Note: This article uses in-text citations, for which full references are provided at the end of the article.

In order to protect U.S. citizens, the U.S. must maintain its current policy of remaining a non-signatory to the International Criminal Court (ICC). Signing the Rome Statute would greatly endanger both U.S. military forces and U.S. sovereignty due to the many definitions of acceptable behavior and justice that exist among the treaty signatories.

Background on the Policy Issue

The International Criminal Court was created on July 1, 2002 by the Rome Statute of the International Criminal Court, and officially located in The Hague, Netherlands, although proceedings may take place in any location (International Criminal Court, 2010). The U.S. became involved with the organization when President Bill Clinton signed the Rome Statute on December 31, 2000, though he did not present it to the Senate for ratification and advised that his successor not submit it either (Schafer, 1998).

President Clinton stated “The United States should have the chance to observe and assess the functioning of the Court, over time, before choosing to become subject to its jurisdiction.” and cited the reason for his signature “With signature... we will be in a position to influence the evolution of the Court. Without signature, we will not.” (Driscoll, 2004, 150) However, he stated “I will not, and do not recommend that my successor submit the Treaty to the Senate for advice and consent until our fundamental concerns are satisfied” (American Service-Members’ Protection Act, 2003). President Bush “un-signed” the treaty in 2002 citing “significant flaws” that threaten the rights of American citizens as well as legitimate U.S. military operations (Schafer, 1998). As of October 2009, there were one hundred and ten member-nations of the court, with thirty eight nations having signed the treaty without ratification (International Criminal Court, 2010).

According to its charter, the ICC is intended as a court of last resort, using the principle of complementarity to establish that the court has jurisdiction only in cases where the nation refuses to prosecute the case on their own soil or is unable to do so (International Criminal Court, 2010). The court possesses jurisdiction only over cases involving genocide, war crimes and crimes against humanity, although there has been discussion of adding “aggression” as a crime prosecutable by the court (ibid.). Currently, ICC jurisdiction extends to individuals from countries that are not party to the Rome Statute if the alleged crimes occur on the territory of the ICC party state, the non-party government invites the jurisdiction of the court, or the U.N. Security Council refers the case to the ICC (ibid.).

Because the U.S. considers the jurisdiction of the court to infringe upon the rights of American citizens overseas, especially those in the military, it passed the American Service Member’s Protection Act of 2002 (ASPA). This act restricts U.S. interaction with the ICC and its signatories (Mirra, 2008, 134). Marc Grossman, Under Secretary for Political Affairs at the State Department, explained the position of the Bush Administration when he stated that the Rome Statute “Creates a prosecutorial system that is an unchecked power” and “Threatens U.S. sovereignty” (Driscoll, 2004, 152). As a result of this position, the U.S. has sought to form Article 98 Agreements with as many nations as possible to guarantee that they will not surrender, extradite or transfer U.S. persons to the ICC for the purpose of prosecution without U.S. consent (ibid., 189).

Under the administration of Barack Obama, the U.S. envoy for war crimes stated “Our government has now made the decision that Americans will return to engagement with the ICC,” referring to the U.S. decision to return to the court as an observer (BBC World News, 16 November 2009). He continued: “There remain concerns about the possibility that the United States, upon whom a great deal of the world relies for security, and its service members might be subjected to politically inspired prosecutions” (ibid.). However, Secretary of State Hillary Clinton stated that it is a “great regret” that the U.S. is not yet a signatory to the ICC (Clarke, 2009). This is surprising because her husband, former President Clinton, did not recommend that the U.S. become a signatory during his term in office or the subsequent term (Schaefer, 1998).

Current U.S. Policy

The current U.S. policy on the ICC is one of assistance by continued apprehension. According Harold Hongju Koh, Legal Adviser to the U.S. Department of State “The Obama Administration has been actively seeking ways that the U.S. can, consistent with U.S. law, assist the ICC in fulfilling its historic charge of providing justice” (Koh, 2010). U.S. Ambassador Rapp announced that he would like to meet with the ICC Prosecutor to determine how we might support current prosecutions underway in the Democratic Republic of Congo, Sudan, Central African Republic, and Uganda (ibid.).

According to the State Department, the U.S. has a number of serious concerns regarding the crime of aggression, which is a jus ad bellum crime, based on acts committed by the state as opposed to the jus in bello crimes of genocide, war crimes and crimes against humanity, which are based on acts of specific individuals (ibid.).

Currently, the U.S. objects to the Rome Statute on five grounds. First, the Rome Statute has jurisdiction over nationals of non-parties; second, politicized prosecution may occur; third, the prosecutor may not be held accountable for his prosecution; fourth, the court might usurp the role of the U.N, Security Council; and fifth, the lack of due process guarantees by the court (Elsea, 2006).

Strengths of Current U.S. Policy

Currently, the U.S. has moved to take a proactive role in aiding international justice while endangering neither its armed forces nor national sovereignty. Undoubtedly, the U.S. appreciates the necessity for an international body which serves to promote justice in the international realm. However, as the world’s greatest economic and military power, the U.S. is expected to practice humanitarian intervention more widely than any other ICC signatory, putting it at much greater risk. Michel P. Scharf, Director of the Cox Center War Crimes Research Office at Case Western Reserve University Law School stated that “The United States’ unique position renders U.S. personalities uniquely vulnerable to the potential jurisdiction of an international criminal court” (Driscoll, 2004, 174). While one hundred and eleven other states might feel that it is in their best interest to become signatories to the ICC, it is clear that they do not have the same vulnerabilities that the U.S. possesses in terms of deployed armed service members and global involvement.

The U.S. also preserves national sovereignty by refusing to become a party to the Rome Statute, because the Rome Statute is in violation of international law as it has traditionally been understood (Schaefer, 2009). Article 34 of the Vienna Convention on the Law of Treaties clearly states “A treaty does not create either obligations or rights for a third State without its consent” (ibid.). Because the Rome Statute allows jurisdiction to be granted through the nation where the crime takes place rather than the nation of the accused, it clearly creates obligations for a third state to extradite criminals without their consent upon indictment of their citizen or citizens by the court.

While some may counter that the crimes covered under the Rome Statute are already prohibited under “universal jurisdiction” or other treaties to which the U.S. is already a party, it is nonetheless imperative that the U.S. remain a non-signatory, due to the upcoming Assembly of States’ Parties that may significantly alter the Statute (Elsea, 2006). If the Statute is altered to include the crime of aggression, the Statute would then fall outside the realm of crimes already under universal jurisdiction, and create an unnecessary threat to U.S. sovereignty.

The Rome Statute states that “The Court shall exercise jurisdiction over the crime of aggression once a provision is adopted in accordance with articles 121 and 123 defining the crime and setting out the conditions under which the Court shall exercise jurisdiction with respect to this crime” (International Criminal Court, 2010). It further states that “Such a provision shall be consistent with the relevant provisions of the Charter of the United Nations” (ibid). At each Assembly of States’ Parties since the establishment of the Rome Statute, the parties have attempted to establish a definition of the crime of aggression and appropriate conditions for jurisdiction (ibid).

No agreement has been reached as of the most recent Assembly of States’ Parties held in November 2009 in The Hague, Netherlands (International Criminal Court, 2010). The Review Conference of the Rome Statute held on June 6, 2010 stated that the views of the delegations on aggression have “continued to diverge” on two key issues; first, whether or not the aggressor State must have accepted the Court’s active jurisdiction over this crime, and second, how the court should proceed in investigating a crime of aggression when the Security Council does not agree that a crime of aggression has occurred (ibid).

Although serious concerns exist, it is possible for the U.S. to engage with the ICC as a non-signatory. The U.S. can accomplish this through sharing its unparalleled diplomatic and intelligence resources such as unclassified reports and satellite images to help build cases (Kraus, 2010). It can use soft power to encourage the cooperation of other nations (ibid.). Additionally, the U.S. can practice engagement through the referral of serious cases to the ICC as a member of the Security Council and participate as an observer in the Assembly of States’ Parties, a step the U.S. has already taken (ibid.).

Because our armed service members are an important reason our nation is able to enjoy the freedoms we are blessed with, it is imperative that their protection be our first priority. The Armed Service-Members’ Protection Act states “The United States Government has an obligation to protect the members of its armed forces, to the maximum extent possible, against criminal prosecutions carried out by the International Criminal Court” (American Service Members’ Protection Act, 2003). The U.S. is correct in allowing service members to be subject only to pre-established domestic military court-martials in the cases of misconduct, and refusing to allow them to be tried in foreign court systems where their rights both as soldiers and American citizens may be revoked (ibid.). If the U.S. wishes to maintain the level of recruitment required for national security, it is critical that they make every effort to secure the rights of these men and women. It is reasonable to conclude that if prospective service members were aware that following orders to complete a legitimate military mission might land them in The Hague awaiting trial for their own actions, there would be a drop in recruitment for the U.S. forces. Because of this important factor, the U.S. is correct in remaining a non-signatory of the ICC, passing the ASPA and seeking Article 98 Agreements with as many nations as is feasible.

Weaknesses of Current U.S. Policy

Although the current policy ensures national sovereignty while allowing us to serve the nations around us, it is not without flaws. Some of the key concerns regarding the current policy include our image in the international community as advocates for justice, accusations of hypocrisy as member of a U.N. Security Council that can recommend cases before the ICC while unwilling to subject ourselves to its jurisdiction, and the ICC’s past record of trying only legitimate criminals.

Because members of the global community vary dramatically in population, military, economy and government structure, each has different policy goals they wish to achieve. Some claim that the U.S. wishes to cover up atrocities committed by foreign soldiers trained by the U.S. Joint Combined Exchange Training Program (JCET) (Mirra, 2008, 134); and believe that if the U.S. truly desired justice they would themselves submit to the jurisdiction of the ICC.

If the U.S. joined the ICC, it would be wise to cease participation in missions that may create liability, due to the proposed statute regarding aggression. According to Harold Koh, a Legal Adviser for the U.S. Department of State, the crime of aggression is a jus ad bellum crime based upon acts committed by the state, as opposed to the currently existing jus in bello crimes of genocide, war crimes and crimes against humanity which are based upon acts committed solely by individuals (Koh, 2010). The feasibility and legality of adding the crime of aggression remains to be seen as the Assembly of States’ Parties convenes later in 2010 to discuss this amendment (International Criminal Court, 2010).

In the event that the U.S. ceases participation in missions that may create liability, the global community would be losing one of its most ardent supporters of human rights, evidenced by our intervention in numerous global crises in an effort to lay the foundation for peace. The U.S. is better suited to perform the role of an observer and adviser to the ICC, providing resources such as intelligence that will enhance the judicial process for less developed nations. As members of the U.N. Security Council, it is our duty to assist less developed nations, while recognizing that the needs of many nations vary according to their stage of development. In regards to accusations of hypocrisy as members of a U.N. Security Council that refers cases to the ICC, the U.S. has consistently maintained that it is both willing and able to try all cases of genocide, war crimes and crimes against humanity in its own court system and issue strict punishment to the offender. This is in compliance with the principle of complementarity set forth in the ICC charter (Kleffner, 2008, 2).

Evidence of this lies in the frequent military court-martials that occur for inappropriate treatment of detainees, such as Specialist Charles Graner (Associated Press, 2005), sentenced to ten years in federal prison for abuse of detainees at Abu Ghraib Prison in Iraq, Private First Class Lynndie England, sentenced to three years confinement for abuse of detainees at the same facility (Associated Press, 2005), and Private First Class Steven Green, sentenced to life in prison without the possibility of parole after raping and killing a fourteen year old Iraqi girl and killing her family (Associated Press, 2009).

As a nation that possesses a well developed legal system and allows freedom of the press to expose scandals to the public, the United States qualifies as both willing and able to prosecute ICC crimes fairly in domestic court. However, in cases such as the nation of Sudan which lacks a stable and legitimate legal system and is led by Al-Bashir, a known perpetrator of genocide in Darfur, many feel it is the duty of the U.S. to support the ICC in its investigation that can be more justly carried out in ICC courts than in Sudanese courts.

Since the indictment of Al-Bashir, ICC president Judge Sang-hyun Song stated “The U.S. government has ended its antagonistic stance towards the ICC and the key phrase that their officials use is having a ‘positive engagement’ with us.” (Reuters, 2010). The U.S. might fulfill this promise of positive engagement by sharing intelligence resources with the ICC, as US intelligence agencies have likely collected evidence of crimes committed in Darfur through advanced intelligence techniques (Copple and Pena, 2007). As a member of the U.N. Security Council, the U.S. can also report lack of cooperation by Sudan to the Security Council and recommend that sanctions be applied to encourage cooperation (ibid.).

The Obama administration has been “fully supportive” of the ICC decision to indict al-Bashir on five counts of crimes against humanity. However, US Envoy to Sudan retired Maj. General J. Scott Gration has stated that the administration’s position will make his mission more difficult, calling for the U.S. to “Realize that (in) resolving the crisis in Darfur and [the] south, issues of oil, and combating terrorism at one hundred percent, we need Bashir” (The Washington Post, 2010).

Although the U.S. acknowledges the legitimacy of the charges the court has brought before individuals in the past, the U.S. cannot jeopardize its national security by joining a body that is rapidly evolving to expand its scope of jurisdiction to include crimes of aggression. Because many legitimate U.S. military operations could be classified as acts of aggression by the ICC, the U.S. cannot become a signatory at the present time. Rather than join and then hastily withdraw when amendments are added to the Rome Statute, it is in the best interest of both national security and national image to remain an observer of the court, offering resources and expertise at its request.

Policy Recommendations

The best course of action for the U.S. to pursue is to remain a non-signatory of the Rome Statute and retain its status as an observer at the ICC. In order to protect U.S. service men and women, it is important that the U.S. continue to seek Article 98 Agreements with as many nations as politically feasible. If the U.S. does see fit to join the ICC at some future date, they should still maintain these Article 98 Agreements because they are consistent with the Rome Statute and would provide valuable protection of U.S. sovereignty (Schaefer, 2009).

Inherent flaws in the ICC provide evidence that the current U.S. policy is sound. First, the U.S. feels strongly that any statute which finds it acceptable to exercise authority over non-signatories is in violation of international law (Driscoll, 2004, 183). Despite the claim that the ICC has jurisdiction over persons, not states, it is clear that it is the duty of a nation to protect the rights of its citizens, especially members of its armed forces carrying out assigned orders, from international detainment and prosecution (Elsea, 2006). The current principle of “territoriality” for which the nation where the crime was committed has the authority to extradite the offender, regardless of his country’s signatory status, has led the U.S. to prohibit aid to any to any ICC signatories, except NATO members and those who sign Article 98 Agreements (Driscoll, 2004, 133).

In addition to the court’s claim of a universal jurisdiction in certain cases, the U.S. is troubled by the possibility of politicized prosecution. Because many nations including the U.S. are pursuing foreign policy goals that other states find offensive, it is the concern of the U.S. that the vague language of the Rome Statute could allow the court to be used as an instrument of political policy rather than social and humanitarian justice. The ICC Statute gives the court jurisdiction over “serious” war crimes that represent a “policy” by the state, language that could be quite condemning to the U.S. if aggression is added to the list of prosecutable offenses (ibid., 175). Some would defend the court on the basis that it claims to practice the principle of “complementarity”, or only possessing jurisdiction in the case that the country is unable or unwilling to hold its own trial (Kleffner, 2008, 194). However, the ICC website defines “unwilling” as “clearly shielding someone from ICC crimes”, an accusation that would likely be brought against the U.S. government for defending American military personnel in the event that aggression is added to the list of ICC crimes (International Criminal Court FAQ, 2010).

Because the fairness of any ICC trial would depend greatly upon the integrity of the prosecution, the U.S. is highly concerned that the ICC prosecutor may not be held accountable for his actions. When a prosecutor acts dishonestly domestically, (for example, D.A. Mike Nifong in the Duke lacrosse case), it is possible to disbar the attorney and sentence them to jail time (CNN Law Center, 2007). In the case of the ICC, removal of the prosecutor would be much more difficult and political, and would almost certainly be opposed by other powerful nations. One U.S. official expressed concern that the independent ICC prosecutor might act as an “international Ken Starr” (Driscoll, 2004, 174). While some would cite the annual required Assembly of States Parties as an ample opportunity to dismiss a dishonest or incompetent prosecutor, it is clear that an annual assembly might not be capable of removing a dishonest prosecutor in sufficient time to prevent unjust charges from being brought against the defendant. The Assembly of States Parties is currently the only way to remove a rogue prosecutor, as an effort to give the U.N. Security Council a check on “overzealous” prosecutors to prevent politicized prosecution was struck down.

Accompanying concerns regarding the removal of the prosecutor, further concerns exist regarding the ICC’s authority relative to that of the U.N. Security Council. Although it can be argued that all state parties will have the opportunity to vote on the definition of aggression, and that such a definition must comply with the U.N. charter, it is unlikely that the numerous members of the ICC would define aggression in the same sense that the five Security Council Members would (Elsea, 2006). Once a definition is established, it would become a statute of the court not subject to alteration by the Security Council, effectively undermining its authority to prevent cases of alleged aggression from being brought before the court.

The final reason for the U.S. policy of remaining a non signatory of the court is concern regarding the lack of due process guarantees. Although the American Bar Association states that the ICC contains rights and protections for the accused that are “fundamentally equivalent” to those provided in the constitution (Mirra, 2008, 132), Henry Kissinger states “Defendants will not enjoy due process as understood in the United States” (Driscoll, 2004, 99). Although many cite the military courts-martial as a constitutional example of trial by a panel, it is clear that current U.S. servicemen and women have chosen a career of military service and have voluntarily consented to be tried under such circumstances should accusations arise against them. The constitutional right to a trial by “an impartial jury of the state and district wherein the crime shall have been committed” guaranteed in the sixth amendment of the U.S. Constitution is one that the ICC does not intend to provide for any that fall under its jurisdiction (The United States Constitution, 1787).

Because of these objections, the U.S. has sought to protect its citizens and sovereignty by remaining a non-member of the treaty. It has sought this protection through the passage of the Armed Service Members’ Protection Act of 2002, and the formation of Article 98 Agreements with other nations. By monitoring the processes of the court as an observer, the U.S. hopes to support the court as in instrument of international justice without bringing itself under its jurisdiction.

Because the Legal Adviser to the U.S. Department of State has cited “strongly held, yet divergent, views on many fundamental and unresolved questions” among State’s Parties to the Court, it is important for the U.S. to remain a non-party to such a philosophically heterogeneous court (American Service Members’ Protection Act, 2003).

From an LDS perspective, it is important that we not enter into any agreements that might compromise the constitutional rights of our citizens, since the Lord has told us in Doctrine and Covenants section 101 verse 80 “I established the Constitution of this land” (The Church of Jesus Christ of Latter-Day Saints, 2010). President M. Russell Ballard has stated “...the rights and privileges guaranteed in the Constitution are God-given, not man-derived. (Ballard, 1992)” President Gordon B. Hinckley has stated that our constitution has become “a model for other constitutions” (Hinckley, 2002).

Because it is a document possessing both divine approval and long-term secular success, it is a document that should be the standard for justice in the international community. Therefore, nations whose constitutions are in harmony with U.S. principles would lose rights by becoming a party to the Rome Statute, while those lacking a developed constitutionally based legal system have much to gain through access to a structured though less ideal system. For this reason, it is imperative that the U.S. support International Criminal Court jurisdiction in those nations whose governments have not yet embraced the divinely-ordained legal principles of the U.S. Constitution.

In conclusion, the U.S. must not become a party to the Rome Statute for reasons of its jurisdiction over nationals of non-parties, possibility of politicized prosecution, lack of prosecutor accountability, potential usurpation of U.N. Security Council authority, and lack of due process guarantees. The U.S. should not be intimidated by accusations of a poor national image, hypocrisy, or lack of respect for the court’s record. Rather, the U.S. must abstain from membership on the court in order to preserve its ability to serve the developing world while protecting its sovereignty. Doing so will allow us to continue as good neighbors in the international community, and to raise as an ensign of freedom to the world the U.S. Constitution and its God-ordained rights.

REFERENCES

Associated Press. 2005. Graner gets 10 years for Abu Ghraib abuse. [Online] Available from http://www.msnbc.msn.com/id/6795956/. 1 April 2010

Associated Press. 2005. England sentenced to 3 years for prison abuse. [Online] Available from http://www.msnbc.msn.com/id/9492624/. 1 April 2010

Associated Press. 2009. Ex-GI convicted of raping, killing Iraqi girl. [Online] Available from http://www.msnbc.msn.com/id/30628635/. 1 April 2010

BBC World News. 2009. U.S. to resume engagement with ICC. [Online] Available from http:// news.bbc.co.uk/2/hi/8363282.stm. 1 April 2010

Ballard, M. Russell. 1992. Religion in a Free Society. [Online] Available from http://www.lds.org/, 16 August 2010

Clarke, David. 2009. U.S. to attend Hague court meeting as an observer. [Online] Available from http://www.reuters.com/article/idUSLG395050. 1 April 2010

CNN Law Center. 2007. Duke lacrosse prosecutor disbarred. [Online] Available from http://www.cnn.com/2007/LAW/06/16/duke.lacrosse/. 1 April 2010

Copple, Gideon and Mariana Pena. 2010. Questions and answers on the ICC Darfur investigation. [Online] Available from http://www.amicc.org/docs/Darfur%20Q&A.pdf . 1 April 2010

Driscoll, William. 2004. The international criminal court: Global politics and the quest for justice, New York: The International Debate Education Association Bureau of Political-Military Affairs. 2003.

American service-members’ protection act. [Online] Available from http://www.state.gov/t/pm/rls/othr/misc/23425.htm. 1 April 2010

Elsea, Jennifer K. 2006. U.S. policy regarding the international criminal court. [Online] Available from http://italy.usembassy.gov/pdf/other/RL31495.pdf. 1 April 2010

Hinckley, Gordon B. 2002. The Times in Which We Live. [Online] Available from http://www.lds.org ,16 August 2010

International Criminal Court. 2010. About the court. [Online] Available from http://www.icc-cpi.int/Menus/ICC/About+the+Court/. 1 April 2010

International Criminal Court. 2010. Review Conference of the Rome Statute. [Online] Available from http://www.icc-cpi.int/iccdocs/asp_docs/RC2010/RC-WGCA-3-ENG.pdf. 16 August 2010

International Criminal Court. 2010. Doesn’t “complementarity” mean that the international criminal court can never prosecute if a country holds its own trial? [Online] Available from http://www.icccpi.int/menus/icc/about%20the%20court/frequently%20asked. 1 April 2010

International Criminal Court. 2010. Rome statute of the international criminal court. [Online] Available from http://www.icc-cpi.int/NR/rdonlyres/EA9AEFF7-5752-4F84- BE94-0A655EB30E16/0/Rome_Statute_English.pdf. 1 April 2010

Ingadottir, Thordis. 2003. The international criminal court: Recommendations on policy and practice, Ardsley: Transnational Publishers, Inc.

Jolly, Richard. 2009. UN ideas that changed the world, Bloomington: Indiana University Press

Karns, Margaret P. 2004. International organizations: The politics and processes of global governance, Boulder: Lynne Rienner Publishers

Kleffner, Jann K. 2008. Complementarity in the rome statute and national criminal jurisdictions, New York: Oxford University Press

Koh, Harold Hongju. 2010. The Obama administration and international law. [Online] Available from http://www.state.gov/s/l/releases/remarks/139119.htm. 1 April 2010

Kraus, Don. 2010. What is the international criminal court? [Online] Available from http://globalsolutions.org/files/general/what_20is_20icc.pdf. 1 April 2010

Mirra, Carl. 2008. United states foreign policy and the prospects for peace education, Jefferson: McFarland & Company, Inc.

Reuters. 2010. ICC chief: Sudan’s Bashir will face justice. [Online] Available from http://www.alertnet.org/thenews/newsdesk/LDE6231XB.htm. 1 April 2010

Safferling, Christoph J.M. 2001. Towards an international criminal procedure, Oxford: Oxford University Press

Schaefer, Brett D. 1998. The international criminal court: Threatening U.S. sovereignty and security [Online] Available from http://www.heritage.org/Research/Reports/1998/07/The-International-Criminal-Court. 1 April 2010

Schaefer, Brett D., Steven Groves. 2009. The U.S. should not join the international criminal court. [Online] Available from http://www.heritage.org/Research/Reports/2009/08/The-US-Should-Not-Join-the-International-Criminal-Court. 1 April 2010

The Church of Jesus Christ of Latter-Day Saints. 2010. The Doctrine and Covenants. [Online] Available from http://scriptures.lds.org/en/dc/101. 16 August 2010

The Washington Post. 2010. U.S. envoy to Sudan says Bashir indictment will make his job harder. [Online] Available from http://www.washingtonpost.com/wp-dyn/content/article/2010/07/21/AR2010072105664.html. 16 August 2010

Full Citation for This Article: Caruso, Anna (2010) "Should the US Accede to the Treaty Establishing the International Criminal Court?," SquareTwo, Vol. 3 No. 2 (Summer), http://squaretwo.org/Sq2ArticleCarusoICC.html, accessed [give access date].

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