said "paramilitary groups are responsible for numerous murders [...] and many of the human rights violations committed [in Colombia] generally."37 79. This situation has led the Commission to establish, for the purposes of determining the international responsibility of the State pursuant to the American Convention, that in cases in which the paramilitary and members of the Army conduct joint operations with the knowledge of higher-ranking officers, or when the paramilitary groups act with the acquiescence or collaboration of the Security Forces, it shall be considered that the paramilitary groups are acting as agents of the State.38 80. For its part, the Inter-American Court has ascertained, at various times and in different geographical contexts, the existence of ties between the Colombian Armed Forces and paramilitary groups. A combined review of cases decided on by the Commission and subsequently by the Inter-American Court points to the existence of a link between the paramilitary groups and members of the security forces in connection with violations of human rights, such as [extra]judicial executions, forced disappearances, cruel, inhuman, or degrading treatment, forced displacement, and so on. This link is evidenced through either acts of direct support, collaboration, or coordination or through omissions by members of teh security forces that have facilitated the actions of the paramilitary groups. Such cases include, but are not limited to: 19 Merchants,39 the Mapiripán Massacre,40 the El Aro and Ituango Massacres,41 and Cepeda Vargas.42 81. Specifically, in the case of the La Rochela Massacre, the Court summarized the grounds for assigning international responsibility to the State for acts committed by paramilitary. First, it reiterated the international responsibility of Colombia: 1) for having issued a legal framework that propitiated the creation of self-defense groups that turned into paramilitary groups; and ii) for failing to adopt all the measures needed to put an effective end to the situation of risk created by the State itself when it issued those provisions.43. Second, the Court pointed out that it had declared Colombia responsible because of its failure to meet its duty to provide guarantees by adopting effective prevention and protection measures for the civilian population that found itself in a situation of risk with regard to paramilitary groups that could reasonably have been foreseen by members of the Armed Forces or State Security.44 Third, the Court indicated that on several occasions it had found Colombia responsible for violations committed by paramilitary groups with the support, acquiescence, participation, and collaboration of members of the security forces.45 82. Recently, in the case of the Afro-descendant Communities displaced from the Cacarica River basin (Operation Genesis), the Court pointed out that "it is a well-known public fact that various decisions of Colombia’s high courts have referred to the connections existing between paramilitary groups and members 37 Cf. I/A Court H.R., Case of the “Mapiripán Massacre” v. Colombia. Preliminary Objections. Judgment of March 7, 2005. Series C No. 122, par. 96.18; I/A Court H.R., Case of the Ituango Massacres. Judgment of July 1, 2006. Series C No. 148, par. 125.23. 38 IACHR. Report No.. 37/00, Monseñor Oscar Arnulfo Romero y Galdámez, par. 64. IACHR. Report No. 75/06, Jesús María Valle Jaramillo, October 16, 2006, par. 63. 39 I/A Court H.R., Case of Blake v. Colombia. Merits, Reparations and Costs. Judgment of July 5, 2004. Series C No. 109 I/A Court H.R., Case of the “Mapiripán Massacre” v. Colombia. Merits, Reparations and Costs. Judgment of September 15, 2005. Series C No. 134 40 41 I/A Court H.R., Case of the Ituango Massacres v. Colombia. Preliminary Objection, Merits, Reparations and Costs. Judgment of July 1, 2006. Series C No. 148 42 I/A Court H.R., Case of Cepeda Vargas v. Colombia. Preliminary Objections, Merits, Reparations, and Costs. Judgment of May 26, 2010. Series C No. 213 43 165, par. 78. 44 165, par. 78. 45 165, par. 78. I/A Court H.R., Case of the Rochela Massacre v. Colombia. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. I/A Court H.R., Case of the Rochela Massacre v. Colombia. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. I/A Court H.R., Case of the Rochela Massacre v. Colombia. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No.