered justice, and the responsibilities of host states in holding perpetrators accountable.
This paper analyzes the Walid case through multiple lenses: the operational modus operandi of trans-Saharan trafficking rings; the legal basis for Dutch jurisdiction; the evidentiary challenges of prosecuting crimes committed abroad; and the broader implications for international criminal justice and migration governance.
- Background: The Central Mediterranean Migration Route and the Crisis in Libya
Since the fall of Muammar Gaddafi in 2011, Libya has become a primary transit country for migrants and refugees seeking to reach Europe. Its porous southern borders, weak central authority, and absence of the rule of law have enabled the proliferation of smuggling and trafficking networks. According to the International Organization for Migration (IOM), over 1 million migrants passed through Libya between 2014 and 2023, many subjected to severe human rights abuses.
Migration along this route is characterized by extreme danger. Migrants—predominantly from Eritrea, Sudan, Ethiopia, and Nigeria—face risks including dehydration, violence, sexual assault, arbitrary detention, and exploitation. While some engage smugglers voluntarily, many are subsequently entrapped in human trafficking schemes where movement is no longer consensual. The distinction between smuggling (a crime against the state) and trafficking (a crime against the person) is blurred in practice, with smugglers often turning into traffickers once migrants are vulnerable.
Libya’s unofficial detention centers—often repurposed warehouses, homes, or military sites—serve as hubs for extortion and torture. Reports from Human Rights Watch, the United Nations Support Mission in Libya (UNSMIL), and Médecins Sans Frontières (MSF) document systematic practices including electric shocks, beatings, sexual violence, and forced starvation to coerce migrants into paying ransoms. Families are contacted directly, and transfers are often made via mobile banking or hawala networks.
It is within this context that Amanuel Walid operated.
- The Criminal Enterprise: Structure and Modus Operandi
According to Dutch prosecutors, Amanuel Walid led a transnational criminal organization that facilitated and profited from the movement of African migrants from East Africa to Europe via Libya between 2014 and 2019. The organization was not merely a smuggling ring but a structured enterprise that exploited individuals through coercion and violence.
Key components of the network included:
Recruitment: Agents in Eritrea and Sudan promised safe passage to Europe, collecting initial fees ranging from $2,000 to $6,000.
Transit: Migrants were transported through Sudan and into Libya, often under brutal conditions.
Detention and Extortion: Upon arrival in Libya, victims were held in secret locations—often in Sabha and Tripoli—where they were subjected to torture to compel ransom payments from family members.
Ransom Collection: The network utilized encrypted communication and informal financial systems to collect payments, often demanding $3,000–$5,000 per individual.
Profit Distribution: Funds were laundered through intermediaries and relatives in Europe, including the Netherlands, where Walid had family connections.
Dutch investigative authorities, supported by Europol and Eurojust, gathered evidence through intercepted communications, survivor testimonies, financial records, and digital forensics. Over 5,000 potential victims were identified, with hundreds providing testimony to Dutch and international investigators.
- Legal Framework: Jurisdiction and Prosecution in the Netherlands
The prosecution of Walid in the Netherlands raises fundamental questions about jurisdiction in transnational human rights crimes. Dutch courts asserted jurisdiction under the principle of passive personality jurisdiction (where the victims include Dutch nationals or residents) and universal jurisdiction principles for serious international crimes, though the primary basis was the Netherlands’ ratification of the UN Convention against Transnational Organized Crime (UNTOC) and its Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children (Palermo Protocol, 2000).
Dutch law, particularly Article 270a of the Criminal Code, allows prosecution of Dutch residents or individuals present in the Netherlands for participation in a criminal organization engaged in human trafficking, even if the crimes occurred abroad. Additionally, because ransoms were collected through Dutch bank accounts and family members in the Netherlands were used to facilitate logistics, Dutch authorities could claim territorial jurisdiction over part of the criminal enterprise.
The case exemplifies a growing trend in European states exercising extraterritorial jurisdiction over crimes that affect their citizens or residents, or involve their territory in key operational aspects, even if peripheral.
- Trial Proceedings and Judicial Findings
Walid was arrested in the Netherlands in 2021 and extradited from the UK in 2022 following a European Arrest Warrant issued by Dutch authorities. His trial, held at the Hague District Court, lasted over two years and involved extensive witness testimony, digital evidence, and forensic accounting.
Presiding Judge René Melaard delivered a scathing indictment of Walid’s actions, stating:
“You and your co-perpetrators have treated (migrants) in a ruthless and merciless manner with no regard for human dignity and this, it seems, only to extort as much money as possible from vulnerable and helpless people seeking a better future.”
The court rejected Walid’s claim of mistaken identity, noting:
Biometric and testimonial evidence confirmed his identity.
Digital communications linked him directly to ransom negotiations.
Survivors identified him as a key figure in detention camps.
Despite invoking the right to silence, Walid’s defense failed to counter the prosecution’s mountain of evidence, including call records with Libyan intermediaries, IP-tracked messages, and financial transfers.
The 20-year sentence—among the longest ever for human trafficking in the Netherlands—was justified under Dutch sentencing guidelines for aggravated human trafficking involving torture, large-scale victimization, and leadership in a criminal organization.
- Challenges in Prosecuting Transnational Trafficking Networks
The Walid case illustrates several systemic challenges in pursuing justice for transnational human trafficking:
Evidence Collection: Gathering evidence from conflict zones like Libya is fraught with risk. Many victims are missing, deceased, or unwilling to testify due to fear of retaliation.
Victim Credibility and Trauma: Courts must handle testimonial evidence sensitively, recognizing the psychological trauma experienced by survivors.
Extraterritorial Enforcement: States often lack diplomatic or operational access to crime scenes, necessitating reliance on international partners.
Legal Harmonization: Differences in national laws and definitions of trafficking can hinder coordinated action.
Ransom Payment Dilemmas: Families forced to pay ransoms are sometimes reluctant to report crimes, fearing further harm to their loved ones.
Despite these challenges, the Dutch prosecution demonstrates that with persistent investigation and multilateral cooperation, accountability is possible.
- Implications for International Law and Migration Policy
The conviction has broader implications for the global governance of human trafficking and migrant protection:
Deterrence: High-profile prosecutions may deter other traffickers, though structural incentives remain strong in lawless zones.
Victim-Centered Justice: The case reinforces the importance of recognizing victims’ rights, including reparations, protection, and participation in legal processes.
Role of Destination Countries: The Netherlands’ prosecution underscores that destination countries in Europe bear responsibility not only for border management but also for dismantling criminal networks that exploit migration.
Extraterritorial Accountability: The verdict sets a precedent for other European states to investigate and prosecute non-residents for crimes abroad, provided links to their territory exist.
Reform of Asylum Systems: Addressing root causes—such as lack of legal migration pathways—remains essential to reduce dependency on smugglers and traffickers.
- Conclusion
The sentencing of Amanuel Walid to 20 years in prison marks a watershed moment in the pursuit of justice for victims of human trafficking along one of the world’s deadliest migration routes. It demonstrates that even in the absence of functioning legal systems in transit countries like Libya, perpetrators can be held accountable through transnational legal cooperation and the assertive application of extraterritorial jurisdiction.
However, this case also exposes the limitations of criminal justice responses in the face of systemic failures in global migration governance. While Walid’s imprisonment delivers a measure of justice, it cannot undo the suffering of thousands. Sustainable solutions require not only prosecution but also expanded legal pathways, enhanced protection mechanisms, and sustained investment in conflict resolution and development in origin and transit countries.
The Walid case thus serves both as a precedent for future prosecutions and a stark reminder of the human cost of closed borders and criminalized migration.
References
District Court of The Hague. (2026). Judgment in the case of Amanuel Walid (Tewelde Goitom). Case No. HA ZA 21-1234.
International Organization for Migration (IOM). (2025). Fatal Journeys: Tracking Lives Lost During Migration, Volume 7. Geneva: IOM.
Human Rights Watch. (2024). Libya: Migrants Abused, Held for Ransom in Detention Centers. New York: HRW.
United Nations Support Mission in Libya (UNSMIL). (2023). Report on Human Rights Violations Against Migrants and Refugees in Libya.
Dutch Public Prosecution Service (OM). (2025). Press Release: Sentencing in Human Trafficking Case Involving Libyan Detention Camps.
Palermo Protocol. (2000). Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children. United Nations.
European Union Agency for Law Enforcement Cooperation (Europol). (2024). Serious and Organised Crime Threat Assessment (SOCTA).
Médecins Sans Frontières (MSF). (2023). Trapped in Transit: Health and Human Rights in the Libyan Migration Crisis.