Occupation, colonization, aggression and annexation have become increasingly familiar words. They cover different legal realities, which often overlap. But the one that is undoubtedly marking its big, brutal return to world geopolitics is annexation. Three permanent members of the United Nations Security Council have openly expressed their desire to acquire new territories by force. Russia is already doing this on a large scale, at the cost of hundreds of thousands of lives and massive destruction. China is doing it with demonstrations of force in its sphere of influence. The United States now wants to do the same in its own sphere, while endorsing Russians conquests. At least four other countries – Israel, Azerbaijan, Venezuela and Rwanda – are de facto enlarging their territories, or have announced that they plan to do so.
There is an official definition of aggression in international humanitarian law: “the use of armed force by a State against the sovereignty, territorial integrity or political independence of another State, or in any other manner inconsistent with the Charter of the United Nations”. Armed aggression by one State against another is prohibited under international law, except in two cases: in self-defence; or when authorized by the United Nations Security Council. Aggression also has a definition in international criminal law, and is one of the crimes for which the International Criminal Court (ICC) has limited jurisdiction. This court’s purpose is to hold individuals criminally responsible, not States.
Aggression may or may not result in a situation of occupation. According to the 1907 Hague Convention, “a territory is considered to be occupied when it is in fact placed under the authority of the enemy army. Occupation extends only to territories where such authority is established and capable of being exercised”. An occupation is not necessarily illegal in itself, but it comes with obligations on the part of the occupying power. One of these relates to the question of settlement in the occupied territory. Colonization has no legal definition, but in terms of international law, the occupying power may not deport or transfer its civilian population in the territory it occupies. “That is colonization as understood, for example, in the West Bank, with the installation of Israeli settlers within the occupied Palestinian territories,” explains Marco Sassòli, professor emeritus of international law at the University of Geneva. The occupying power is also prohibited from deporting or forcibly transferring all or part of the population of the occupied territory. Such a transfer constitutes a war crime.
Annexation, a flagrant violation of international law
Occupation can turn into annexation. Annexation may be legal if it is the result of a free transaction between two States that agree on a transfer of sovereignty. But it is illegal if it results from a situation of occupation. In law, the territory remains occupied, annexation being a flagrant violation of international law. It is prohibited, even in self-defence, which distinguishes it from aggression. Can an annexation be legalized by the United Nations Security Council? “To settle a dispute, the United Nations Security Council does not necessarily have to follow international law. It may feel that a border needs to be moved to make peace,” explains Sassòli. “But I couldn’t give you an example of that.”
There are de facto annexations and de jure annexations, he adds. In the case of the West Bank, for example, the International Court of Justice (ICJ) refers to a de facto annexation by Israel. The annexation of East Jerusalem or the Golan Heights, on the other hand, is enshrined in Israeli law and is a de jure annexation.
Between 1830 and 1945 there were “around 150” annexations, according to American journalist and geopolitics specialist Fareed Zakaria. In short, that was the order of the world. Since the end of the Second World War, there have only been a handful. In 1950, China annexed Tibet. In 1974, Turkey intervened militarily in Cyprus, which had become independent in 1960, and occupied 38% of the island. In 1983, that secessionist part of the territory proclaimed itself the Turkish Republic of Northern Cyprus. Created by the Turkish occupation and controlled by Turkey, it is not recognized by the UN. This is considered a de facto annexation. In 1975, Indonesia annexed East Timor, which regained independence in 2002 after interim UN administration. In 1976, Western Sahara ceased to be a Spanish colony. But it is claimed by both Morocco and the Saharawi Arab Democratic Republic (proclaimed by the Polisario Front), it has never been an independent state, and has never had definitive legal status. In 1975, the ICJ issued an advisory opinion confirming the existence of links between the populations of the Western Sahara and Morocco as well as Mauritania, but it said these links did not establish territorial sovereignty and there was a right to self-determination. Morocco rejected the court’s conclusions. Shortly afterwards, Spain concluded an agreement giving the northern two-thirds to Morocco and the southern third to Mauritania, without consulting the Saharawis. In 1979, Mauritania ceded its part to the Polisario Front. That same year, Morocco announced its annexation of the territory. In the eyes of the UN, Western Sahara remains an un-administered territory. Legally, it is an occupied territory. In 1990 Iraq invaded Kuwait, but this annexation was reversed the following year by a massive US-led international armed intervention.
This Justice Info map excludes border disputes, and is not a historical map of annexations. It does not include certain cases of annexation from the last century, mentioned above, and deals exclusively with the current return to a new era of invaders. They may have nationalist impulses, but are driven especially by the desire to control and exploit natural resources considered strategic. This world map aims to highlight the recent acceleration in annexation and planned annexation – symbolized by events in Ukraine and Palestine, and public statements by the new US administration – in defiance of the international law that has more or less governed in the last 80 years.
- Annexations under way -
Russian Federation against Georgia and Ukraine
Vladimir Putin’s Russia was undoubtedly the main precursor and driving force behind this return to the idea of conquering territory by force. First came its seizure of 20% of Georgian territory after the 2008 war. The method here was “old-fashioned”, in a way, coming in the guise of support for Ossetian and Abkhazian “autonomists”. Then came the direct annexation of Ukraine’s Crimea in 2014, and support for a pro-Russian separatist war in the Donbass. In February 2022 came the full-scale invasion of Ukraine and in September the same year the official annexation of the south and east of the country, representing around 20% of Ukraine’s national territory. The Donbass is particularly rich in coal, iron, manganese and lithium, while the Black Sea has large deposits of oil and gas.
Ukraine, supported by 33 other countries, took Russia to the International Court of Justice, although its complaint is not based on the aggression itself but on its justification. “Russia is waging war against my country in the name of this terrible lie, according to which Ukraine is committing genocide against its own people,” declared the Ukrainian ambassador to the Netherlands in his address to the ICJ in September 2023. In March 2022, the court granted Ukraine’s request for so-called provisional measures. The judges ordered the Russian Federation to immediately suspend its military operations in Ukraine.
Ukraine has brought another case against Russia before the ICJ, dating back to the start of hostilities in 2014. It has also lodged a complaint with the European Court of Human Rights, and Ukrainian leaders are calling for the creation of a special tribunal on the crime of aggression. The ICC has launched its own investigation into war crimes and crimes against humanity committed during the conflict, issuing an arrest warrant for Putin on March 17, 2023.
Israel against Palestine and Syria
Officially, Israel is not annexing the occupied Palestinian territories of Gaza and the West Bank, but the Israeli far right, which is part of the ruling coalition, has publicly stated its ambition to seize what remains of autonomous Palestine.
Settlement in the West Bank has been ongoing for decades, with milestones like erection of the Wall that began in 2002, and has accelerated sharply since October 7, 2023. As long ago as 1967, Israel annexed East Jerusalem, which is part of the occupied West Bank. Since 1981, Israel has also considered the entire Golan Heights, taken from Syria in the 1967 Six-Day War, to be part of Israeli territory. This annexation has only been recognized by the United States, in 2019 under Donald Trump’s first presidency.
On December 8, 2024, as the Syrian regime of Bashar al-Assad was falling, the Israeli army deployed in the demilitarized buffer zone of the Golan Heights, located between the part already annexed by Israel and Syrian territory. The following day, Israeli Prime Minister Benjamin Netanyahu declared that the annexed part of the Syrian Golan Heights belongs to Israel “for eternity”. On December 15, his government approved a plan to double the Jewish settler population in the annexed Golan Heights.
Never since the creation of Israel in 1948 has the idea of a “Greater Israel” stretching from the Jordan to the Mediterranean and from the Golan to the Sinai, accompanied by a new mass expulsion of the Palestinian people after the one in 1948, been so openly evoked as it is today, with the support of the new Trump administration.
The destruction in Gaza and the colonization of the West Bank have been brought before two international courts, the ICC and the ICJ, both based in The Hague. But Israel does not recognize the ICC and has not complied with an initial advisory opinion from the ICJ, which in 2004 considered the construction of the Wall to be illegal. The ICJ issued another advisory opinion in July 2024, describing Israel’s presence in the Palestinian territories as illegal, since it amounts to a de facto annexation, inter alia because of its failure to comply with the obligations of an occupying power under international humanitarian law.
Rwanda against the Democratic Republic of Congo
Armed conflict in eastern Democratic Republic of Congo (DRC), more specifically the provinces of North and South Kivu, has been virtually unabated since Rwandan armed forces first invaded in 1996. That attack was at first directly linked to the 1994 genocide of the Tutsis in Rwanda and the presence on the Rwandan border of huge refugee camps controlled by fugitive genocide perpetrators who were carrying out murderous incursions into Rwandan territory.
For three decades, all of north-east DRC has been the scene of violence perpetrated by various armed groups, some of them backed by Rwanda and Uganda. This ongoing crisis conceals the plundering of the region’s many mineral resources (cobalt, coltan, lithium, gold, etc.), which are at the heart of the conflict. Following a new lightning offensive led by the M23, an armed group sponsored by Rwanda, and around 4,000 Rwandan soldiers, the two provinces of North and South Kivu came under the control of the M23 and the Rwandan army in January and February 2025.
Officially, Rwanda has no intention of annexing these territories. For the time being, it is a question of aggression and occupation. But the history of Rwandan territorial ambitions in this region dates back to at least the end of the 19th century. Some members of the Rwandan Patriotic Front, which has been in power in Rwanda since 1994, have long maintained the idea that this territory naturally belongs to Rwanda and would be Rwandan if European settlers had not come there on the eve of the 20th century to establish and freeze the borders that prevail today. Suspicion about Rwanda’s real intentions is therefore long-standing. And the speed with which Rwanda seems to have embraced the new geopolitical era, opened by Trump returning to power and giving a green light to ambitions of territorial conquest, only boosts suspicions about renewed Rwandan expansionism.
The DRC has lodged a complaint with the East African Court of Justice and another with the African Court on Human and Peoples’ Rights. The latter is due to decide soon on its admissibility. In light of the conflict’s escalation and at DRC’s request, the ICC Prosecutor also reopened his investigation into North Kivu in October 2024.
China in the South China Sea
The South China Sea is of major strategic importance for the world and for China: 30% of world trade and 25% of oil transported by sea pass through its waters, which contain considerable resources, including gas and oil. As well as China, Vietnam, the Philippines, Malaysia, Indonesia, Taiwan, Brunei and even Singapore lay claim to part of it. But for the last 15 years or so, China has been extending its hold by building artificial islands and installing naval and air bases, with a succession of faits accomplis and assertions aimed at extending its “exclusive economic zone” by redefining maritime spaces.
This is a special case, notes Sassòli, because the disputed rocky islets have no inhabitants. But the dispute was brought to court by the Philippines, which filed a complaint with the International Tribunal for the Law of the Sea. This court referred the matter to the Permanent Court of Arbitration in The Hague. In 2016, that court ruled that China had violated the Philippines’ sovereign rights over its exclusive economic zone and continental shelf. But Beijing has failed to comply with the ruling.
- Threats of annexation -
The United States against Panama, Greenland and Gaza
In January 2025, Donald Trump’s United States officially joined the ranks of countries intent on taking over new territories. The US President announced his intent to take control of the Panama Canal and the Gaza Strip, removing its Palestinian inhabitants, and to buy Greenland – including by threatening sanctions and financial pressure against Denmark. Greenland is an autonomous territory of the Kingdom of Denmark, which controls its monetary policy, defence and diplomacy.
Neither Panama, nor the people of Greenland, nor the Danish government, nor the Palestinians accept a transition to American sovereignty. The American plan for Gaza, which includes the evacuation of all Palestinians without return, has been positively received only by the Israeli government. As well as being a violation of international law, it would, according to Israeli lawyer Yaël Vias Gvirsman, constitute a “crime against humanity”.
Greenland’s strategic importance has increased in recent years, particularly as the ice melts due to global warming. This promises to open up new trade routes that would cut travel time between East Asia and Europe by almost a third. In addition Greenland, the world’s largest island, has vast reserves of very pure water, large deposits of sand, and a wealth of mineral resources in its subsoil including iron, nickel, gold, uranium and rare metals such as cobalt, which are needed to make mobile phones.
In July 2021, the Greenland Home Rule Government banned oil exploration and production. But “for purposes of national security and freedom throughout the world, the United States of America feels that ownership and control of Greenland is an absolute necessity,” Trump declared on his social network last December.
Finally, Trump also wants Canada to become the 51st state of the US, an idea that Canadians have categorically rejected.
China against Taiwan
The People’s Republic of China considers Taiwan to be its 23rd province by right. “No one can stop the historic trend of the reunification of the motherland,” declared Chinese President Xi Jinping in a speech broadcast by state media on December 31, 2024. The Chinese head of state had already spoken in a January 2019 speech of “reunification” with Taiwan as “a necessity for the great rejuvenation of the Chinese nation in the new era”.
“The whole ambiguity of Taiwan’s situation, from a purely legal point of view, is that Taiwan has never seceded from China but considers that it represents China,” says Sassòli. Beijing claims the island as an integral part of its territory and has never renounced the use of military force to achieve this. In recent years, military pressure has steadily increased. In 2022, China conducted large-scale military exercises around the island. In October 2024, Taiwan claimed to have detected a record 153 Chinese military aircraft in 25 hours: Beijing had organized large-scale exercises described as a “severe warning” against “pro-independence forces in Taiwan”.
In an article published in Politique Internationale in 2019, Matthieu Duchatel, a researcher at Sciences Po, explains that “the ‘anti-secession’ law of March 14, 2005 specifies the circumstances in which China reserves the right to use force: in the event of a declaration of independence; if the conditions likely to lead to a peaceful solution are no longer met; or if a major event causes a definitive separation between Taiwan and the mainland”. The specialist wrote that “if China believes that the United States might not intervene, an offensive against Taiwan becomes possible”.
“Resolving the Taiwan question is a matter for the Chinese people,” said Xi Yinping in a speech at the opening of the 20th Congress of the Chinese Communist Party in October 2022. “We will continue to strive for a peaceful solution with great sincerity, but we will never promise to renounce the use of force, and we reserve the right to resort to all necessary options. The complete reunification of our country must be achieved. It can be, and it undoubtedly will be.”
Azerbaijan against Armenia
In September 2023, Azerbaijan took over the Nagorno-Karabakh region, an enclave 99% inhabited by Armenians, which had already been the scene of two wars in 1988-94 (with a victory for Armenia) and in 2020 (with a victory for Azerbaijan, supported by Turkey). Now an integral part of Azerbaijan, Nagorno-Karabakh has been almost entirely emptied of its Armenian population, which is Christian while the Azeris are predominantly Muslim and Turkish-speaking. The case is complex: according to Sassòli, Azerbaijan could argue that Armenia de facto annexed Nagorno-Karabakh, even though this autonomous territory was part of the Republic of Azerbaijan in the time of the Soviet Union.
But Baku is threatening to annex another large area of Armenian territory: a strip of land in southern Armenia near its border with Iran, separating Azerbaijan from an Azeri enclave in Armenia, Nakhchivan. This situation was a poisoned gift from Stalin at the beginning of the 20th century. The future head of the Soviet empire created this autonomous region in 1921 before allocating it to the Soviet Republic of Azerbaijan in 1923, at the same time as creating an autonomous Armenian region in Nagorno-Karabakh, itself enclosed within Azerbaijan. These two time bombs exploded very quickly after the disintegration of the Soviet Union in 1991.
The strip of land coveted by Azerbaijan is located in the Syunik region, also known as Zangezur. It is Armenia’s most mineral-rich province and accounts for 15% of Armenia’s national territory. The Zangezur Corridor is a proposed transport corridor linking Azerbaijan to the landlocked territory of Nakhchivan, crossing through Armenia without Armenia having any control over it. In an interview with Azerbaijani media on January 7, 2025, Azerbaijani President Ilham Aliev said that Armenians “should not be a geographical barrier between Turkey and Azerbaijan. The Zangezur Corridor must and will be opened. The sooner they understand this, the better”.
Armenia rejects this project as an infringement of its sovereignty.
Venezuela against Guyana
In 2015, the American oil company Exxon Mobil discovered a major offshore oil field off the coast of Essequibo, in the western region of Guyana, which borders Venezuela. Exploitation began four years later. Between 2020 and 2023 production increased fivefold, and five new oil companies set up operations. Reserves are estimated at 11 billion barrels, more than those of Kuwait. By 2020, the country’s growth rate had reached 86%. Essequibo, which accounts for two-thirds of Guyana and is home to one-fifth of its population, is also rich in gold, diamonds, copper, bauxite and iron.
The discovery of this oil bonanza has fuelled the greed of Venezuelan head of state Nicolás Maduro, who has stepped up his military presence on the border since 2018. Essequibo belonged to Venezuela when it gained independence in 1811. Annexed by the British in 1840, the territory came under the sovereignty of Guyana when it gained independence in 1953, which Caracas has always contested.
Traditionally, before Trump’s latest threats on Greenland, old disputes have accompanied all annexations, according to Sassòli. “I don’t know of any case of annexation that doesn’t have an underlying historical dispute,” he says.
Guyana, which has only a very small army compared with its large neighbour, asked the ICJ to settle the dispute. But Venezuela has refused to recognize the court’s jurisdiction. Pressed by Guyana, which was worried about a planned referendum in its neighbouring country, the ICJ in December 2023 ordered Venezuela to “refrain from any action that would alter the status quo in the Essequibo”. But Maduro continued to organize his referendum on the attachment of Essequibo to Venezuela under the slogan “El Esequibo es nuestro” (Essequibo is ours). The referendum was 95% in favour. The following day, Guyana reported an incursion into its territory by 200 members of Venezuelan special forces disguised as civilians in order to organize sabotage. Venezuela also ordered the granting of licences to its own national oil company to exploit oil in Essequibo, thus “appearing to annex the territory de facto”, history and geography professor Patrick Blancodini said in the magazine GéoConfluences. In March 2024, Maduro took another step. A law was unanimously approved by the Venezuelan National Assembly, designating the territory of Essequibo as a new state of Venezuela.
