OBSERVARE
Universidade Autónoma de Lisboa
e-ISSN: 1647-7251
Vol. 8, Nº. 2 (November 2017-April 2018), pp. 70-87
PROMOTION OF LGBTI RIGHTS OVERSEAS: AN OVERVIEW OF EU AND US
EXPERIENCES
Artem Patalakh
artem.patalakh@unimi.it
PhD candidate in Political Studies at Università degli Studi di Milano (Milan, Italy). His research
interests include International Relations theory, Russian and EU foreign policies, soft power,
promotion of ideas of values in International Relations. He holds BA and MA degrees in Regional
Studies from MGIMO-University (Moscow, Russia)
Abstract
The essay problematizes the incorporation of LGBTI rights promotion into the US and EU
foreign policies. First, the paper examines the two actors’ key documents, speeches, and
policies devoted to the promotion of LGBTI rights abroad, the similarities and differences
between the two actors’ approaches, attending to the tendencies of their evolution and the
ongoing development. Second, the article discusses the internal conditions in target countries
that are conducive to the success and failure of international support of LGBTI rights. Finally,
the study makes a critical overview of the measures that are argued to be necessary to
increase the efficiency of LGBTI rights promotion in countries with most negative current
trends in and/or poorest records on LGBTI rights.
Key Words
EU foreign policy, human rights promotion, homonationalism, homophobia, LGBTI rights,
same-sex marriage, US foreign policy.
How to cite this article
Patalakh, Artem (2017). "Promotion of LGBTI Rights Overseas: An Overview of EU and US
Experiences". JANUS.NET e-journal of International Relations, Vol. 8, Nº. 2, November 2017-
April 2018. Consulted [online] on the date of last consultation, DOI:
https://doi.org/10.26619/1647-7251.8.2.6
Article received on February 29, 2016 and accepted for publication on May 7, 2017
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Promotion of LGBTI rights overseas: an overview of EU and us experiences
Artem Patalakh
71
PROMOTION OF LGBTI RIGHTS OVERSEAS: AN OVERVIEW OF EU AND US
EXPERIENCES
1
Artem Patalakh
Introduction
2
“The Obama Administration defends the human rights of LGBTI people as
part of our comprehensive human rights policy and as a priority of our
foreign policy”.
Hillary Clinton, US Secretary of State, June 12, 2011.
“Through dialogues with third countries, our work in multilateral fora, public
statements, and through our support to civil society, the EU will continue to
advocate measures to combat discrimination and violence against LGBTI
persons, and to actively promote their rights”.
Federica Mogherini, EU High Representative for Foreign Affairs and Security
Policy, May 17, 2015.
If one took a retrospective look at human rights progress in the last 20-30 years, they
would probably conclude that it is LGBTI rights that have been developing most
dynamically. It would not even be an overstatement to argue that nowadays a country’s
“progressiveness” is, in a sense, determined by its government’s attitude to LGBTI
people, the degree of the recognition of their rights
3
, and the level of homophobia in
everyday life. Analogously to the 20
th
century’s battles for women’s and black people’s
rights, LGBTI rights presently are at the front line of human rights debates; their
standards vary dramatically from country to country, ranging from legalised same-sex
marriages to death penalty for homosexuality.
A number of Western countries have incorporated the promotion of LGBTI rights into
their foreign policy strategies. Among such “activists” are Australia, Brazil, Canada etc.;
however, as evident from the above-cited quotes, the two main actors having established
policies in this field are the US and the EU. Of note, certain peculiarities of LGBTI rights
make their international furtherance harder than other human rights. To name but a few,
1
Text reviewed by Carolina Peralta.
2
I am grateful to David Kharebov, Vanessa Melching, and two anonymous reviewers for their insightful
feedbacks on earlier versions of this article.
3
This phenomenon, commonly referred to as “homonationalism”, is conceptualized as “a facet of modernity
and a historical shift marked by the entrance of (some) homosexual bodies as worthy of protection by
nation-states, a constitutive and fundamental reorientation of the relationship between the state,
capitalism, and sexuality” (Puar 2013: 337).
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the very idea of LGBTI rights is so fervently contested and encounters such a bitter
hostility in certain parts of the world that their propagation requires an especially high
degree of caution and determination. Besides, as opposed to other minorities’ rights,
LGBTI rights protection does not directly rest on any universal legal documents, which
gives their opponents a particularly strong argument for challenging their universality,
allowing them to blame the West for imposing its own values on culturally divergent
societies.
Unfortunately, the existent academic literature comparing EU and US human rights
promotion (e.g. Wouters et. al. 2014, Heras 2015) tends to overlook such peculiarities.
In attempt to fill this gap, this essay makes a survey of the EU and US experience of
supporting LGBTI rights abroad. Aside from recent academic literature on international
LGBTI rights promotion, this study largely rests on non-academic articles, experts’
interviews, news agencies reports as well as documents and politicians’ statements. The
first part focuses on the distinctive features of the EU and US approaches in terms of
their forms, methods, and legal frameworks. The second chapter discusses conditions in
the target states which are propitious and, contrariwise, detrimental to international
furtherance of LGBTI rights. The third part elaborates on possible ways to promote LGBTI
rights in countries with the poorest record on and/or most negative ongoing trends in
LGBTI rights.
EU and US Strategies: A Comparative Analysis
As stated above, human rights and democracy promotion in general is at the core of the
EU and US foreign policies, with hardly any foreign policy speech of their officials not
mentioning it. Nevertheless, there are features making the two actors distinct from each
other; those features originate from the roles they play in the international system, their
foreign policy decision making processes as well as differences in their historical
development. At the level of the fundamental legal base for human rights support, an
apparent distinction between them is that the EU is obliged to promote human rights
abroad by its founding document, the Treaty on European Union (Consolidated Version
2012: articles 3 (5), 21 (1) and 21 (3)). For the US, human rights promotion is a matter
of image rather than obligation: since its foundation, the US has positioned itself as “the
land of the free”, with the promotion of freedom and democracy in its external and
internal policies running through US politicians’ rhetoric. The external component got a
special significance after the Second World War and especially the signing of the 1975
Helsinki Act, when the universality of democracy and human rights was accepted as a
fundamental standard of international conduct (Osiatyński 2013: 17-18). It provided a
favorable environment for the US to portray its value-based foreign policy aims as
protecting a universal order rather than its self-interests.
Moreover, the two actors have historically prioritized diverse aspects of promotion of
values: while the US approach has focused on democracy, political parties, elections, and
free media, the EU has paid more attention to socio-economic development, education,
and NGOs. Otherwise stated, the EU has primarily emphasized human rights, whereas
the US has mainly concentrated on democracy (Haras 2015). This difference seemingly
reflects the two actors’ strengths and weaknesses, particularly the fact that the US is
deemed politically stronger than the EU: promoting democracy generally requires
capability to exert pressure on elites, while furthering human rights mostly presupposes
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73
supporting NGOs and bottom-up initiatives. Remarkably, the two approaches have drawn
together in recent years. On the one hand, Obama separated democracy promotion from
his predecessor’s “war on terror” and connected it to development and human rights.
Concurrently, the EU established European Endowment for Democracy which operates
much more politically than the bloc’s traditional instruments, bearing certain resemblance
with the US National Endowment for Democracy known for considerably politicized
activities (ibid).
Concerning the basic principles for the promotion of specifically LGBTI rights, both the
EU and the US proceed from their universality and impossibility to use rhetoric of
traditional values and national culture to disguise their violations (US Department of
State 2011, Council of the EU 2013). Tellingly, both actors have been gradually extending
the areas and deepening the activities in this sphere. First, they have included
intersexuals in the policies that previously aimed solely at LGBT people
4
. Additionally,
they have progressively increased the number of gay ambassadors: the US, for example,
after appointing the first openly gay ambassador in 1999, gradually continued this
practice, to have, as of August 2016, six gay ambassadors
5
(Bier 2017). Finally, the two
actors have expanded their activities from a purely legal area to social life in a wider
sense, from promoting LGBTI rights in particular to fighting against homophobia in
general. To exemplify, unlike the 2010 analogous document, the EU’s current key
document on LGBTI protection abroad, “Guidelines to Promote and Protect the Enjoyment
of All Human Rights by Lesbian, Gay, Bisexual, Transgender and Intersex (LGBTI)
Persons”, mentions combating LGBTI-phobic violence as one of the priority areas of
action (see Council of the EU 2010, 2013).
Both actors clearly exhibit a trend toward universalizing legal recognition of same-sex
relationships in the foreseeable future, be it in the form of a union or marriage. In Europe,
for example, the 2015 European Court on Human Rights’ ruling obliging Italy to legalize
same-sex unions may become a precedent for other member states of the Council of
Europe (Delman 2015), which the EU may use as an argument in its foreign policy.
Several European politicians have already announced intentions to “export” same-sex
marriages abroad (among them is UK ex-Prime Minister David Cameron, see Hope 2013),
or at least urge every EU member state to legalize same-sex marriage (among them is
the vice-president of the European Commission Frans Timmermans, see Timmermans
2015). However, the former seems wishful thinking, for it appears too early to promote
universality of same-sex marriages while this issue is still being hotly debated inside the
EU and the US. It gives their opponents a valid argument to blame them for double
standards, which eventually weakens both actors’ norm-promoting capabilities.
Moreover, EU/US leaders seem to underrate the limits of foreign policy for human rights
promotion in general, forgetting that norms promotion has little chances to succeed in
the absence of adequate rewards and/or corresponding internalized values of the target
countries’ governments and populations (e.g. see Schimmelfennig and Sedelmeier 2005:
10-25). In this light, statements like Hillary Clinton’s electoral promise to totally eradicate
4
To verify this, one can compare earlier and later documents and speeches on the same issue, e.g. Council
of European Union (2010) and (2013), US Department of State (2014) and (2016) etc.
5
Yet, President Trump later dismissed five out of those six ambassadors (Duffy 2017) so that as of June
2017, the US had only one openly gay ambassador, namely Ted Osius in Vietnam; however, Trump
promised to nominate open gay Richard Grenell to be the US ambassador to NATO (Butterworth 2017).
Incidentally, in June 2014, the then State Secretary John Kerry announced intentions to appoint also lesbian,
bisexual and transgender ambassadors; nonetheless, those plans remained unaccomplished (Bier 2017).
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74
LGBTI discrimination abroad (Brydum 2015) could be considered a way to attract voters
rather than genuinely achievable intentions.
Both powers tend to approach LGBTI rights in geopolitical terms, sometimes trading
LGBTI issues for more important strategic interests, which, some believe, poses one more
expression of double standards. To illustrate, in 2014, the US strongly condemned
Uganda and Gambia for adopting anti-LGBTI laws, simultaneously expressing much
softer criticism of Middle Eastern states - Iran, Iraq, Saudi Arabia, Qatar, the UAE, Yemen
- arguably due to its strategic interests in that region related to oil and counter-terrorism
(Peale 2015). The EU is also blamed for a realpolitik approach to LGBTI rights, tending
to sacrifice them to achieve geopolitical ends. For instance, the bloc arguably shut its
eyes to Ukraine’s record on LGBTI rights in order to move the country to its side in its
confrontation with Russia (Kozlowska 2014); the EU also conceded to Macedonian
conservatives by dropping anti-discrimination against LGBTI out of the list of
requirements for visa liberalization (Slootmaekers and Touquet 2016: 33-34).
Furthermore, like the US, the EU is frequently blamed for homonationalism, using LGBTI
rhetoric to advance its reputation rather than genuinely improve the life of LGBTI people.
For example, one study on the Europeanization of Kosovo concludes that
[t]he EU does not really seem to be concerned about the rights of
the LGBT communities... rather, it is concerned about policing the
symbolic borders of the space of the EU, and utilizing its power (i.e.,
its rhetoric on democracy and rule of law) to construct and maintain
an image of Europe as multicultural, tolerant, and secular (Rexhepo
2016: 49).
Generally, it appears reasonable that certain interests may be sacrificed to prevent more
serious problems, especially under extreme conditions: to illustrate, few would blame the
US and the UK for cooperation with the totalitarian Soviet Union during the Second World
War. However, without such extreme conditions, a realpolitik approach to human rights
tends to reduce the West’s credibility in the eyes of minorities and activists in target
countries (e.g. Euractiv 2008).
A clear difference between two actors’ approaches concerns their evolution and
continuity. The US approach appears to be rather substantially contingent on each
President’s personal views. During the Bush presidency, US LGBTI-related activities
abroad mainly focused on combating HIV rather than struggling for tolerance (Bromley
2007). Obama’s presidency, contrariwise, was characterized by an important role of
LGBTI rights in foreign policy: Obama significantly increased his support to overseas
NGOs promoting LGBTI rights (Romanovski 2015) and was the first leader in the world
to appoint a special envoy on LGBTI rights abroad, Randy Berry, in April 2015. Albeit the
envoy’s activities are scarcely noticeable - his interviews show that he mostly represents
the US on LGBTI issues rather than takes concrete actions (US Embassy in Kosovo 2015,
DeBarros 2016) - the very fact that the State Department has a special person dealing
specifically with LGBTI protection overseas is a serious step of Obama’s foreign policy
that even the EU has yet to take. Yet, Obama’s LGBTI rights promotion encountered
criticism for gaps between word and deed: one study found that while Obama’s 2011
memorandum clearly linked US foreign aid allocation to LGBTI rights practices in recipient
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countries (see Obama 2011), the US did not decrease its foreign aid to Uganda and
Nigeria in 2011-2014 despite that they had significantly toughened anti-LGBTI laws
(Comstock 2016). It remains to be seen what Trump’s Presidency will bring for LGBTI
rights’ international promotion, but the first months of his presidency appear less
conservative than most had presumed: despite that his cabinet largely consists of LGBTI
opposers (see Morse 2016) and he has fired most gay ambassadors appointed by Obama,
he has unexpectedly kept Randy Berry on his post and promised to nominate an open
gay Richard Grenell to be the US ambassador to NATO (Butterworth 2017).
Against the US backdrop, the EU approach seems more systematic and less exposed to
subjective changes. In particular, it does not appear significantly affected by the
presiding state in the Council of the EU or the personality of the High Representative for
Foreign Affairs and Security Policy. To illustrate, the above-mentioned “Guidelines to
Promote and Protect the Enjoyment of All Human Rights by Lesbian, Gay, Bisexual,
Transgender and Intersex (LGBTI) Persons” were adopted in June 2013 during the
presidency of Ireland. Any succeeding presiding states, even relatively conservative
Lithuania or Latvia, although did not initiate any improvements on LGBTI rights, did not
try to annul the “Guidelines” either. Two factors seem to contribute to this discrepancy
between the two actors. First, a US system conferring wide powers to President is
generally conducive to personalization of power (see Linz 1990), whereas collective
decision-making in the European Council makes its President a figurehead rather than a
real leader. Second, unlike US presidents elected for a four-year term, EU member states
preside over the Council of the EU just for six months which is apparently insufficient to
make substantial changes.
Another factors influencing the two actors’ LGBTI rights promotion policies regard their
positions in the IR system: the US more closely resembles a global power having interests
across the globe, whereas the EU is mostly concerned with its neighbourhood. To
exemplify, while the US keeps track of and issues annual reports on human rights
practices around the world, the EU does so only in its candidate countries. The contents
of their reports’ sections devoted to LGBTI rights are also dissimilar: while the US tries
to describe all the cases of discrimination on the ground of sexual orientation and gender
identity found in the news and NGOs’ reports, EU reports are mostly made of general
phrases as well as recommendations to national governments (for comparison, see US
Department of State 2014: 35-36 and European Commission 2015a: 20, 23, 25). In
fairness to the EU, while it does not conduct any full-scale monitoring of LGBTI rights
observance beyond Europe, however, to improve such monitoring inside Europe, the bloc
cooperates with regional organizations, such as ILGA-Europe, an NGO which issues
detailed annual reports on the situation with LGBTI rights (e.g. ILGA-Europe 2016), and
the Council of Europe’s European Commission against Racism and Intolerance, whose
quadrennial country reports on racism in intolerance in the member states of the Council
of Europe have included LGBTI rights since 2015 (e.g. ECRI 2015).
Lastly, both actors equally apply “soft” methods of LGBTI rights promotion, such as
supporting local activists and NGOs, advising foreign governments on reforms in this
sphere etc. However, compared to the EU, the US seems far more prone to take punitive
measures against the countries violating LGBTI rights. For example, in 2014, after
Uganda adopted the Anti-Homosexuality Act, President Obama imposed sanctions on that
country which included cutting or redirecting funds for particular programs, banning some
Ugandan politicians from entering the US, cancelling plans to hold a military exercise etc
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(Hayden 2014). The EU, in turn, decided not to impose any sanctions for the reason of
Uganda’s importance as a partner on South Sudan and Somalia (Atuhaire 2014), just the
bloc’s three-member states - Denmark, the Netherlands, and Sweden - cut or suspended
their aid to the Ugandan government. This example, again, displays a gap among EU
members in their attitudes to LGBTI rights
6
, which seemingly limits the range of methods
disposable for the bloc, enfeebling its potential to promote LGBTI rights.
On the Success of Promotion: Conditions in the Target Countries
Despite the growing importance of LGBTI rights promotion in the US and EU foreign
policies, the positive results achieved so far appear tangible, but still limited, because of
both domestic conditions in the target countries and the mechanisms the two actors use
to support LGBTI rights. One can single out two main groups of states which have shown
progress in LGBTI rights in the last 10-15 years
7
. The first one embodies EU candidate
countries and the participants of other EU-led initiatives (e.g. the Eastern Partnership).
For those states, amelioration of their domestic LGBTI-related legislations is a
prerequisite for an EU membership or a common free-trade area. For this reason, most
of them have adopted regulations securing the EU’s minimal requirements regarding
LGBTI rights, namely decriminalising homosexuality, allowing gay prides, outlawing
discrimination based on sexual orientation and gender identity etc. As case studies (e.g.
Bilić 2016, Kalezić and Brković 2016, Rexhepi 2016, Vasilev 2016) show, those countries’
elites undertake such measures primarily not because of their ideological predisposition
in favour of LGBTI rights per se, but, rather, due to their identification with Europe as a
modern and civilized entity and/or simply for instrumental reasons, in order to formally
fulfil an EU requirement. Put theoretically, most of those states seem to have socialized,
but not internalized LGBTI rights as a norm (Schimmelfennig, Engert and Knobel 2006:
3-5). Hence, their elites tend to treat LGBTI issues formally, mostly aiming to pass the
EU’s “checklist” rather than improve LGBTI people’s life, to alter legal environment in
particular rather than tackle homophobia in general. Furthermore, because those states’
adherence to LGBTI rights chiefly originates not in their own values, but in the external
environment, their LGBTI rights-related policies highly hinge on the EU’s (instrumental
or identity-based) attractiveness for them. A possible future decrease in the latter may
be detrimental to former.
Incidentally, in a long-term perspective, EU directives seem to only serve as a sort of
safely cushion providing a minimal level of LGBTI rights. Whether any deeper measures
aiming to curb homophobia in general are taken appears to depend on the national
governments’ will and the strength of local advocacy groups. The experience of the 2004
acceding states shows that two scenarios are possible. In some cases, EU influence does
appear to generate tolerance among ordinary citizens: the Czech Republic, for example,
is nowadays one of the most tolerant EU countries toward LGBTI with the 80%
acceptance of homosexuality (Pew Research Center 2013: 1). By contrast, in other states
the situation seems to be even moving in the opposite direction: for instance, polls
6
This gap apparently also relates to differences in EU members’ foreign policy interests, capabilities and
identities (see Keukeleire and Delreux 2014: 116-134).
7
Since disentangling the impact of international actors’ LGBTI rights furtherance from the role of local
activists and other factors is complicated and sometimes nearly impossible, this study assumes that any
improvement in LGBTI rights in country A is to some degree affected by the EU/US if their promotion
activities in country A have been tangible.
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conducted in 2013 showed that only 35% of Lithuanians were accepting homosexuals in
workplace, and the attitudes toward homosexuals had become more negative by 14%
over the past five years (Valentinavičius 2013)
8
.
Another region, in which LGBTI rights promotion goes well, is Latin America, where
progress in this area in the last decades has in large part taken place because local
activists have been inspired by a similar process in Spain, receiving tactical and financial
aid from there (Díez 2015: 127, Encarnación 2016b: 37-38). Encarnación (2016b: 49-
74) notes several internal conditions that favoured the success of LGBTI rights promotion
in that region. First, homophobic sentiments in Latin America were initially weak: unlike
in Europe, homosexuality in Latin America was decriminalized in the 19
th
century, which
laid the foundation for a decrease in homophobia in general. Second, Latin America has
traditionally had strong human rights movements keeping good ties with European left-
wing politicians and advocacy groups. Moreover, in Latin America, it it mostly local
activists and not international actors who have promoted legalization of same-sex
unions/marriages; for this reason, society have considered them as a real need of local
LGBTI communities rather something imposed from abroad. Finally, auspicious for LGBTI
rights has been Latin America’s strong autonomous judiciary (especially in Mexico, Brazil,
and Colombia) which has often ruled in favour of LGBTI community.
The movement toward liberalisation, demonstrated by both aforementioned groups of
countries, especially sticks out against the backdrop of the states where LGBTI-related
laws have been, conversely, tightened in the last years. Again, there are two main “poles”
exhibiting this trend. The first one is Russia that has banned adoption of children to
countries where same-sex marriage is legal, passed a law criminalizing homosexual
“propaganda” and endeavoured to push a number of post-Soviet states to adopt similar
laws
9
. The second pole is sub-Saharan Africa
10
, where three countries - the Gambia,
Kenya and Nigeria - have significantly toughened criminal laws against homosexuality in
the recent years, and there is a certain risk that the continent’s other states, especially
the Democratic Republic of Congo, Liberia, and Uganda, will follow the path. Though the
EU and the US have taken various measures to curb LGBTI discrimination, from
sponsoring LGBTI projects and funding NGOs to raising their concern verbally to imposing
economic sanctions, these measures have not achieved the intended goals for a number
of reasons.
One factor that stands out is an initially strong social consensus on the unacceptability
of homosexuality: in the above-mentioned states, tolerance toward LGBTI ranges from
1% of population in Nigeria to 16% in Russia (Pew Research Center 2013: 1). The exact
roots of that consensus differ from case to case. In Africa, for instance, an important
factor is religious opposition groups that receive material support from Western
8
Interestingly, given that Lithuania shows a growing pro-European sentiment (European Commission 2015b:
8), a rising homophobia in that country seems to contradict the theoretical argument that the stronger a
state’s identification with the EU, the higher the odds of the success of EU LGBT discourse there (see Vasilev
2016).
9
For instance, in Kyrgyzstan, a similar law is pending consideration in the Parliament as of June 2017; in
Armenia, Kazakhstan and Ukraine, governments proposed such laws, but later withdrew them. A similar
law was passed in Moldova in 2013, but later abrogated under EU pressure; in Latvia and Lithuania, such
laws were initiated by conservative groups, but never went as far as being discussed in the Parliaments.
10
One can add a third “pole” of this process, India, where the Dehli High Court recognized the then existing
criminal punishment for homosexuality as unconstitutional in 2009, but the Supreme Court annulled that
judgement in 2013. Nevertheless, later, in 2016, the Supreme Court agreed to review the ruling, positing
that a further hearing of the issue should be carried out by the Constitutional bench. As of June 2017, it is
hard to foresee if the situation with LGBTI rights in India is going to worsen or improve.
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conservatives (Ibrahim 2015: 269-270). However, the factor that is common in all those
countries is strong anti-Westernism, which in Africa is mostly a vestige of its colonial past
and in Russia is a remnant of the Cold War. In both cases, anti-Westernism has been
recently “activated” and inflamed by those countries’ autocratic leaders (Mole 2016: 114-
116). Anti-Westernism induces those societies to conceive of anti-LGBTI laws in
geopolitical terms, as a contribution to the fight against the West that allegedly foists its
culture upon their traditional life (Encarnación 2016a: 220-221). For international
promoters of LGBTI rights, such creates somewhat a stalemate: the more they criticize
the laws, the more those laws are supported by the majority of those countries’
populations. In such circumstances, international furtherance of LGBTI rights only
inflames aggression against local LGBTI communities who tend to be viewed as Western
spies at home. Moreover, EU/US pressure leaves national elites cornered, since people
are likely to perceive any mitigation of the anti-LGBTI laws as cowardice in front of the
West (Downie 2014: 9-10). This raises a question of methods the EU and the US should
apply for LGBTI rights promotion in “difficult” states (discussed in the next section). Yet,
widespread homophobia hardly seems the only reason for those countries’ regression in
LGBTI rights: in the end, South Africa, where only 32% of population found
homosexuality acceptable in 2013 (Pew Research Center 2013: 1), legalized same-sex
marriages eight years earlier, and Hungary, 53% of population deemed homosexuality
as “morally wrong” in 2017 (Pew Research Center 2017), legalized same-sex
partnerships as early as in 2009.
Another factor is that neither of those countries is a democracy, at least not a stable
one
11
. A democratic system is argued to conduce to LGBTI rights advancement in three
ways, that is, enabling a sturdy civil society, making it possible to extend citizenship
(understood as membership in society) to minorities and disadvantaged groups and
guaranteeing judiciary independence (for details, see Encarnación 2014: 99-101).
Indeed, partial judiciary makes defending human rights in the court practically
impossible: for instance, a recent study on Russian LGBTI activists’ attempts to contest
discrimination in court concluded that “[i]n the majority of cases concerning
discrimination – either explicitly or implicitly – the courts did not analyse whether
discrimination had occurred in any meaningful way” (Equal Rights Trust 2016: 133)
12
.
Moreover, those countries’ civil societies remain relatively weak, easily suppressible by
the government and, as a result, they can hardly serve as reliable allies in EU and US
LGBTI rights promotion: local LGBTI organizations are scanty and frangible and even
most progressive political parties do not actively struggle for LGBTI rights, either due to
their fear to lose supporters if they raise such an unpopular issue, or owing to their true
conservatism concerning LGBTI rights. Illustrative of this is that, as of June 2017, neither
of the leading liberal Russian parties - Civic Initiative, Democratic Choice, People’s
Freedom Party, or Yabloko - has any provision in its program regarding LGBTI rights and
freedoms (Civic Initiative 2015, Democratic Choice 2012, Parnas 2015, Yabloko 2012).
Moreover, but for rare exceptions, their leaders show, at best, indifference to LGBTI
issues and, at worst, somewhat homophobic views. For example, in June 2013, Sergei
Mitrokhin, the then leader of Yabloko, said in an interview:
11
Exemplary of this fact is that Freedom House (2017: 20-24) marks neither of these states “free”, as opposed
to most of the aforementioned countries where LGBTI rights promotion has succeeded.
12
Tellingly, all those states rank low in the global Rule of Law Index (World Justice Project 2016: 21).
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I’m not an advocate of gay parades. The people who organize them
are provocateurs. They are provoking a counter-wave in society,
and these minorities which they are supposedly defending only have
it worse (The Interpreter 2013).
A month later, Mitrokhin called same-sex marriages unacceptable, however, arguing that
gay parades should not be banned, for they represent people’s constitutional right to
express their opinion peacefully (Baev 2013). Taking into cognizance that Yabloko is a
member of the European ALDE Party, a strong proponent of LGBTI rights, this instance
may be demonstrative of Russian democratic politicians’ notable conservatism compared
to their EU counterparts, their inconsistency on LGBTI issues and somewhat
unimportance with which they treat them
13
.
Any Possibility of Improvement? A Critical Overview of Suggestions
Is this situation a complete deadlock, or is there a way for the EU and the US to further
LGBTI rights in such states
14
? Intuitively, it seems possible to achieve internalization on
the level of society in the long run through strengthening local advocacy groups. For this
reason, it may be effective to redirect funds from the governments to human rights
NGOs, like the US and three EU members did in Uganda (Downie 2014: 16). A long-term
strategy requires educational programs debunking faulty statements on which anti-
Westernism and homophobia rest (Onishi 2015). In particular, such programs may
explain that human rights is not only a Western concept: African states and Russia are
also vigilant to discrimination against black people and Russian language speakers
respectively. Education can also help dissuade people from a false idea that
homosexuality was historically unacceptable in their societies: historical evidence shows
that homosexuality was well tolerated in pre-colonial Africa (Ibrahim 2015: 268-269) and
medieval Russia (Kon 2006: 321-322).
However, providing aid to local activists for conducting educational programs is normally
possible only in democracies, where national governments do not impede such activities.
The problem with autocracies is that they tend to encumber human rights NGOs from
receiving foreign aid: Russia, for instance, recently expelled USAID from the country and
adopted a law that labels NGOs receiving foreign aid “foreign agents” which in Russian
equals “spies”. Therefore, some argue, LGBTI issues in autocracies can be tackled only
after democratisation (e.g. Encarnación 2014: 101-103) that will create environment
favorable for LGBTI activism. Yet, democracy does not seem to be a panacea for LGBTI
discrimination. First, most people may favor the idea of marriage equality, but not
consider it a priority when voting: seemingly for this reason, same-sex marriages are not
legal in Australia as of June 2017, despite that opinion polls have shown that most
Australians have been supportive of them since 2007 (Hutchens 2016). Second, in
13
Some note, however, that in recent years Russian liberals have been getting gradually more empathetic
toward LGBT community against the backdrop of the rising anti-LGBTI oppressions (Healey 2014: 65-66).
As an illustration of this, currently most influential Russian opposition leader Alexei Navalny recently spoke
in favour of gay marriage legalization (Navalny 2017) notwithstanding that most Russians share anti-LGBTI
sentiments.
14
The following discussion holds not only for states where situation with LGBTI rights is currently worsening,
but also other autocracies where society and political elite are mostly anti-Western and homophobic (e.g.
Iran).
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conservative societies, a democratic system is likely to help homophobic populists to
come to power through elections: as Encarnación (2014: 97) puts it,
democracy is not an insurance policy against anti-gay
discrimination, much less a guarantee that gay rights will be
protected, even after these rights have been enshrined in law.
Democracy can just as easily be used by foes of the gay community
to undermine gay rights as it can by gay-rights advocates to
advance them.
Another way to push for LGBTI rights from abroad is undertaking penalizing measures,
such as shaming and economic sanctions, against the governments of countries
discriminating against LGBTI communities. With regard to such measures, however,
analysts and experts have three diverse opinions. Some favor them, contending that they
are likely to work if the target country is economically dependent on the West (e.g.
DeCataldo 2015): according to Jessica Stern, the executive director of the International
Gay and Lesbian Human Rights Coalition, this logic impelled Uganda to abolish its anti-
gay law in 2014 following US sanctions (Peale 2015). Yet, while academic studies on
sanctions efficiency support this argument, they also show that economic sanctions work
best under conditions which seem absent in the countries under research: when imposed
on democracies, when approved by an international institution and not only a country,
when at issue is a matter of low salience (for a literature review, see Drezner 2011: 99).
Similarly, scientific research reveals that shaming is most effective against governments
that care about their international reputation (Risse, Ropp and Sikkink 2013), a condition
which usually does not hold for anti-Western autocrats.
Another group of analysts (e.g. Downie 2014: 9-10, Onishi 2015) oppose shaming and
economic sanctions, arguing that such measures aggravate anti-Westernism and anti-
LGBTI aggression, thus playing into the hand of traditionalists who can use LGBTI people
as scapegoats, blaming them for social and economic problems. Indeed, a number of
academic papers (e.g. Wachman 2001) support the argument that inside the target state,
international sanctions may produce anger rather than compliance. Yet, research also
shows that punitive measures may have positive effects: even though economic
sanctions may not improve human rights situation in the target country, they tend to
fear the region’s other countries and hence, reduce (actual or possible) human rights
violations there (Carneiro 2014). Furthermore, punitive measures give psychological
support to activists and victims of human rights violation in target countries (Kinzelbach
and Wolf 2015) and show that the EU and the US treat their values not as mere
declarations, but as principles by which they genuinely abide. Hence, the third approach
calling for punitive measures to be applied only if/when local LGBTI activists request
them (Godfrey 2014) appears most balanced and, as academic studies (e.g. Murdie and
Davis 2012) show, especially efficient.
Several analysts believe that the EU and the US must not specially accentuate LGBTI
rights so as not to create the impression that they prioritize certain rights over others.
In this vein, Downie (2014: 13) points to the fact that the US imposed sanctions on
Uganda over the Anti-Homosexuality Act, while when several presidential candidates
were arrested in that country at a peaceful demonstration in 2011, the US confined itself
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to soft criticism. In fairness to the US, nonetheless, its approach does not appear so
unbalanced. First, one can see a correlation between the seriousness of human rights
abuses and the degree of punitive measures introduced by the US: indeed, the above-
mentioned arrested Ugandan candidates were released after several days, while the Anti-
Homosexuality Act stipulated up to 14 years of imprisonment. Second, one can find
certain reasonableness in other cases where US policies get blamed for double standards:
to illustrate, the aforesaid tendency to strongly criticise anti-LGBTI laws in certain
countries (Uganda, Gambia) while overlooking identical laws in other states (Iraq, Saudi
Arabia) may mean that the US applies decisive measures only with respect to states
stiffening such laws, censuring in a “softer” way countries, where anti-LGBTI legislation,
even tough, has long been unchanged.
Finally, so as not to waste resources and not to deteriorate anti-LGBTI aggression, it
seems reasonable for the EU and the US to give priority to promoting LGBTI rights in the
countries where progress seems accomplishable rather than in the world’s most
homophobic states, even if it may generate accusations of double standards. As Stern
noted, “[w]e can’t only invest in the so-called ‘worst places on Earth’. The United States
is capable of being most helpful where the U.S. Government record is not hotly
contested... otherwise U.S. involvement can backfire on local communities” (Peale 2015).
Unfortunately, it tends to remain intuitively unapprehended by policymakers who prefer
allocating resources where aid is most needed: as Polish LGBTI activist Zofia Jablonska
regrettably noticed, “when it comes to funding from American donors, Poland is not their
main priority anymore, because now we are in the EU. For them this is an indicator that
minority rights situation in Poland cannot be that bad off comparing, for example, with
the Global South countries” (Romanovski 2015).
In Lieu of Conclusion
While the US and the EU, two main international relations actors supporting LGBTI rights
abroad, agree on the basic principles of their promotion, their strategies and methods
differ in technical terms. Those differences reflect their general approaches to foreign
policy making, namely a stronger and more globally oriented stance of the US and a
softer and more regionally aligned attitude of the EU. The fact that the two actors are
strategic allies allows them to enjoy the strengths of each other’s approaches: the
decisiveness of American foreign policy may help the EU in dealing with target states’
elites, while the US, in turn, can capitalize on EU experience of cooperating with NGOs
and civil societies. However, both powers’ reputation as human rights promoters suffers
from certain features steadily associated with them: the EU is notorious for being overly
bureaucratized and treating human rights superficially and formally, while the US, in
turn, is traditionally infamous for handling human rights in a politicized way.
So far, EU and US promotion of LGBTI rights has mainly been successful in the states
that have formal commitments to respect LGBTI rights and/or in countries where initial
domestic conditions were in favour of LGBTI activists. Conversely, in more conservative
conditions, furtherance of LGBTI rights from abroad, especially when coupled when
punitive measures against target countries’ governments, tends to backfire on local
LGBTI activists. Perhaps ironically, it goes at odds with one of the basic principles of
human rights promotion, namely “taking into account the local realities in which human
rights defenders need to advance their struggle” (Council of the EU 2013). To date, it
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seems that the two actors must cooperate and coordinate their activities to formulate a
detailed and well-planed long-term strategy to effectively further LGBTI rights in the
world.
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