Throughout the history of nuclear counterproliferation, Libya was the only U.S. enemy which renounced its nuclear weapons program. In December 2003, Libya announced a decision of “its own free will” to stop developing its WMD programs including nuclear weapons. Shortly after the announcement, U.S. implemented inspection of Libyan nuclear facilities and verified that “Libya has eliminated or has set in place the elimination of all its WMD and MTCR-class missile programs” (DeSutter 2004).
Contrary to its successful counterproliferation against Libya, the U.S. failed to stop other adversarial nuclear aspirants, such as North Korea and Iran, from developing nuclear weapons. Despite two counterproliferation agreements with the U.S. (the Agreed Framework in 1994 and the Joint Statement in 2005), North Korea did not abandon its nuclear ambition and became a
This article argues that Libyan nuclear reversal was caused by two factors – a credible guarantor and cooperation against a common threat – which decreased the level of distrust between adversarial counterparts. The United Kingdom, which had the willingness and capacity, played a pivotal role as a credible guarantor and alleviated distrust by providing its own security guarantee to Libya and by confirming Libya’s genuine intention for denuclearization to the U.S. The U.S.-Libyan cooperation against their common enemy – terrorist groups – also contributed to bring successful counterproliferation by greatly reducing U.S. suspicion about Libya.
This paper is expected to expand the scope of counterproliferation studies by exploring a case involving adversarial counterparts. The literature on alliance restraint on nuclear proliferation is small but relatively well developed (Gerzhoy 2015; Miller 2018; Lanoszka 2018). Despite a fact that counterproliferation efforts in recent years involve adversarial inhibitors, however, little has been written on the attempts.
In terms of policy contribution, this paper provides practical knowledge to policymakers who are eager to restrain nuclear aspirants. States have strived to stop other states from having nuclear weapons for various reasons: some leaders believe that the spread of nuclear bombs can endanger international security (Sagan 1994; Sagan and Waltz 2003); others argue that proliferation would reduce nuclear states’ bargaining leverage over nonnuclear states (Kroenig 2010). To their disappointment, however, efforts to prevent nuclear proliferation have not always been successful. Since this article analyzes the determinants of counterproliferation success in Libya, it can offer recommendations about which strategies policymakers should adopt to prevent further nuclear proliferation.
This paper proceeds as follows. The next section demonstrates distrust between the U.S. and Libya, which prohibited their agreements on the counterproliferation issue. Then, I analyze how the two factors – the U.K.’s as a credible guarantor and U.S.-Libyan cooperation against terrorist activities – brought about the successful nuclear reversal in Libya by reducing distrust. In the subsequent section, I examine two alternative explanations. The final section summarizes the main findings and provides implications.
It is hard to achieve successful counterproliferation against adversaries since there is a high level of distrust between them. Distrust is mostly caused by the risk of cheating, which means that each side greatly worries that the other might unilaterally break counterproliferation agreements and gain unfair benefits.
The key concern for the Libyan authorities was how far and how quickly the U.S. would provide promised inducements – normalization of bilateral relations – in exchange for eliminating its nuclear weapons program (Schwartz 2007, 575). Saif Aleslam, a son of Muammar Qaddafi, announced in Middle East Policy that: “Libya insists on Washington’s stating explicitly that, following the settlement, it will permanently lift the barriers to Libya’s normal relations with the outside world. This applies particularly to the United States itself” (al-Qadhafi 2003).
Libyan anxiety about the inducements was fostered by U.S. hostile measures against the regime. In December 2002, for example, the George W. Bush administration identified Libya as one of the countries “that are the central focus of the new U.S. approach” along with Iran, Syria, and North Korea and stated that the U.S. would “respond with overwhelming force, including “all options,” to the use of biological, chemical, radiological or nuclear weapons on the nation, its troops or its allies” (Allen and Gellman 2002). This hostile measure made Qaddafi uncertain and anxious about U.S. inducements. Qaddafi, therefore, insisted on further reassurance of U.S. inducements by saying that “if Libya abandoned its WMD program, the U.S. in turn would drop its goal of regime change” (Hirsh 2005).
The U.S., on the other hand, was suspicious of Libya’s intention of abandoning its nuclear weapons program. It was because Libya showed “behaviour that is difficult to square with its supposed willingness to give it up” (Jakobsen 2012, 500). As explained above, the Libyan delegation kept denying the existence of a nuclear program until the BBC China interdiction. It was difficult for the U.S. to consider this Libyan move as showing “any eagerness with respect to coming clean on … its nuclear programme” (Jakobsen 2012, 501).
U.S. mistrust of Libya had a deep-rooted history. Since 1992, Libya had approached the U.S. about the normalization of bilateral relations. At that time, Libya was accused of being involved in the bombing of Pan Am Flight 103 over Lockerbie, in which 270 people died. The Libyan side suggested to turn over the two Pam Am bombing suspects, Abdel Basset Ali Megrahi and Lamen Khalifa Fhimah, in return for a commitment from the U.S. such as the lifting of sanctions and eventual normalization of relations between the two nations. The U.S., however, denied the discussion itself because it did not believe that Libyan offer was serious (Hart 2004). Ronald E. Neumann, then the Deputy Assistant Secretary of State, raised two major concerns about Libya: first, the “Libyan leadership may be fundamentally anti-American, that is, committed to opposing American interests and an American policy agenda simply because they are American.” Second, “Libya continues to pursue programs for the acquisition of WMD and missiles, which would threaten U.S. interests (Zoubir 2006, 53).” This statement well captures how the U.S. considered Libya and its claim for nuclear rollback.
The U.K. played a pivotal role as a credible guarantor in reducing distrust between the U.S. and Libya since it had both the willingness and capacity to be a credible guarantor.2 The U.K. government’s performance “stood as a testament to the notion that adversarial relations could be reversed” (Alterman 2006, 24).
The U.K., however, was not able to develop its economic relationship with Libya because of the U.S. secondary boycott. In 1996, the U.S. enacted the Iran and Libya Sanctions (ILSA) because of Libya’s involvement with the Lockerbie attack.3 The U.S. renewed the bill for five years in 2001, which even reduced the limit on investment to \$20 million.4
The U.K. was still struggling with the ILSA because the Libyan energy industry was too important for the U.K. to give up. Robertson Research, a British consulting company, ranked Libya “as the world’s top exploration spot” for three years in a row from 2000 (Robertson Research 2002, 20). The company analyzed that total oil reserves in Libya, combining discovered and undiscovered recoverable ones, were estimated at 56.9 billion barrels of equivalent (Robertson Research 2002, 20). The natural gas reserves, which were expected to be enormous, also remained mostly unexplored (Katan and Khalaf 2006). Since the U.K prioritized its alliance with the U.S., London felt restricted to maintain or expand its business with Tripoli, which might hurt Washington’s feelings (Genugten 2016, 125).
Many European countries heavily relied on Libyan oil due to its high quality and its proximity to Europe (O’Sullivan 2003, 189). In 2001, Libya was the fourth biggest supplier of crude oil to the European countries, following Norway, Russia, and Saudi Arabia (European Commission 2020). The top three importers were Italy, France and Germany. Among them, Italy was especially dependent on Libyan oil since it imported a quarter of its total needs from Libya (Eurostat 2020).
Despite European energy dependence on Libya, securing a steady oil supply from Libya had been consistently challenged by the U.S. UN sanctions, which were prompted by the U.S. and prohibited Libya from buying equipment for refineries, disturbed a stable supply of oil to Europe (O’Sullivan 2003, 197).
The Tony Blair government believed that Libya’s nuclear rollback would strengthen its leadership in the region by solving volatility of energy supplies from Libya. The U.K. wanted “to rebuild its status in Europe and sees Libya as a means by which it can demonstrate to its partners its influence in a region of vital importance to Europe, particularly over questions of energy supply” (Joffé 2004, 224).
The U.S., however, did not want to provide any specific
The U.K. resolved Libya’s worries about U.S. inducements by providing its own security assurances to Libya. The U.K. agreed with Libya to sign
-The U.K. would “seek appropriate action by the Security Council in the event that it determines that the Great Socialist People’s Libya Arab Jamahiriya is subject to an act of aggression or threat of aggression in which chemical or biological weapons are used.”
-The U.K. would “work directly or through the international community to strengthen Libya’s conventional defense capabilities so as to ensure that it is able to protect its security and the safety of its national territory from all threats.”
-Libya and the U.K. would affirm “the intention of the U.K. to seek immediate Security Council action to provide assistance, in accordance with the Charter, to any non-nuclear weapons state party to the Treaty on the Non-Proliferation of Nuclear Weapons, that is a victim of an act of aggression in which nuclear weapons are used.” (Bowen 2012, 99)
In addition to providing positive security assurance, the U.K. also helped Libya to attain negative security guarantees, albeit informal, from the U.S. Michael O’Brien, then U.K. Foreign Office Minister responsible for relations with North Africa, visited Libya in August 2002 and discussed the nuclear issue with Qaddafi. After O’Brien’s visit to Libya, Blair proposed to accept “a reaffirmation that a deal on WMD would bring normalization of relations” at a meeting at Camp David in September of 2002 (Jentleson and Whytock 2005, 73). Bush accepted Blair’s suggestion. As a result, the U.S. agreed to provide “implicit assurance of regime survival” in the form of an “assurance of non-intervention” (Litwak 2008, 99). Saif Aleslam said that Libya decided to abandon its WMD programs in December 2003 “after Washington assured Gadhafi it was not planning to topple him” (Bowen 2012, 97). According to him, Libya was also promised to receive economic assistance via foreign investment and access to strengthen its defense capabilities (Litwak 2007, 194-195).
British assurance of Libyan intention to the U.S. was possible for two reasons. First, the U.K. was able to understand what the Libyan authorities had in mind since the two states had maintained close relations for decades. Despite officially cutting diplomatic relations in 1984, the U.K. kept “informal contacts with Libya during the 15 years prior to 1999” until it resumed official relations again (Bowen 2006, 59). Especially after O’Brien’s visit to Libya, there was conviction on both sides that the U.K. and Libya had established a channel together that could potentially negotiate with the U.S. on the Libyan WMD issue (Bowen 2006, 61-62).
Second, the U.K. was a close ally of the U.S. Since 1940, the two countries had enjoyed a “special relationship” sharing similar interests over politics, economy, and security (Mix 2018, 12). In 2003, for example, President Bush stated that “[t]he United States has no truer friends than Great Britain” (Hewiit 2016). The extraordinary relations between the two states enabled the U.S. to believe the British assurance of Libya’s intention for denuclearization.
U.S.-Libyan joint counterterrorist activities enabled them to reach the successful counterproliferation by mediating U.S.’s distrust of Libya. The two countries actively cooperated against Islamic terrorist groups because the terrorists were the biggest security threat to both of them. Libya provided useful intelligence about terrorist organizations to the U.S., which the U.S. did not have. The U.S. suppressed terrorist groups with its military capability and curtailed international support to them, which was beyond Libya’s capacity.
Libya, however, halted its support for terrorist movements in the late 1980s when terrorist groups started to attack the Qaddafi regime. Islamic fundamentalists were dissatisfied with the Qaddafi regime because Qaddafi attempted to replace the old religious establishment with his own Islamic ideology, “which he viewed as more progressive and in line with the spirit of the nationalist era” (Pargeter 2012, 86). These reformative actions provoked a number of anti-Qaddafi terrorist movements inside and outside of the country.
Libyan terrorist groups targeting the Qaddafi regime posed grave security threats to the regime through the entire 1990s. Among a number of terrorist groups, the biggest security concern to the regime was the Libyan Islamic Fighting Group (LIFG). During the 1990s, the LIFG frequently attacked security forces in Libya and provoked massive armed resistance against the regime (U.S. Department of State 2006, 210). It even attempted to assassinate Qaddafi four times – the last attempt in 1998.
The Qaddafi regime, however, achieved only partial success in suppressing the rebellions. First, the eastern region of the country, where the LIFG had its bases, was so mountainous that the regime found it difficult to conduct military operations against the terrorists. The offenses by Qaddafi in 1996 severely weakened the power of the LIFG but failed to completely eradicate them from the area.7 Second, Libya was also struggling to cut external assistance to the LIFG. It was important to cut this support because the LIFT kept strengthening its power by actively engaging with international terrorist groups such as al-Qaeda, Armed Islamic Group (Groupement Islamique Arme, GIA), and Salafist Group for Preaching and Combat (Le Groupe Salafiste pour la Predication et le Combat, GSPC) (Hochman 2006, 67; Ashour 2011, 378).
From the Libyan perspective, threats from Islamist fundamentalists were greater than those from the U.S. As a personalist regime concerned more “about the security of the regime than that of the state as a whole, largely because of its preoccupations with regime survival from domestic challenges to its own authority,” the Qaddafi regime considered the terrorist attacks more offensive since they were directly aimed at regime security (Hong 1999, 5). As demonstrated above, the Islamist radicals, who labeled the Qaddafi regime as “infidel,” wanted to replace it with orthodox Islamist leadership (Ronen 2008, 42). Qaddafi consistently viewed the Islamic opposition “as the single most important internal challenge to his regime” (Pargeter 2008, 83). In contrast to terrorist threats targeting the Libyan leadership, U.S. policies against Libya were not aiming to weaken regime security. It was because the U.S. mainly focused on isolating Libya from the international community by imposing various economic sanctions.
The Bush administration’s military response, however, was unsuccessful in that the U.S. had failed to capture or annihilate al-Qaeda and the Taliban leadership. U.S. bombs were often poorly targeted and failed to hit principal Taliban forces. Despite fierce battles of Kandahar and Tora Bora in December 2001, a number of al-Qaeda fighters and Taliban forces, including bin Laden, survived and escaped to Pakistan (Kellner 2003, 97). In an interview with USA Today, then Secretary of Defense Donald Rumsfeld admitted that the U.S. did not know the location of bin Laden and that finding him was a difficult mission like “looking for a needle in a haystack” (CNN 2001).
The failed attacks against al-Qaeda and the Taliban regime was mostly caused by an “intelligence vacuum” on the targets (Kellner 2003, 97). Due to short the timeline of U.S. military operations, Washington developed its relationships with local intelligence sources too quickly without having enough time to check their loyalty and quality (Conneta 2002). For this reason, Washington failed to attain neither sufficient nor qualified information about terrorists and their locations.
Poor intelligence hindered U.S. forces from conducting effective military operations mainly for two reasons. First, false information boosted civilian casualties, which made local people reluctant to cooperate with the U.S. Civilian casualties in the Afghanistan campaign was at least four times as much as in the Kosovo war in 1998 (Conneta 2002). Second, U.S. bombing campaigns were often exploited for a “proxy war” between local rival groups.9 Anti-Taliban forces often had their revenge against the Taliban government by borrowing U.S. military capability. These reprisals were “either irrelevant or even detrimental to U.S. campaign objectives” since they resulted in the continuous escape of major terrorist figures for whom the Bush administration had searched (Conneta 2002).
Substantial progress in U.S.-Libyan counterterrorist cooperation began in October 2001.10 After the 9/11 attacks, the CIA director George Tenet strongly emphasized the necessity to work “closely with intelligence agencies across the Muslim world” to defeat al-Qaeda (Cobain 2017). With this aim, William Burns, then the Assistant Secretary of State for Near East Affairs, met with Musa Kusa, the chief of the Libyan intelligence, in London and asked Libyan assistance to fight against the terrorists “in serious need of one thing Libya could provide: intelligence” (Suskind 2006). American demands were straightforward: “Washington presented Kousa [Kusa] and his colleagues with a list of more than 40 Libyan intelligence agents it accused of co-ordinating terrorist attacks” (Beaumont et al. 2003). Upon the request, Kusa handed over a list of key terrorist figures including al-Qaeda and other terrorist groups fighting with bin Laden in Afghanistan (Zoubir 2011, 286-287). After this, Tripoli kept sharing useful information related to terrorist activities with Washington.
Libya was able to provide intelligence since it had various channels for gathering information about terrorist organizations. Most data had been accumulated via Libya’s wars against terrorist organizations since the late 1980s. Libya also could gain precious information on the Islamist radicals due to its geographical situation of being surrounded by “strong Islamist presence and immigrants from South Asia and the Arab World.” (Zoubir 2006, 59) The Qaddafi regime also amassed terrorist data from the
The U.S. reciprocated by eradicating the LIFG still remaining in Libyan territory. The U.S. bombing of Afghanistan in November 2001, for example, “flushed out” scores of LIFG members who had been protected by the Taliban government (Pargeter 2012, 99). The U.S. also curtailed international support to the LIFG. The U.S. froze assets of the LIFG in late September 2001 and listed it on the Terrorist Exclusion List (TEL), which permitted the U.S. to “exclude or deport aliens who provide material assistance to, or solicit it for, designated organizations.” (United States of Department 2002, 151).11 Additionally, the U.S. designated the LIFG as a Foreign Terrorist Organization (FTO) in December 2004.
Since Libya had already been accused of its own terrorist activities – some of them directly targeting the U.S. – the U.S. had to be more cautious when cooperating with Libya over the counterproliferation issue. As mentioned earlier, the U.S. denied Libyan approaches to discuss its nuclear weapons program in the 1990s.
In 1999, for example, the U.S. refused the Libyan offer by saying that the U.S. “did not wish to pursue the WMD question; terrorism and the resolution of the Lockerbie case were [its] top priorities” (Zoubir 2006, 62).
Libya’s suggestion to discuss the dismantling of its own nuclear weapons program was finally accepted when Libya eagerly cooperated on U.S.-led counterterrorism activities. In March 2003, Libya came to the U.K. and expressed its willingness for negotiations over its WMD program with the U.S (Blair 2003). After that, trilateral talks for Libyan counterproliferation began in earnest.
Due to Libyan efforts of fighting against terrorism, U.S. stance on the Libyan counterterrorist activities changed in a favorable way. The U.S. Department of State, for example, described Libyan cooperation with much suspicion in 2001: “Libya
This section examines two alternative explanations about Libyan nuclear renunciation, one focusing on positive inducement and the other on politico-economic factors.
The positive inducement explanation argues that Libya abandoned its nuclear weapons program because of positive inducements from the U.S (Nincic 2011; Reardon 2010). The political and economic rewards were sufficient enough to encourage Libya to renounce its nuclear ambitions.
The positive inducement explanation, however, has the following shortcoming in that the U.S. did not explicitly state what compensation would be until Libya completely abandoned its nuclear weapons program. The arguments of the positive inducement explanation assume that Libya was certain of rewards from the U.S. in case of its nuclear renunciation. As explained, however, Libya was seriously concerned about the reliability of U.S. inducements. Libya decided to renounce its nuclear weapons programs not because Libya was certain of U.S. rewards, but because the U.K. reduced the uncertainty of U.S. inducements by providing the British security assurances to Libya.
The political economy explanation argues that Libya’s nuclear reversal was possible due to Qaddafi’s desire for global economy (Solingen 2007). The shift from an inward-looking to an outward-looking model brought Libya’s nuclear rollback by increasing the sanctions’ effectiveness against Libya.
There is, however, major inconsistency between this explanation and the Libyan case. Qaddafi expressed its willingness to halt its nuclear weapons program six years before he started his economic reforms. Major shifts in Libyan economic policies began in 1998 as Qaddafi took up with pro-reform pragmatists (Takeyh 2001). Libya, however, made conciliatory gestures to the U.S. in the late 1980s. In 1988, Qaddafi showed an interest in starting bilateral talks with the U.S. in order to resolve “the difficult issues that had dogged US-Libyan relations for many years” (St. John 2004, 388). The Qaddafi regime showed its willingness again to make concessions over its WMD programs in exchange for normalization of bilateral relations in 1992 (St. John 2004, 388). These facts refute the political economy explanation arguing that economic liberalization should coincide with or precede nuclear reversal.
This paper explains why U.S. counterproliferation efforts successfully led Libya to renounce its nuclear weapons program. Consequently, counterproliferation against Libya was successful because two factors were present. The U.K., which had the economic and political willingness, greatly mitigated distrust by decreasing the Libyan uncertainty of U.S. inducements and the U.S.’s worries of the Libyan nuclear aspiration. With regard to its willingness, the U.K. expected huge gains from the Libyan oil industry and restoration of its status as a leading state among European countries. As for its capability, the U.K. reduced the Libyan distrust of the U.S. by providing direct inducements to Libya and thereby weakened Libya’s uncertainty that it might not be rewarded after its nuclear renunciation. The U.K. also resolved U.S. suspicion by sharing its information about Libya’s sincere intention for nuclear rollback. It helped weakening the U.S.’s distrust of Libya. In addition, Libya cooperated with the U.S. against terrorist activities, which enabled the two counterparts to cooperate again over the counterproliferation issue by reducing distrust. Cooperation against terrorist threats was possible because the terrorists posed the biggest security threat to both U.S. and Libya.
Despite different historical and geopolitical contexts, findings of this paper have implications for explaining why the U.S. failed to denuclearize North Korea and Iran. In the case of North Korea, there was no credible guarantor which could reduce distrust between Washington and Pyongyang. China, the chair of the Six-Party Talks, was expected to play this role, but it had neither the willingness nor the capability to be a credible guarantor (Samore 2003). In addition, North Korea did not share any adversary with the U.S. They had a chance to cooperate against terrorism after 9/11, but the U.S. consistently refused to cooperate with North Korea, an “axis of evil” country (Pritchard 2007; Chinoy 2008). As a result, the level of distrust was too high for them to achieve agreements on denuclearization of North Korea.
The Iranian nuclear crisis could also be explained by this paper’s arguments. First, there was no credible guarantor in this case. Three European countries – France, Germany, and the U.K. (EU3) – were willing to play this role but did not have the capability to decrease distrust between the U.S. and Iran. It was because they failed to make concerted policies not only among themselves, but also with the U.S. When President Barack Obama suggested the swap deal to Iran in 2009, for example, Germany welcomed the proposal while France and the U.K. were critical of it.12 Due to disharmony among the would-be guarantors, the level of bilateral hostility between the U.S. and Iran remained high. In addition, Washington and Tehran did not share enemies, thus did not cooperate against common threats. Iran persistently supported terrorist organizations, such as the Kata’ib Hizballah (KH), the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), and the Bashar al-Asad regime in Syria, which the U.S. strongly opposed or designated as a Foreign Terrorist Organization. Thus, the U.S. and Iran failed to decrease the level of distrust which was essential to reach counterproliferation success.
1 This article distinguishes counterproliferation from nonproliferation. While nonproliferation is defined as “activities to deter or dissuade state and non-state actors from acquiring nuclear weapons,” counterproliferation denotes “strategies that compel to stop or reverse nuclear activities that state and non-state actors have already begun.” For details, see (Wilson Center 2005).
2 A credible guarantor is a state playing a pivotal role in reducing distrust between a nuclear proliferator and a counterproliferator. Contrary to a mediator, which arranges the setting for negotiations and promotes bilateral talks between counterparts, a credible guarantor is more actively involved in the counterproliferation process and often provides its own guarantees to a counterpart (or both if necessary) in order to reduce distrust.
3 According to regulations under the ILSA, the U.S. government could impose mandatory sanctions on any company that made investments of more than \$40 million over 12 months in Libya’s energy sector.
4 Even though most European countries agreed that Libya had met all the requirements from the West by turning over the two suspects of the Lockerbie bombing in 1999, the U.S. insisted on the extension by arguing that additional measures were necessary until the U.S. was assured of Libya’s sincerity. For details, see (Robertson Research 2001, 7).
5 The Green Book, a short book containing Qaddafi’s political philosophy, properly elaborated on this aspect; “all states made up of diverse nationalities for religious, economic, military or ideological reasons will eventually be ripped apart by national conflict until every nationality gains its independence.” For details, see (Genugten 2016, 87-88).
6 The agency assisted various organizations such as the Palestinian Islamic Jihad, the Irish Republican Army, and the Moro National Liberation Front of the Philippines. For details, see (Pargeter 2012, 136).
7 In addition to the military strikes, Qaddafi carried out various measures to restrain the terrorist activities. In June 1996, after a revolt by several Islamist inmates of the Abu Slim prison, he executed a massacre of prisoners in the name of eliminating Islamic opponents. In March 1997, he enacted the Charter of Honor, a law to punish people providing assistance to or involving in Islamist rebellions. For details, see (Pargeter 2011).
8 While the LIFG leadership denied its connectivity with al-Qaeda, hundreds of its members joined al-Qaeda in Afghanistan when the LIFG failed to assassinate Qaddafi in 1996. The U.S. designated it as a FTO shortly after 9/11.
9 The word of “proxy war” has dual meanings. As explained above, one captures the local military forces’ proxy war by using U.S. military fighting against their long-time enemies. The other meaning implies that the U.S. carried out a proxy war by using local militia fighting against terrorists without dispatching U.S. ground troops. For details, see (Kellner 2003, 174-177).
10 U.S.-Libyan cooperation against terrorism was possible because terrorism posed the most dangerous security threat to them, even greater than the threat they posed to each other. As a personalist regime concerned more about regime security than state security, the Qaddafi regime considered the terrorist attacks as more offensive since they were directly aimed at regime security. The U.S. also worried more about the terrorists than the Qaddafi regime. It was because threats from terrorist organizations became the most urgent security agenda in U.S. security policies after 9/11.
11 The holding was based on the Executive Order 13224 which was signed by President Bush on September 23, 2001. According to the Order, the U.S. was able to freeze the assets of organizations and individuals accused of being related to terrorism. It included 189 groups, entities, and individuals.
12 Germany agreed with the U.S.’s ideal since it could break the deadlock in the negotiations at that time. In contrast, France and the U.K. opposed to the proposal by arguing that one-time swap would not resolve the problem. For details, see (Cronberg 2017).