130 | Towards the Closure of Guantanamo 323. The U.S. Office of the Director of National Intelligence regularly releases an unclassified “Summary of the Reengagement of Detainees Formerly Held at Guantanamo Bay, Cuba.” The last report, dated July 15, 2014, indicates that 17.3% of former detainees have “reengaged” in terrorist or insurgent activities, and that 12.4% are suspected of doing so. The numbers for those detainees transferred after January 22, 2009, (date of the adoption of new guidelines to govern the transfer of detainees) are considerably lower (6.8% and 1.1% respectively). 393 Accordingly, only six former Guantanamo detainees released after January 22, 2009, reportedly engaged in terrorist or insurgent activities. The names of the detainees have not been publicly released. The New America Foundation created a list of former detainees who have “returned to the battlefield.” According to this research, as of June 5, 2014, 3.6% of former Guantanamo detainees were reported to be engaging in militant activities against U.S. and non-U.S. targets (all of them released from Guantanamo before 2007) and 4.6% were suspected of doing so. 394 324. The IACHR notes with concern that by the end of 2014 there remained approximately 30 detainees who had once been charged but are not currently considered for prosecution or who were still under the category of “continued law of war detention” in an ever-evolving armed conflict. The IACHR is also troubled by the fact that those detainees with respect to whom the PRB determined that continued detention remained necessary (four as of December 2014) will have to wait three years until a new full review would be conducted. This means that some detainees will have to wait until 2018 to have their status reviewed. The IACHR notes that semi-annual file reviews only focus on new information or change of circumstances. 325. Finally, with regard to the risk of “recidivism,” the IACHR points out that the use of this term is erroneous. The term recidivism implies that the person has been convicted of a criminal offense and has reengaged in illegal conduct. These former Guantanamo detainees, however, have never been tried. 393 394 Office of the Director of National Intelligence, Summary of the Reengagement of Detainees Formerly Held at Guantanamo Bay, Cuba, as of July 15, 2014. Available at: http://www.dni.gov/files/documents/September_2014_GTMO%20Unclass%20Release.pdf New America Foundation, Appendix: How Dangerous are Freed Guantanamo Prisoners?, by Peter Bergen and Bailey Cahall, June 5, 2014. Available at: http://newamerica.net/publications/resources/2014/how_many_guantanamo_detainees_return_to_the_bat tlefield Organization of American States | OAS