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President Trump Announces U.S. Troop Withdrawal from Syria

Published online by Cambridge University Press:  09 April 2019

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Begun over seven years ago, the conflict in Syria became and remains a humanitarian crisis. The United States entered the conflict in 2014 and has since been involved through its use of airstrikes and deployment of ground forces. On December 19, 2018, President Trump announced his decision to withdraw U.S. troops from Syria. In the months subsequent to this announcement, unsettled questions have lingered regarding a timeline for withdrawal, the fate of the U.S.-backed Kurdish forces in Syria, and how the decision to withdraw will affect U.S. interactions with other Middle Eastern countries.

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Type
Use of Force, Arms Control, and Nonproliferation
Information
American Journal of International Law , Volume 113 , Issue 2 , April 2019 , pp. 394 - 400
Copyright
Copyright © 2019 by The American Society of International Law 

Begun over seven years ago, the conflict in Syria became and remains a humanitarian crisis.Footnote 1 The United States entered the conflict in 2014 and has since been involved through its use of airstrikes and deployment of ground forces. On December 19, 2018, President Trump announced his decision to withdraw U.S. troops from Syria.Footnote 2 In the months subsequent to this announcement, unsettled questions have lingered regarding a timeline for withdrawal, the fate of the U.S.-backed Kurdish forces in Syria, and how the decision to withdraw will affect U.S. interactions with other Middle Eastern countries.

The United States first entered the conflict in Syria in 2014 when President Obama began ordering airstrikes, joined by Qatar, Bahrain, Jordan, Saudi Arabia, and the United Arab Emirates, against the terrorist organization known as the Islamic State of Iraq and the Levant (ISIL).Footnote 3 The Obama administration claimed that it had domestic legal authority to conduct airstrikes against ISIL based on the 2001 and 2002 Authorizations for Use of Military Force,Footnote 4 and it claimed that, under international law, the U.S. use of force fell within its rights to individual and collective self-defense against threats posed by ISIL to itself and Iraq.Footnote 5 In 2015, Obama authorized the first ground forces to enter the Syrian conflict.Footnote 6 Under this authorization, American Special Operation troops came to Syria in 2016, joining the Syrian Democratic Forces, a Kurdish-led militia, in the fight against ISIL.Footnote 7 Trump indicated on his first day in office in January 2017 a continued resolve to defeat ISIL, stating, “[w]e have to get rid of [ISIL]. Have to get rid of [ISIL]. We have no choice.”Footnote 8

Over the course of 2017 and 2018, ISIL's territory shrunk dramatically, continuing a trend since its territorial peak in 2014 when ISIL controlled approximately 100,000 square kilometers of territory in Syria and Iraq.Footnote 9 By December 2018, ISIL remained in possession of only about one percent of this territory.Footnote 10 Although Trump occasionally indicated during 2018 that ISIL had been fully defeated,Footnote 11 other government officials insisted that the Trump administration continued to fight ISIL in Syria. In April of that year, the White House press secretary stated that the “United States and our partners remain committed to eliminating the small [ISIL] presence in Syria that our forces have not already eradicated.”Footnote 12 Several months later, the Acting Assistant Secretary of State for the Bureau of Near Eastern Affairs, David Satterfield, emphasized that “[t]here should be no doubt as to the position of the President with respect to the broader issue of the U.S. enduring presence in Syria.”Footnote 13 When asked in early December if American soldiers would remain in Syria for “some time unforeseen,” Special Presidential Envoy for the Global Coalition to Defeat [ISIL] Brett McGurk responded that “it's fair to say Americans will remain on the ground after the physical defeat of the caliphate, until we have the pieces in place to ensure that that defeat is enduring.”Footnote 14

With the diminishment of ISIL's territorial reach, government officials began discussing additional U.S. objectives for Syria. Secretary of State Mike Pompeo remarked in October 2018:

[ISIL], though not completely snuffed out, has been beaten into a shadow of its former self. And these changing circumstances have required the reassessment of America's mission in Syria. Defeating [ISIL], which was once our primary focus, continues to be a top priority, but it will now be joined by two other mutually reinforcing objectives. These include a peaceful and political resolution to the Syrian conflict and the removal of all Iranian and Iranian-backed forces from Syria.Footnote 15

On November 30, the White House released a statement supporting a bill called the Caesar Syria Civilian Protection Act of 2018 (CSCPA).Footnote 16 The CSCPA would have required sanctions on persons the president determines are knowingly engaged in providing financial, material, or technological support to the Syrian government and its officials and it would have barred such persons from entering the United States.Footnote 17 The CSCPA also described a strategy for deterring “foreign persons from entering into contracts related to reconstruction” in the areas that the president determined were under the control of the Syrian, Russian, and Iranian governments.Footnote 18 Although this bill passed the House, it did not receive a floor vote in the Senate before the expiration of the congressional session.Footnote 19 But another bill directed broadly at the conflict in Syria had more success. On December 11, 2018, Trump signed into law the Iraq and Syria Genocide Relief and Accountability Act of 2018 (ISGRAA), which “authorizes assistance to entities engaged in aiding individuals and communities in Iraq or Syria who are being, or are likely to be, targeted for genocide, crimes against humanity, or war crimes.”Footnote 20 Some of the assistance the ISGRAA authorizes includes permitting the secretary of state and the administrator of the United States Agency for International Development to conduct criminal investigations, provide infrastructure to effectively adjudicate cases, and collect and preserve evidence “for use in prosecutions in domestic courts, hybrid courts, and internationalized domestic courts … .”Footnote 21 This legislation signals a congressional interest in Syria that goes beyond a narrow focus on defeating ISIL.

In an apparently abrupt decision, Trump informed senior officials on December 18, 2018, of his decision to withdraw U.S. forces from the country.Footnote 22 Trump made his decision public when he tweeted the next morning that “[w]e have defeated [ISIL] in Syria, my only reason for being there during the Trump Presidency.”Footnote 23 Trump elaborated later that day in a tweeted video:

I've been President for almost two years and we've really stepped it up. And we have won against [ISIL]. We've beaten them and we've beaten them badly. We've taken back the land. And now it's time for our troops to come back home… . It's time to come back. They're getting ready. You're going to see them soon. These are great American heroes… . So our boys, our young women, our men—they're all coming back and they're coming back now.Footnote 24

Congressional leaders and government officials were quick to criticize Trump's decision. One day after Trump's public announcement, two of his officials sent letters of resignation. McGurk announced that he would resign, explaining that “[t]he recent decision by the president came as a shock and was a complete reversal of policy that was articulated to us,” leaving “coalition partners confused and our fighting partners bewildered.”Footnote 25 Secretary of Defense Jim Mattis also announced his resignation, stating that like Trump, he has “said from the beginning that the armed forces of the United States should not be the policeman of the world,” but that his “views on treating allies with respect and also being clear-eyed about both malign actors and strategic competitors are strongly held … .”Footnote 26 Mattis explained that “[Trump] ha[s] the right to have a Secretary of Defense whose views are better aligned with [Trump's] on these and other subjects … .”Footnote 27 U.S. Senator Lindsey Graham along with five other senators signed a letter to Trump calling the decision to withdraw at this time “premature” and a “costly mistake.”Footnote 28 The letter also expressed concern about the Kurdish forces that the United States would leave behind.Footnote 29 In a further signal of congressional concern, in early February the U.S. Senate passed a Middle East policy bill by a 77–23 vote that included a section warning against a “precipitous withdrawal” of U.S. forces in Syria and Afghanistan and expressing the Senate's “sense” that there is a “continuing threat to the homeland and our allies posed by al Qaeda and [ISIL], which maintain an ability to operate in Syria and Afghanistan.”Footnote 30

Analysts expressed concern about how the U.S. troop withdrawal would leave Kurdish forces vulnerable to attacks by Turkey.Footnote 31 Turkey's government has viewed the Syrian Democratic Forces as a threat due to their connections with a Turkish Kurdish separatist group, the PKK.Footnote 32 Only a week before Trump's announcement, President Erdogan had suggested that Turkey would undertake a raid in northeastern Syria, where the Syrian Democratic Forces receive U.S. support.Footnote 33 The Syrian Democratic Forces released a statement responding to Trump's withdrawal, expressing that,

at a time, while we are having fierce battles against the terrorism in the last strongholds of [ISIL] and fighting it's [sic] sleeper cells that are trying to organize its ranks in the region, the White House's decision to withdraw from northern and eastern Syria will negatively affect the campaign against the terrorism, and it will provide a chance for terrorism and its supporters in the political and military fields to recover again and launch counter-terrorist campaign in the region.Footnote 34

Others expressed approval of Trump's decision to withdraw. President Putin announced that he believed Trump's decision was “correct” and that “[w]ith regards to the victory over ISIL, on the whole I agree with the president of the United States.”Footnote 35 Erdogan remarked that Turkey “welcome[d]” Trump's withdrawal statements and that he would delay an offensive against Kurdish forces in northeastern Syria based on a phone call he had with Trump.Footnote 36

Several days after the announcement, Trump visited U.S. troops stationed at Al Asad Air Base in Iraq and spoke about his decision:

American and coalition forces have had one military victory after another over the last two years against [ISIL], including the retaking of both Mosul in Iraq and Raqqa in Syria… .

…

I made it clear from the beginning that our mission in Syria was to strip [ISIL] of its military strongholds; we're not nation building. Rebuilding Syria will require a political solution. And it's a solution that should be paid for by its very rich neighboring countries, not the United States. Let them pay for it. And they will. They will.

…

There will be a strong, deliberate, and orderly withdrawal of U.S. forces from Syria—very deliberate, very orderly—while maintaining the U.S. presence in Iraq to prevent an [ISIL] resurgence and to protect U.S. interests, and also to always watch very closely over any potential reformation of [ISIL] and also to watch over Iran. We'll be watching.Footnote 37

State department officials tried to clarify that despite the announced withdrawal from Syria the “United States is not leaving the Middle East.”Footnote 38 Trump stated that there were no plans to pull troops out of Iraq.Footnote 39 Pompeo scheduled a visit to Jordan, Egypt, Bahrain, UAE, Qatar, Saudi Arabia, Oman, and Kuwait “to share with them a couple [of] ideas” including that “America is there … to do the things that need to be done to protect the American people and to ensure Middle East stability” and that “[t]here's no change in our commitment to the defeat of the caliphate or of [ISIL] globally” and “no change in our counter-Iran strategy.”Footnote 40

At the time of this writing, no timeline for the U.S. troop withdrawal from Syria has been fully established. State Department officials have shared that “[i]t will be done in such a way that we … maintain pressure on [ISIL] throughout, and that we do not open up any vacuums for terrorists to exploit.”Footnote 41 National Security Adviser John Bolton has added conditions to the troop withdrawal, telling reporters that American forces will remain in Syria until the remnants of ISIL are defeated and Turkey agrees to protect the U.S.-backed Kurdish forces.Footnote 42 When questioned about possible tensions between the statements made by Bolton and Trump, Pompeo replied “I think they've both said the same thing.”Footnote 43 On February 21, 2019, the Trump administration announced that 200 U.S. soldiers would remain in Syria after the withdrawal of the rest of the troops.Footnote 44

References

1 U.S. Dep't of State Press Release, Briefing on Syria (Nov. 14, 2018), at https://www.state.gov/r/pa/prs/ps/2018/11/287368.htm [https://perma.cc/CV2N-2HMJ] [hereinafter November Briefing] (noting that the conflict has led to an estimated 400,000 deaths, 200,000 incarcerations, 100,000 disappearances, and thousands tortured). For information about the Syrian refugee crisis, see UNHCR, Syria Emergency, at https://www.unhcr.org/syria-emergency.html.

2 Donald J. Trump (@realDonaldTrump), Twitter (Dec. 19, 2018, 3:10 PM), at https://twitter.com/realDonaldTrump/status/1075528854402256896 [https://perma.cc/Q6GG-9WRA] [hereinafter Trump Video Announcement].

3 White House Press Release, Transcript of Background Conference Call on Airstrikes in Syria (Sept. 23, 2014), at https://obamawhitehouse.archives.gov/the-press-office/2014/09/23/background-conference-call-airstrikes-syria [https://perma.cc/V2NV-6CNR]. For more details, see Kristina Daugirdas & Julian Davis Mortenson, Contemporary Practice of the United States, 109 AJIL 174, 199 (2015).

4 White House Press Release, Letter from the President – War Powers Resolution Regarding Iraq (Sept. 23, 2014), at https://obamawhitehouse.archives.gov/the-press-office/2014/09/23/letter-president-war-powers-resolution-regarding-iraq [https://perma.cc/V8HE-6X59]. The 2001 AUMF authorizes the president “to use all necessary and appropriate force against those nations, organizations, or persons he determines planned, authorized, committed, or aided the terrorist attacks that occurred on September 11, 2001, or harbored such organizations or persons, in order to prevent any future acts of international terrorism against the United States … .” Authorization for Use of Military Force (AUMF), Pub. L. No. 107-40, § 2(a), 115 Stat. 224, 224 (2001) (codified at 50 U.S.C. § 1541 (2012)). The 2002 AUMF provides that the “President is authorized to use the Armed Forces of the United States as he determines to be necessary and appropriate in order to (1) defend the national security of the United States against the continuing threat posed by Iraq; and (2) enforce all relevant United Nations Security Council resolutions regarding Iraq.” Pub. L. No. 107-243, § 3(a), 116 Stat. 1498 (2002) (codified at 50 U.S. § 1541 (2012)). For discussion of the legal reasoning undergirding the reliance on these two AUMFs, see Daugirdas & Mortenson, supra note 3, at 207–08 (further noting that reliance on the 2002 AUMF was limited to airstrikes against ISIL in Iraq rather than Syria).

5 The United States claimed that it had the right to conduct airstrikes in Syria based on Article 51 of the UN Charter because “the government of the State where the threat is located is unwilling or unable to prevent the use of its territory for such attacks.” Letter from Samantha Power, U.S. Ambassador to the United Nations, to Ban Ki-moon, Secretary-General of the United Nations, UN Doc. S/2014/695 (Sept. 23, 2014) [https://perma.cc/HPS9-S6AW]. But see Daugirdas & Mortenson, supra note 3, at 204–06 (noting that this “unable or unwilling” analysis is “relatively controversial”). In November 2015, the Security Council passed Resolution 2249, which “[c]alls upon Member States … to take all necessary measures … on the territory under the control of ISIL also known as Da'esh, in Syria and Iraq, to redouble and coordinate their efforts to prevent and suppress terrorist acts committed specifically by ISIL … .” SC Res. 2249, para. 5 (Nov. 20, 2015). This ambiguous language may be taken to provide additional international legal support for uses of force against ISIL. See Dapo Akande & Marko Milanović, The Constructive Ambiguity of the Security Council's ISIS Resolution, EJIL: Talk! (Nov. 21, 2015), at https://www.ejiltalk.org/the-constructive-ambiguity-of-the-security-councils-isis-resolution. For airstrikes in Iraq, the United States claims an international legal justification separate from self-defense, namely the consent of the government of Iraq. See Daugirdas & Mortenson, supra note 3, at 206.

6 President Barack Obama White House Press Release, Daily Press Briefing by the Press Secretary Josh Earnest 10/30/15 (Oct. 30, 2015), at https://obamawhitehouse.archives.gov/the-press-office/2015/10/30/daily-press-briefing-press-secretary-josh-earnest-103015 [https://perma.cc/J37Y-5W84].

7 Rod Nordland, U.S. Exit Seen as a Betrayal of the Kurds, and a Boon for ISIS, N.Y. Times (Dec. 19, 2018), at https://nyti.ms/2Gwys3S.

8 Donald J. Trump, Remarks at the Central Intelligence Agency in Langley, Virginia, 2017 Daily Comp. Pres. Doc. No. 61, at 2 (Jan. 21).

9 U.S. Dep't of State Press Release, Department Press Briefing – December 11, 2018 (Dec. 11, 2018), at https://www.state.gov/r/pa/prs/dpb/2018/12/288024.htm [https://perma.cc/KFT3-R47P] [hereinafter December Briefing].

10 Id.

11 In April 2018, Trump stated at a conference that he wanted “to bring our troops back home” and that it was “time” in light of the “success[] against [ISIL].” The President's News Conference with President Kersti Kaljulaid of Estonia, President Raimonds Vejonis of Latvia, and President Dalia Grybauskaite of Lithuania, 2018 Daily Comp. Pres. Doc. No. 212, at 6 (Apr. 3). Additionally, in November 2018, Trump claimed in an interview leading up to U.S. midterm elections that “[w]e've defeated [ISIL]. [ISIL] is defeated in all of the areas that we fought [ISIL] … .” John Hudson, Lawmakers Raise Alarm About ISIS Attacks Against Syria's Druze Population, Wash. Post. (Nov. 8, 2018), at https://www.washingtonpost.com/world/national-security/lawmakers-raise-alarm-about-isis-attacks-against-syrias-druze-population/2018/11/07/333c5872-b360-495a-92af-f5ef6ef50a73_story.html.

12 White House Press Release, Statement by the Press Secretary on Syria (Apr. 4, 2018), at https://www.whitehouse.gov/briefings-statements/statement-press-secretary-syria [https://perma.cc/P46S-KBHF].

13 U.S. Dep't of State Press Release, Briefing on the Status of Syria Stabilization Assistance and Ongoing Efforts to Achieve an Enduring Defeat of ISIS (Aug. 17, 2018), at https://www.state.gov/r/pa/prs/ps/2018/08/285202.htm [https://perma.cc/GLN9-KZBU].

14 December Briefing, supra note 9. Special Representative for Syria, Ambassador Jim Jeffrey, had previously remarked that “the enduring defeat means not simply smashing the last of [ISIL's] conventional military units holding terrain, but ensuring that [ISIL] doesn't immediately come back and sleeper cells come back as an insurgent movement.” November Briefing, supra note 1.

15 U.S. Dep't of State Press Release, Remarks at the 36th Annual Jewish Institute for National Security of America Awards Dinner (Oct. 10, 2018), at https://www.state.gov/secretary/remarks/2018/10/286559.htm [https://perma.cc/K6EG-3TEQ]. Ambassador Jeffrey also listed the same three U.S. objectives for Syria in a later briefing. November Briefing, supra note 1.

16 White House Press Release, Statement of Support: H.R. 1677 – Caesar Syria Civilian Protection Act of 2018 (Nov. 30, 2018), at https://www.whitehouse.gov/briefings-statements/statement-support-h-r-1677-caesar-syria-civilian-protection-act-2018 [https://perma.cc/7QRN-D7Q4]. The bill was named for a Syrian photographer with the pseudonym of Caesar who provided photographs of atrocities committed by the Assad regime. U.S. House of Representatives Comm. on Foreign Affairs Press Release, Engel Welcomes Senate Action on Syria Sanctions Bill (Sept. 26, 2018), at https://foreignaffairs.house.gov/2018/9/engel-welcomes-senate-action-on-syria-sanctions-bill [https://perma.cc/FN4M-23EU].

17 H.R. 1677, 115th Cong. § 102 (2018). The text as reported to the Senate is available here: https://perma.cc/PY38-GVD7.

18 Id., § 103.

19 All Actions H.R.1677 — 115th Congress (2017–2018), Congress.Gov, at https://www.congress.gov/bill/115th-congress/house-bill/1677/all-actions?overview=closed#tabs [https://perma.cc/P9UL-T6MA].

20 Iraq and Syria Genocide Relief and Accountability Act, Pub. L. No. 115-300 (2018) [hereinafter ISGRAA]; White House Press Release, President Donald J. Trump Signed H.R. 390 into Law (Dec. 11, 2018), at https://www.whitehouse.gov/briefings-statements/president-donald-j-trump-signed-h-r-390-law [https://perma.cc/KJJ4-BJUF].

21 ISGRAA, supra note 20, § 5(a).

22 Julian Borger & Martin Chulov, Trump Shocks Allies and Advisers with Plan to Pull U.S. Troops Out of Syria, Guardian (Dec. 19, 2018), at https://www.theguardian.com/us-news/2018/dec/19/us-troops-syria-withdrawal-trump. Just days before, Trump had noted to congressional leadership that as “part of a comprehensive strategy to defeat [ISIL], United States Armed Forces are conducting a systematic campaign of airstrikes and other necessary operations against [ISIL] forces in Iraq and Syria.” White House Press Release, Text of a Letter from the President to the Speaker of the House of Representatives and the President Pro Tempore of the Senate (Dec. 7, 2018), at https://www.whitehouse.gov/briefings-statements/text-letter-president-speaker-house-representatives-president-pro-tempore-senate-5 [https://perma.cc/YQ4T-2P8R] [hereinafter Letter to Congress] (sending letter to Congress pursuant to Trump's War Powers Resolution duty, 50 U.S.C. § 1543(c), to keep Congress informed about deployments of U.S. forces equipped for combat).

23 Donald J. Trump (@realDonaldTrump), Twitter (Dec. 19, 2018, 6:29 AM), at https://twitter.com/realDonaldTrump/status/1075397797929775105 [https://perma.cc/JT3S-GN3L].

24 Trump Video Announcement, supra note 2.

25 Rukmini Callimachi & Eric Schmitt, Splitting with Trump Over Syria, American Leading ISIS Fight Steps Down, N.Y. Times (Dec. 22, 2018), at https://nyti.ms/2RcP5pk. He further stated that he “ultimately concluded that [he] could not carry out these new instructions and maintain [his] integrity.” Id.

26 Daniel Bush, Read James Mattis’ Full Resignation Letter, PBS (Dec. 20, 2018), at https://www.pbs.org/newshour/politics/read-james-mattis-full-resignation-letter. The letter is permanently available here: https://perma.cc/974Q-W78E.

27 Id.

28 Lindsey Graham (@LindseyGrahamSC), Twitter (Dec. 19, 2018, 6:27 PM), at https://twitter.com/LindseyGrahamSC/status/1075578496733364226 [https://perma.cc/5NWL-SK97].

29 Id.

30 Strengthening America's Security in the Middle East Act of 2019, S.1, 116th Cong. § 408(a) (2019). Twenty-five Democrats voted for the bill while twenty-two voted against it, signaling that it may be possible for the bill to pass in the Democrat-controlled House. Marianne Levine, Senate Passes Middle East Policy Bill that Rebukes Trump, Politico (Feb. 5, 2019), at https://www.politico.com/story/2019/02/05/senate-passes-middle-east-policy-bill-1147816. Trump recently announced in his State of the Union Address that as his administration makes progress in peace negotiations with the Taliban, “we will be able to reduce our troop's presence [in Afghanistan] and focus on counterterrorism.” White House Press Release, Remarks by President Trump in State of the Union Address (Feb. 5, 2019), at https://www.whitehouse.gov/briefings-statements/remarks-president-trump-state-union-address-2 [https://perma.cc/PJ6Q-688F].

31 Nordland, supra note 7.

32 Id.

33 Id.

34 Syrian Democratic Forces Press Release, To the Public Opinion (Dec. 20, 2018), at http://sdf-press.com/en/2018/12/to-the-public-opinion-5 [https://perma.cc/TC67-V8JP].

35 Neil MacFarquhar & Andrew E. Kramer, Putin Welcomes U.S. Withdrawal from Syria as “Correct,” N.Y. Times (Dec. 20, 2018), at https://nyti.ms/2RfTrw9.

36 Erin Cunningham & Louisa Loveluck, Turkey's Erdogan Delays Operation Against Kurdish Forces in Syria, Wash. Post. (Dec. 21, 2018), at https://www.washingtonpost.com/world/middle_east/turkeys-erdogan-delays-operation-against-kurdish-forces-in-syria/2018/12/21/ea505452-418f-4d98-bc7d-7ae527c46d18_story.html.

37 White House Press Release, Remarks by President Trump to Troops at Al Asad Air Base, Al Anbar Province, Iraq (Dec. 26, 2018), at https://www.whitehouse.gov/briefings-statements/remarks-president-trump-troops-al-asad-air-base-al-anbar-province-iraq [https://perma.cc/E7MU-V4A6] [hereinafter Trump Remarks to Troops].

38 U.S. Dep't of State Press Release, Senior State Department Officials Previewing Secretary Pompeo's Upcoming Trip to the Middle East (Jan. 4, 2019), at https://www.state.gov/r/pa/prs/ps/2019/01/288333.htm [https://perma.cc/XPM2-49JX] [hereinafter Briefing on Middle East Trip].

39 Trump Remarks to Troops, supra note 37. In Iraq, U.S. forces have been “advising and coordinating with Iraqi forces and providing training, equipment, communications support, intelligence support, and other support to select elements of the Iraqi security forces, including Iraqi Kurdish Security forces.” Letter to Congress, supra note 22.

40 U.S. Dep't of State Press Release, Interview with Wilfred Frost of CNBC (Jan. 7 2019), at https://www.state.gov/secretary/remarks/2019/01/288346.htm [https://perma.cc/MLC2-YAT4].

41 Briefing on Middle East Trip, supra note 38.

42 Steve Holland, Bolton Says Turkey Must Not Attack Kurdish Fighters Once U.S. Leaves Syria, Reuters (Jan. 6, 2019), at https://www.reuters.com/article/us-mideast-crisis-usa-syria/bolton-says-turkey-must-not-attack-kurdish-fighters-once-u-s-leaves-syria-idUSKCN1P0090.

43 U.S. Dep't of State Press Release, Remarks to Press (Jan. 7, 2019), at https://www.state.gov/secretary/remarks/2019/01/288349.htm [https://perma.cc/K8Z8-VD95].

44 Annie Karni & Thomas Gibbons-Neff, 200 U.S. Troops to Stay in Syria, White House Says, N.Y. Times (Feb. 21, 2019), at https://www.nytimes.com/2019/02/21/world/middleeast/us-troops-syria-.html (reporting that “the move was aimed at encouraging France and Britain to keep troops in Syria, as well as to help secure a safe zone near the Turkish border”).