The Associazione per gli Studi Giuridici sull'Immigrazione (ASGI) has published a new research report, Migration from Libya. Between Externalisation Policies and the Exploitation of Migrants (2017-2025), produced with the University of Milan within the project Traces of Mobility, Violence and Solidarity, funded by the Compagnia di San Paolo Foundation.

Drawing on years of strategic litigation carried out through ASGI's Sciabaca and Oruka project, the report reconstructs how the 2017 Italy-Libya Memorandum of Understanding reshaped the Central Mediterranean Route (CMR). After an initial fall, sea crossings from Libya have risen again since 2020, and the migrant population inside the country reached an estimated 928,839 people between August and October 2025, an 18% increase year-on-year according to the International Organization for Migration.

The report argues that European and Italian funding for the Libyan Coast Guard (LCG) has not reduced departures, but has instead consolidated a profitable system built around Libyan detention centres. There, extortion is described as the core business model: detainees are tortured, the violence is filmed and sent to their families to obtain ransom payments, and those who cannot pay are often trapped in cycles of re-detention or handed over to armed groups to work off their debt.

A substantial section addresses legal accountability. It traces the International Criminal Court's (ICC) longstanding interest in crimes committed against migrants in Libya, from Prosecutor Fatou Bensouda's early findings of "systematic atrocities" to a 2021 communication asking the Court to investigate 19 individuals for crimes against humanity under Article 7 of the Rome Statute.

On Italy's own responsibility, the report examines Article 16 of the Articles on Responsibility of States for Internationally Wrongful Acts (ARSIWA), covering a State's liability for aid or assistance in another State's wrongful acts, alongside individual criminal liability under Article 25(3)(c) and Article 25(3)(d) of the Rome Statute. It also revisits the European Court of Human Rights' case law on extraterritorial jurisdiction, contrasting Hirsi Jamaa and Others v. Italy with the more restrictive S.S. and Others v. Italy.

At the national level, the report highlights a growing line of Italian case law recognising Italy's liability for maritime push-backs carried out with Libyan involvement. In the pioneering Orion case, the Rome Tribunal held in 2019 that intercepting and returning migrants to Libya violates not only the principle of non-refoulement but also the right to asylum enshrined in Article 10, paragraph 3 of the Italian Constitution, ordering compensation and the issuance of entry visas. Subsequent rulings, including several cases linked to the 2018 push-back carried out by the Italian merchant vessel Asso 29, have since consolidated this line of jurisprudence.

The final chapter challenges the legitimacy of the Libyan Search and Rescue (SAR) zone, established in 2017. It argues Libya cannot be considered a safe country for disembarkation and that the LCG lacks the capacity to conduct genuine rescue operations, a finding echoed by the Court of Crotone in the June 2024 Humanity 1 case, which leaves Italy with a residual duty to intervene at sea.