Martin Ryan in Azerbaijan, Laurent Vinatier in Russia, Cécile Kohler and Jacques Paris in Iran, Michael Kovrig and Michael Spavor in China… This list of Westerners arrested on spurious pretexts in authoritarian countries, held for lengthy periods and eventually released in exchange for various concessions, is far from exhaustive. While French journalist Christophe Gleizes remains imprisoned in Algeria for “apologia for terrorism,” against a backdrop of tensions between Algiers and Paris, the author of this article puts forward a number of ways in which democracies could better resist such blackmail.

For several decades now, the arrest and subsequent negotiated release of Western nationals on fanciful charges, following sham judicial proceedings and “magnanimous” pardons, has been part of the repertoire of a number of authoritarian states. The phenomenon, known since the late 1960s, accelerated from the 2010s onwards. Through its frequency, “hostage diplomacy” has become a fully fledged dimension of international relations, forcing governments to renounce their principles in order to save citizens for whom they are responsible. On one side, an undemocratic state arrests a foreign national and uses him or her as leverage in pursuit of strategic objectives; on the other, a democratic state works behind the scenes, through concessions and ransoms negotiated in the shadows, to bring that person home.

Faced with a “rogue state,” one must therefore negotiate—and negotiating means giving way, since whatever one agrees to give, however little, will have been extorted. It is important to take the measure of this phenomenon, which is beginning to attract the attention of researchers (1). Why are democracies becoming the almost institutional victims of these practices? And what means do they have at their disposal to deal with them?

Big Players and Small Players

The Hostage, from Political Guarantee to Diplomatic Leverage

Alongside alliances, peace treaties and oaths of allegiance, hostage-taking has been part of international-relations practice since the earliest antiquity. For centuries, the hostage represented a legitimate political guarantee. The Roman and Chinese empires did not hesitate to keep the sons of tributary princes at their courts as a pledge of loyalty and a vehicle for civilisation.

Modern international law and the codification of state norms gradually shifted hostage-taking into illegality; with the Geneva Conventions defining hostage-taking as a war crime, yesterday’s diplomatic act became a criminal one (2).

This legal downgrading has reshaped the phenomenon: certain authoritarian regimes have resorted to a new “hostage diplomacy” that defies the international order under the cover of domestic legality. Indeed, no international body can have jurisdiction before domestic remedies have been exhausted before domestic courts—most often sham courts—serving the foreign policy of the hostage-taking state (3).

China, Iran, Russia: Experts in the Field

Although China has a broad range of coercive instruments—trade restrictions, investment boycotts, pressure on investments, exit bans, and so on—the arbitrary detention of foreign nationals is often, for the People’s Republic, one of the most effective means. As early as 1967, in response to the arrest in Hong Kong of one of its subversion agents, it detained the Reuters correspondent in Beijing (4), inaugurating a logic of reciprocity that has affected Washington’s closest allies—Canada, Australia and the United Kingdom—in order to undermine the credibility of the United States in Asia (5). The so-called “two Michaels” case is the most recent illustration: in 2018, the arrest in Vancouver of Meng Wanzhou, Huawei’s chief financial officer, as part of a US extradition request, triggered within days the detention in China of two Canadian nationals, Michael Kovrig and Michael Spavor, officially charged with espionage. Held for more than 1,000 days, sometimes in solitary confinement and without regular access to consular or legal assistance, the two men were released only in 2021, just hours after Meng Wanzhou reached a deferred-prosecution agreement with US justice authorities. The simultaneity of the releases was explicit; the Chinese strategy was clear: never separate individual detention from the broader political objective, and signal to third countries the cost of aligning themselves with the United States.

Iran excels at this game. Since the founding crisis of the US embassy in Tehran in 1979, during which 52 diplomats were held for 454 days before being released in exchange for the unfreezing of several billion dollars in Iranian assets, the Islamic Republic has progressively elevated the instrumentalisation of foreign nationals’ detention into a state doctrine. The mechanism follows a well-established operational logic: prioritising dual nationals with Western citizenship; espionage or national-security charges brought in the opacity of revolutionary courts; followed by negotiated exchanges of these innocent people for Iranian offenders held abroad, sanctions relief, the abandonment of pressure over the nuclear issue, and the unfreezing of funds. The arrests coincide strategically with moments of maximum tension in international negotiations.

Since 1979, with nearly one hundred detainees held in this context, Iran has become the world’s leading jailer of US nationals. Five Iranian-American dual nationals—including the former head of the Washington Post’s Tehran bureau, Jason Rezaian—were released in 2016 in return for the signing of the Joint Comprehensive Plan of Action (JCPOA) (6). The same logic prevailed in 2023, when five Americans were released in exchange for five Iranians, together with the transfer to a Qatari account of six billion dollars in Iranian oil funds frozen in South Korea. Sometimes the detainee disappears, as in the case of Robert Levinson, a former FBI agent detained in 2007 whose death in detention was officially concluded by Washington in 2020.

Europe has not been spared. French student Clotilde Reiss, arrested in July 2009, was released the following year in exchange for an Iranian imprisoned in Paris. In 2022, British-Iranian national Nazanin Zaghari-Ratcliffe, detained for six years, was released only after the United Kingdom settled a historic £400 million military debt contracted under the Shah. That same year, Iran arrested Belgian aid worker Olivier Vandecasteele in order to trade him in 2023 for Iranian diplomat Asadollah Asadi, sentenced to twenty years in prison for terrorism. Two Swedes, detained since April 2022 and November 2023, one of them a member of the European Union diplomatic service, were released in 2024 in exchange for Hamid Nouri, a former senior Iranian prison official serving a life sentence in Sweden for his role in the mass executions of 1988. After Fariba Adelkhah, French nationals Cécile Kohler and Jacques Paris, arrested in 2022, were released in 2026 in exchange for an Iranian woman convicted in France of “online incitement to terrorism.” In 2026, the One Free Press Coalition designated, on World Press Freedom Day, the case of Reza Valizadeh (7), a former Radio Farda journalist, as the most urgent in the world…

Russia, for its part, has adopted a hostage diplomacy that is more a matter of tactical opportunism and a taste for spectacle, with highly visible negotiated exchanges turning the release of its nationals into a demonstration of power. In 2019, it imprisoned an American tourist, Trevor Reed, to exchange him for a Russian drug trafficker held in the United States. In 2022, a few days after the invasion of Ukraine, American basketball star Brittney Griner was sentenced to nine years in a penal colony for possession of vape cartridges containing cannabis for medical use. Moscow had a valuable card: the detainee’s media profile, which mobilised US public opinion, offered an ideal lever for securing the release of Viktor Bout, a Russian arms trafficker sentenced to 25 years in prison in the United States. The exchange, staged on the tarmac in Abu Dhabi in December, marked a Russian success (8). The exclusion from the agreement of former Marine Paul Whelan, also detained in Russia, demonstrates the calculated precision with which this state values its hostages as assets to be traded. Emboldened by this success, Russia secured in 2024 the largest prisoner exchange with members of the G7 since the Cold War (9).

The Laurent Vinatier case reveals another facet of this strategy: the use of detention as an instrument of pressure in bilateral relations in times of crisis. The French researcher was arrested in Moscow in 2024 and sentenced to three years in prison under Russian legislation on “foreign agents.” The escalation of the charges against him in 2025—he was charged with espionage, a crime punishable by twenty years’ imprisonment—came amid frozen Franco-Russian relations. His release, obtained after 589 days in detention by presidential pardon, in exchange for a Russian basketball player detained in France for involvement in a hacker network, confirms the superiority in this field of a Russian power that alone sets the timetable and the price.

A Growing Phenomenon

Hostage diplomacy is by no means the preserve of first- or second-tier powers. Actors with more limited capabilities and ambitions have incorporated it into their arsenal. In 1990, Saddam Hussein detained foreign journalists to deter the UN coalition from striking his installations. North Korea has for decades detained tourists, students and foreign nationals on fanciful pretexts, sometimes with the aim of obtaining political concessions, sometimes to use them as human shields in the event of possible US intervention—we remember the tragic case of American student Otto Warmbier, arrested and imprisoned in Pyongyang in 2015 and who died in 2017, shortly after being released in a coma. Turkey has used the same methods, notably with the imprisonment in 2016 of American pastor Andrew Brunson over his alleged links to the Kurdistan Workers’ Party (PKK) and the Gülen movement, in order to secure the extradition of Fethullah Gülen, a US-based arch-enemy of President Erdoğan. In 2022, Venezuela negotiated the release of two nephews of Nicolás Maduro, convicted in the United States of drug trafficking, in exchange for seven US executives from the CITGO refinery imprisoned in Caracas.

Algeria has embraced hostage diplomacy enthusiastically. The arrest in 2024 of Franco-Algerian writer Boualem Sansal, followed by his conviction to five years in prison for “undermining national unity,” is evidence of this. His release after a year, by presidential pardon granted under German diplomatic pressure, represented for France a humiliation at least equal to that of his “capture.” The case of French sports journalist Christophe Gleizes, arrested in Kabylia in 2024, follows the same logic… which extends to Burkina Faso, where four French DGSE agents were arrested upon their arrival in Ouagadougou in December 2023, and to Mali, where French Lieutenant-Colonel Yann Vézilier was arrested and sentenced to twenty years in prison for attempting to “destabilise the institutions of the Republic.” In Azerbaijan, French businessman Martin Ryan, imprisoned in 2023 for espionage, was pardoned in 2026 in exchange for France securing from the European Union the lifting of sanctions against Russian oligarch Alisher Usmanov. It should be added that the Gulf monarchies, apparently allies of Western democracies, are not reluctant to play the same game (10).

It should be noted that liberal democracies are not entirely immune to the temptation, even if they target private actors. In 2013, Frédéric Pierucci, a senior executive at Alstom, was arrested by the FBI upon arrival at JFK Airport and then imprisoned for fourteen months in a high-security US prison, cut off from his family and employer, as part of proceedings based on the Foreign Corrupt Practices Act, legislation establishing a principle of extraterritoriality, designed to combat corruption of public officials committed by individuals or companies, American or otherwise, that are established in the United States, listed on a stock exchange there, or participate in a regulated financial market in the country. The aim is to protect market transparency and ensure that US companies are not treated unfairly. The pressure exerted on Alstom in this case led to a $772 million fine, which the company paid, and ultimately to General Electric’s acquisition of the group’s energy division. The protagonist himself denounced the strategic coherence of this sequence of events in memoirs that became an international bestseller, including in the United States, but also in China and Russia, where it helped highlight the “bad faith” of the West (11).

It will be understood: the boundary between the legitimate use of law and its instrumentalisation for strategic purposes is, even in a democracy, less impenetrable than one might wish to believe.

Why Democracies Are Vulnerable

The United Nations Charter, adopted in 1945, prohibits the use of force between states, and the 1961 Vienna Convention on Diplomatic Relations enshrines the inviolability of diplomats.

Democracies are thus deprived of the classic instrument of armed retaliation, since the disappearance of the casus belli has stripped diplomatic law here of its binding force. Consequently, a state victim of hostage diplomacy must confine itself to economic sanctions, the expulsion of diplomats and recourse to the International Court of Justice. Democracies are disarmed because they cannot apply the law of retaliation by arbitrarily arresting nationals of the rogue hostage-taking state. Two categories of states can thus place themselves outside the law at relatively little cost: the most powerful, whose political weight shields them from any effective sanction; and those that choose their victims among states whose cowardice is taken for granted or whose capacity to respond is perceived as structurally limited (hence the number of French hostages). Authoritarian powers therefore have an ever-growing interest in resorting to hostage diplomacy against Western democracies from which they do not expect military retaliation (12).

A state taking hostages does not merely commit an act of diplomatic coercion: it triggers, in the captives’ home country, an emotional and political dynamic that has powerful effects on government decision-making. These effects operate at three levels.

The first is that of families and public opinion. Relatives of detainees, supported by the media and social networks, exert growing pressure on governments to secure their release. This mobilisation, legitimate from a human standpoint, can rapidly become political pressure: opposition parties seize upon it and governments are pressed to act.

The second level is precisely that of political power. The longer the detention lasts, the greater the political cost of inaction becomes for the government concerned. The hostage then becomes a subject of public debate, or even an instrument with which the opposition can challenge government policy, all too happy to seize upon a humanitarian cause (13).

The third is that of the strategy of the hostage-taking state, which can exploit these tensions to its advantage. By maintaining the detention, it increases the pressure exerted on its adversary and can seek to divide its public opinion, test its resolve or obtain concessions. Detention thus becomes a form of “weaponisation of emotions”: the adversary turns a human situation into political leverage (14).

This mechanism explains why time rarely works in favour of the democratic state. Each additional day strengthens the mobilisation of relatives, increases political pressure and can allow the adversary to consolidate its position. For humanitarian reasons as much as to avoid this spiral, rapid action should therefore remain an absolute priority, which unfortunately is rarely the case.

What Should Be Done, and How?

How can this slowness be explained? Probably by the fact that states that must respond to the arbitrary detention of their nationals have only a limited number of options and go over them again each time there is a “hostage-taking.”

Beyond practical preventive measures such as travel advice and raising awareness among companies, the first political response of democracies is to return to the texts. Hence the proposal by many legal scholars to impose on states a universal obligation to protect their nationals, including dual nationals, regardless of the rule requiring the exhaustion of domestic remedies. Some advocate compulsory arbitration and recourse as a last resort to the International Court of Justice (15)—an option rejected by several states (including Algeria, China, Iran, Turkey and Venezuela) as soon as it was included in the 1979 International Convention against the Taking of Hostages (16).

Another avenue is to broaden the negotiating space beyond the strictly bilateral framework. Victim states could coordinate their positions more closely, share information and involve third parties capable of putting pressure on the hostage-taking state. In the case of the “two Michaels,” for example, US involvement in negotiations with China helped unlock the situation. Canada attempted to move in this direction with its Declaration Against Arbitrary Detention in State-to-State Relations, published in 2021 with the support of 58 signatory states (17). The initiative is intended in particular to strengthen cooperation between states confronted with this phenomenon and enable them to coordinate their responses more effectively. Its supporters argue that the scope of such a text depends less on its content than on the cohesion of the coalition defending it and the symbolic costs imposed on the states concerned. This may be doubted: it remains devoid of any binding mechanism, and its effectiveness depends on the willingness of signatory states to stand together. China simply dismissed the initiative as interference in its internal affairs without changing its treatment of its prisoners, dismissing the supposed declaratory effectiveness of the exercise.

Nevertheless, middle powers with limited bilateral coercive resources when facing major authoritarian powers would make better use of multilateralism if it were “activated” in such difficult moments. The release of seventy-year-old Israeli-Argentine Yaakov Harari, after 496 days in detention in a Venezuelan prison where he languished under accusations of “mercenarism,” was thus secured through an international diplomatic effort coordinated by the Mossad involving the United States, Germany, Austria and Italy as part of a broader framework of detainee releases (18).

Hence the value of systematising the use of the resources available to the state whose nationals are victims. This is the second idea put forward by the Canadians in their “Partnership Action Plan” in order to turn their “Declaration” into action. It calls for mobilising a broad range of actors—civil society, academia, think tanks and legal experts—to strengthen strategic cooperation and global awareness, notably through targeted campaigns in traditional and social media (19). Systematically pooling the experiences of victim states—individual, diplomatic and legal experience concerning the methods of arbitrary detention and release strategies—is a necessary but insufficient condition for collective action.

Indeed, if a declaration is often merely a futile gesture, only action itself would have meaning. Yet democratic states have no common doctrine capable of being translated into diplomatic measures. Apart from certain studies conducted within intelligence services—occasional and confidential—this issue is not the subject of public reports. This discretion is partly structural: the management of such crises falls within the executive’s prerogatives, in a field where publicising deliberations can undermine the effectiveness of action. Intelligence services and specialised consular units remain executors whose actions, however competent, do not fit into a shared framework. The result is that each case is handled ad hoc, in an emergency, or even in panic, with the inevitable risks of improvisation, producing partial responses and ultimately prolonging the victims’ ordeal.

Negotiate or Apply Pressure?

Some specialists (20) also propose incorporating related issues into negotiations, so as to create value for both parties and move beyond the deadlocks associated with the zero-sum logic of hostage exchanges. The American experience with Cuba illustrates this three-pronged approach: the release of USAID contractor Alan Gross in 2014 resulted from a negotiation—in which Canada and the Vatican played a crucial role as neutral intermediaries motivated solely by humanitarian concerns—combined with spy exchanges. The parties were so satisfied with the outcome that in 2015 Washington and Havana restored diplomatic relations. Similarly, the release of Canadian couple the Garratts, arrested in China that same year, was included in the conditions for opening trade negotiations between the two countries.

The idea put forward by these negotiation professionals is to step away from direct confrontation and enter the framework of reasoned negotiation. This approach may nevertheless appear questionable insofar as it rests on acceptance of a disguised capitulation. Conversely, one might argue that it is better to accept confrontation but conduct it through a strategy that takes into account the adversary’s concerns about prestige, reciprocity or sovereignty, rather than only one’s own. Provided one gives oneself the means to prevail.

Thus, when in 2016 Turkey charged American pastor Andrew Brunson and proposed exchanging him for Fethullah Gülen, Recep Tayyip Erdoğan’s arch-enemy living in the United States, Washington did not merely reject the proposal, but froze the assets of the Turkish interior and justice ministers and increased tariffs on Turkish steel and aluminium to the point of causing a sharp fall in the Turkish lira. The pastor was then transferred to house arrest for health reasons, found guilty of supporting terrorist organisations and sentenced to three years and one month in prison—for the sake of saving face—and immediately released on the grounds of time already served and good behaviour.

The United States offers a benchmark model on several fronts: an established doctrine, revised procedures, coercive power, substantial investment in consular procedures… But this model has a limitation that Europeans would be wrong to ignore: the United States is also a participant in the dynamics it claims to correct. The extraterritorial use of US law in the Pierucci case and the pressure exerted on Canada in the two Michaels case remind us that coercive power, even when democratic, can itself become an instrument exercised to the detriment of allies. This does not invalidate the American model; it means that middle powers can neither reproduce it on their own scale nor submit to it without discernment. They need an architecture of their own.

Such an architecture exists in embryonic form with the 2021 Declaration and the Partnership Action Plan. If a multilateral response should probably be institutionalised (21), it is also necessary to determine what framework to give it and what content to prepare. As for the UN, it has certainly taken up the issue through the report of Special Rapporteur Alice Jill Edwards on torture and other cruel, inhuman or degrading treatment or punishment (22) and the creation of the Working Group on Arbitrary Detention (23), but there is little to be expected from an organisation slowly turning into a club of dictatorships and whose own employees participate in hostage-taking, as was the case in Gaza…

The G7 is probably the most realistic framework. Homogeneous in terms of values and endowed with proven economic coordination capacity, it can avoid the paralysis of the UN and the constraints of a transatlantic alliance that operates only by consensus and of which Turkey is a member. The objective would be to establish a commitment modelled on “Article 5 of NATO” applied to hostage diplomacy: any arbitrary detention of a national of a member state would automatically trigger, according to a pre-established scale, targeted sanctions against identified individuals responsible—police officers, judges, diplomats, political decision-makers—as well as retaliatory measures in the economic, financial and diplomatic spheres. Automaticity is decisive here: as with any blackmail, the more one gives in, the more one will give in. The only way forward is to make the cost of hostage-taking structurally greater than its benefits, in a mechanical and predictable manner, so that compassion cannot jam the sanctions machine on the grounds that the prisoners might suffer more as a result.

This ambition requires preparatory work that European democracies neglect. Potential targets among their own nationals must be mapped, and the economic, diplomatic and “reputational” weaknesses of states likely to detain them identified; a communications protocol must be developed, in consultation with families, that involves them in the need for discretion without excluding them from decisions that concern them; and, within each government, officials must be designated to coordinate the response with their allied counterparts—not in an emergency, but before the crisis. Yet, on the European Union side, there remains a preference for invoking grand principles rather than patiently building the means to defend them. And who in Brussels would want to fall out with China in order to help its European neighbour? Some forms of altruism are nevertheless investments: saving a European neighbour’s hostage today means signalling to the hostage-taking state that targeting one member of the coalition amounts to targeting all its members. Solidarity, if credible, is also a form of deterrence.

In Conclusion…

Hostage diplomacy is not a marginal or temporary phenomenon; it is a revealing sign of a profound transformation in the international order, in which the individual has become a bargaining chip through low-cost destabilisation strategies. Democracies’ attachment to human life, their submission to public opinion, and their devotion to an international law that their adversaries respect only selectively are all virtues transformed into vulnerabilities by states that have understood that the price of a hostage is inversely proportional to the ability of his or her government to respond. Hostage diplomacy reveals less the brutality of hostage-takers than the disorientation of democracies trapped in a moribund international legal order in a world they have ceased to shape.

They still possess instruments—economic sanctions, diplomatic pressure, multilateral coordination—but are reluctant to use them with the consistency and predictability that would give them deterrent value. Yet firmness pays, and the dozens of unresolved cases or cases settled through capitulation show the cost of its absence. The choice is not between negotiation and confrontation, but between a prepared, collective and methodical confrontation and a capitulation disguised as “creative diplomacy.”

The proposal for an automatic response mechanism is not a utopia. It is the minimum that the situation requires. Major transnational corporations would be well advised to push democratic governments in this direction: to finally agree to treat hostage diplomacy not as a succession of consular crises but as a permanent front in the competition between political and economic systems. Until they do so, democracies will continue to pay, in concessions, ransoms and humiliations, the price of a naivety they can no longer afford.