Although the colonial powers withdrew – for the most part –, the prison models they had established continued to operate. Even today, many formerly or currently colonised countries have adopted penitentiary standards, ranging from prison architecture to management practices, that originated elsewhere and, in many cases, were introduced through international cooperation. Staff training, security measures and disciplinary decisions remain heavily influenced by western standards, which are rarely adapted to account for the national context. This contemporary diffusion through financial support or direct intervention perpetuates a power relationship inherited from the colonial past.

The United States is by far and away the leading country in terms of exporting its prison model and practices. Researcher Julie de Dardel observes that “the primary export channel of the American carceral model is directly related to the United States’ foreign policy and its military actions”. Initially in the name of the “war on terror”, then the “war on drugs”, “the driver of the foreign deployment of the American carceral model [is] national interest or, in other words, the defence of the ‘vital interests’ of the United States”.

Julie de Dardel further explains that in Afghanistan and Iraq, this exportation was mainly focused around the operational and security systems of the federal penitentiary system. In Pakistan, Justice Project Pakistan (JPP) reports that since the war on terror began, the United States has been particularly present in the northern province via the State Department’s Bureau of International Narcotics and Law Enforcement Affairs (INL), and in that time has provided significant funding to the Pakistani penitentiary institution.

Sarah Belal points out that the American authorities contributed to the construction of new prisons that clearly reproduce the United States’ carceral model.

The US authorities’ investment took place, in the context of the “war on drugs”, in the form of government-to-government technical assistance, through the sending of experts, reports Julie de Dardel. In Colombia, this assistance was coordinated by the National Institute of Corrections (NIC) in the form of “a multi-year takeover of the prison service by the American agents and an in-depth transformation of this sector”. The United States has spent 140 million dollars since the 2000s to reform Colombia’s justice system, notes Equal Justice Initiative (EJI). Six new prisons were built between 2000 and 2003 based on the blueprints of a federal prison in Florida. Sixteen more were built over the following 12 years, increasing Colombia’s prison capacity by 70%.

Through the INL, the United States has trained tens of thousands of correctional officers around the world as part of anti-terrorist and anti-drug policies. This included around 50,000 correctional officers over a period of ten years, who then helped train at least 60,000 others. In 2017, the INL was active in 38 countries, with about one hundred advisers deployed full-time, reports Buzzfeed News.

In Latin America, correctional officers are trained using American instruction manuals that have been translated into Spanish, notes EJI. Some Colombian officers trained using techniques from the United States were, according to Buzzfeed, later accused of violating human rights. The United States’ intervention is considered a failure by civil society organisations: prison overcrowding has increased, as has the widespread use of solitary confinement.

The situation is no different in Afghanistan. Buzzfeed reports that in 2013, the United Nations Assistance Mission in Afghanistan stated that there was “sufficiently credible and reliable evidence” that hundreds of incarcerated individuals had been tortured and mistreated by prison officers, many of whom were likely trained by the United States.

The United Kingdom has faced similar accusations. In 2018, Reprieve published a report accusing the authorities of being complicit in human rights violations in Bahrain and of lacking transparency regarding the use, between 2012 and 2017, of a programme to reform security and justice in the kingdom that had been allocated 5 million pounds sterling. The organisation reports that the British authorities trained hundreds of correctional officers who were later accused of torturing incarcerated people. Its report notes that despite the significant sum committed to the programme, the number of incarcerated individuals on death row tripled, torture in detention continued and executions started again for the first time since 2010.

Sarah Belal explains that in Pakistan, the most sought-after prison training programme is run by the INL, which selects prison officials in the four provinces. Following the training course, these officials go on to hold prominent positions. “They are taken to Colorado”, she says. “The United States has taught everyone how to manage prisons, and it has become a reference. The number of times where we have to say in court: ‘Stop citing American prisons. They are not a model; they do not meet any standards’. We need to draw judges’ attention to the fact that Pakistani prisons are, in many aspects, more humane than American prisons. But that’s when we see how much influence this programme has.” She adds that the majority of the inspectors general have taken this course.

In Haiti, the majority of prisons were constructed with the financial assistance of the international community, Roberson Édouard explains. “It was not sovereign, domestic reasoning that presided over the construction of the detention centres, but rather international assistance, in particular through the wishes of Canada and the United States, which led to the construction of a detention centre and the regulation of the correctional system.” Moreover, the country’s official statistical data are published by international bodies, and not by a national government agency.

Roberson Édouard summarises the situation: “Do you want a statistic? Don’t go to the Haitian bureau of statistics (Institut Haïtien de Statistique et d’Informatique), go to the World Bank or the Economic and Social Council of the UN (ECOSOC). Do you want economic information? The World Bank has it. You want information about the justice system? Don’t ask the Ministry of Justice, try the United Nations Integrated Office in Haiti (BINUH). And even the state authorities cite international data to maintain credibility because – pardon the expression – if the white man says it, it must be true.”

International bodies such as the European Union finance a great number of programmes to support prison reform, often based on a single model and the same specifications. This consequently results in standardised penal solutions that meet the recommendations of the backers, stresses Marie-Julie Bernard, a researcher at CERDAP².

The administrative and institutional differences of the national context remain unconsidered, in a sector with significant institutional complexity given the numerous stakeholders (justice practitioners, civil society groups, solicitors, etc.) and the codification of procedures.

With regard to Côte d’Ivoire, she indicates that despite the considerable analysis of the criminal justice system – including by financial backers such as the United Nations Development Programme (UNDP) –, the approaches adopted are typically limited to applying international standards without taking into consideration national situations. Projects aim to “study the operation” of the judicial system, but the diagnosis and the suggested solutions are the same as elsewhere, such as in Madagascar, the Central African Republic and Chad. The specific administrative and institutional context of Côte d’Ivoire is therefore ignored.

Professional associations and international conferences also play a decisive role in spreading the models. “In the prison sector, these ‘global micro-spaces’, where the actors of the carceral sector gather, discuss and connect, are absolutely crucial in the development of a global market that primarily benefits the American prison industry”, observes Julie de Dardel. The International Corrections and Prisons Association (ICPA) plays the leading role in bringing together prison services across the world and companies specialising in the carceral field and security measures. In summary, “the ICPA is, in a way, the World Economic Forum of the prison sector”.

The international assistance intended for justice and prison systems is often accompanied by more or less explicit terms: to benefit from financial or logistical support, the countries in question must conform to previously determined standards, procedures or indicators. These requirements shape national priorities, guide reforms, and contribute to the imposition of a global carceral model that is often disconnected from reality.

Marie-Julie Bernard notes that since the end of the post-election crisis, Côte d’Ivoire has complied with supranational injunctions, in particular through the 2016-2020 national development plan (Plan National de Développement, PND) and the creation of specific programmes whose stated objective is to improve imprisonment conditions. “In this way, [the state incorporates] international standards relating to detention in order to satisfy the demands of international injunctions, lenders and organisations”, she writes. She indicates that the implementation of international standards leads to the adoption of standardised correctional solutions.

Without alternatives and due to their financial needs, the states often have no other choice but to accept. But these reforms, designed on foreign soil, struggle to take root: they remain difficult to implement, or even impossible to put into practice, as they are so far removed from the domestic situation.

In Côte d’Ivoire, ACAT-CI notes that the new correctional facilities are partially funded by the European Union, based on architectural and operational models that follow the European standards and models. The standards being endorsed – whether in relation to the minimum space requirement per incarcerated individual, natural light or sanitary conditions – are presented as universal benchmarks meant to guarantee a “dignified” detention.

However, these norms are far from being systematically respected in the very countries that establish them or that finance their implementation elsewhere. This contradiction underscores the limits of a model that is exported without consideration for its application, and occasionally reveals a merely symbolic usage that does not effectively ensure the respect of human rights.

In Haiti, international aid finances a considerable portion of the prison system: building construction, personnel training and management systems. “It also includes the implementation of repressive measures, in particular solitary confinement cells, surveillance systems or even forensic identification”, explains Roberson Édouard. And the introduction of these measures generates other needs that are addressed by the same states that suggested them in the first place – in essence creating a lucrative market.

“International assistance is heavily reliant on selling expertise. ‘We helped build a prison, but you don’t know how to operate it? We’ll show you how to do it. To do so, we’ll bring in experts from Canada, France or the United States – a big budget, in any event.’ That’s what international assistance is.”

The assistance also translates into the shipment of equipment and the introduction of new technologies into Haitian prisons. But these gifts come with strings attached, explains Roberson Édouard: “The United Nations Stabilisation Mission in Haiti (Mission des Nations Unies pour la stabilisation en Haïti, MINUSTAH) offered a new system to manage penitentiary data. It was not at all adapted to the situation in the country, as it required Internet access, which is prohibitively expensive. Then the authorities from the United States joined the conversation and said, ‘No, we’ll give you something else.’ What they failed to mention is that the system they intended to give the prison service was a system that would be used by them and them alone. They provided devices that took photos, recorded fingerprints, etc., but which, at the end of the day, essentially only benefited the consular services of the United States in screening people who file visa requests. They enabled these services to run direct forensic identity searches: they need only enter a name to know if the person has spent time in prison. If that’s not out-and-out colonialism, what is it?”