International Criminal Law and the UN Security Council - Research Paper Example

International Criminal Law and the UN Security Council Introduction This work, which is in five parts, discusses the relationship between the International Criminal Court and the United Nations Security Council. In addition, the functioning of these entities was also examined. The avowed objective of these two organizations is to promote international humanitarian law. However, the UN Security Council has on several occasions circumscribed the jurisdiction of the International Criminal Court (ICC). The first part, presents a synopsis of the relationship between the UN Security Council and the ICC. The second part, describes the method of establishment and objectives of these organisations in protecting international human rights; whilst the third part, dilates upon the controversy relating to their mutual coordination. The fourth part of this work presents a discussion on the examples that pertain to the working coordination between these two institutions. The last part presents recommendations and suggestions. Overview of the issue This part of the paper will present an over view of the issue regarding the relationship between the International Criminal Court and the United Nations Security Council. Relationship between the United Nations Security Council and International Criminal Court The UN Security Council plays a pivotal role in maintaining international peace and security. Its primary responsibility is to ensure international peace, and it endorses its authority to the ICC; thereby enabling the latter to prosecute criminals who attempt to destroy the peace in any member state. The ICC is supported by the Security Council in exercising its jurisdiction and prosecuting individual criminals. However, it is important to respect the rights of the States and individuals. The recent decisions of the Security Council affected the rights of State Parties and individuals. Therefore, both the ICC and the Security Council are required to safeguard the rights of those concerned1. The relationship between the ICC and the UN Security Council merits close monitoring. It should be established at the international level to impose restrictions on the decisions of the Security Council and the actions initiated by the ICC. This will provide accountability and transparency to the relationship between these two bodies. It would also promote equitable representation, which permits the intervention of the United Nations General Assembly in matters relating to international peace and security2. The International Criminal Court is expected to play a major role in deterring crimes against humanity and in promoting international peace. It is not a branch of the United Nations, and stands established by a treaty. However, it is intimately connected to the United Nations, whose Security Council can direct it to investigate specific issues. In addition, the UN Security Council can refer matters to the ICC for further action. However, the ICC retains its autonomy and cannot be controlled by the UN Security Council3. The relationship between the Security Council and the ICC is not confined to the Statute. Its coverage exceeds the Statute and invokes the principles of international law and other policy matters. One of these policy issues relates to the linkage between political bodies and judicial entities. The relationship between the ICC and the Security Council comes in to play, whenever political bodies attempt to behave as a quasi – judicial authority. In such situations, the areas of operation, ratione materiae, of the ICC and the Security Council overlap each other4. Establishment of the United Nations Security Council The United Nations has four principal organs. The Security Council is one such organ. The primary objective of the Security Council is to preserve international peace and security. It realized, in the very initial stages of its existence that justice is essential in establishing peace. Accordingly, the Security Council established several international tribunals, such as the ICTY and the ICTR. These tribunals were instituted in order to prosecute and punish individuals who had committed genocide, war crimes and crimes against humanity. Prosecution and punishment undoubtedly bring justice to the victims. This further advances the cause of peace5. As such, peace, security and well being of the world are the primary objectives of both the International Criminal Court and the United Nations Security Council. The efficient functioning of the ICC and its judicial integrity has to be ensured by the UN Security Council. In order to achieve that objective, the UN Security Council should restrict its involvement with and supervision of the ICC, and ensure that its role is not hindering the efficiency of the ICC6. To this end, the relationship between these two bodies has to be customized to establish a healthy relationship under which the ICC can work better than before. The Security Council can request the ICC to initiate an investigation if it finds the existence of a crime of aggression. This is one of the most important aspects of the relationship between these two entities. Thus, the Security Council can invoke the jurisdiction of the ICC, and therefore has the ability to cause the ICC to initiate action. Moreover, Article 39 of the UN Charter empowers the Security Council to determine whether there had been a breach of peace, a threat to peace or an act of aggression. In addition, the Charter authorizes the Security Council to provide guidelines or recommendations to states. Furthermore, it can initiate enforcement measures against intractable countries; and some of these measures could even employ force against the offending state7. At the moment, international justice seems to be unlikely. The powerful nations of the world, like the US, China and Russia have consistently, violated human rights and utilised their veto power to defeat any UN Resolution that seeks to indict them for such transgressions. For instance, the gross human rights violations in Chechnya, Abu Ghraib and Guantanamo Bay are least likely to be redressed8. In this manner, the permanent members of the UN Security Council have ignored the International Criminal Court (ICC), whilst simultaneously retaining their immunity from action against their breach of human rights Establishment of the International Criminal Court The International Court of Justice is an international judicial body that is seized with resolving disputes between countries. However, The ICC deals with war crimes, genocide and crimes against humanity perpetrated by military leaders and heads of government. According to the Statute, individuals like a Head of a State or Government, a member of government or national parliament, an elected representative, and a government official can also be prosecuted for crimes against humanity, even if such a person had been acting in an official capacity9. There is no exemption from criminal prosecution or criminal responsibility under this Statute. The ICC can initiate investigations in 106 countries, and the UN Security Council can act in a totally unbiased manner. This bestows a global character on the ICC. However, in practice, there is considerable prejudice, and several extraneous factors tend to exercise a countervailing influence10. The International Criminal Court can exercise its jurisdiction over crimes committed on the territories of the State Parties. It can prosecute individuals or state authorities who have committed crimes prohibited by the Statute, under which the ICC had been established. It has jurisdiction in the States that had ratified the Statute. As such, it can prosecute individuals who have committed genocide, war crimes and crimes against humanity in those member states, regardless of whether those individuals were the nationals of those states. However, such requirements are not deemed to be essential, if the UN Security Council refers a case to the ICC11. Moreover, the role of the ICC starts when the concerned State Party fails to initiate any investigation or action against the crimes committed on its territory. The State Party can request the ICC to investigate or prosecute if it is not in a position to do so or if it is unable to carry out such prosecution or investigation. The International Criminal Court is a permanent international judicial authority. More than fifty percent of the world nations had ratified the Statute of the ICC. The US adopted a well planned strategy to undermine the ICC, but its iniquitous efforts have not borne fruit. There has been mitigation in the opposition of the US to the ICC, on account of its realization that the ICC does not pose any threat to its activities12. The State Parties can directly refer cases to the ICC, and the Prosecutor of the ICC can bring cases before it for prosecution on his own initiative13. The UN Security Council has widespread authority over its Member States, upon whom its decisions are binding. As such, it can bring any case before the ICC; irrespective of the State Party, on any charge of crime that falls within the scope of the jurisdiction of the ICC. In such instances, the Security Council is not required to procure the consent of the pertinent nation, and its decision in such matters is final. If the Prosecutor had initiated action, then the ICC can exercise jurisdiction in respect of crimes committed in any State Party or by its citizens14. The ICC achieved its goals by prosecuting and punishing individuals who commit crimes that threaten the well being, security and peace of the world. Prosecution and punishment have two important outcomes. First, the immediate victims of these crimes receive justice; and second, such punishment acts as a deterrent to the commission of these crimes in the future15. Moreover, prosecution and punishment prevents retaliatory actions by the victims and their sympathizers. Divergence Between the United Nations Security Council and International Criminal Court The ICC and the United Nations strive to promote human rights and international humanitarian law. The very mandates of these two bodies indicate that they have similar objectives. As such, the relationship between them is well established by their respective mandates. The preamble to the Rome Statute states that the fundamental objective of the ICC is to erode the impunity for the perpetrators of crimes that are “unimaginable atrocities that deeply shock the conscience of humanity.” The previous century had witnessed such grave crimes, which had posed a serious threat to international peace and security. The well – being of the world had been jeopardized by those atrocities16. The establishment of the ICC resulted in widespread debate about the role of the UN Security Council in respect of prosecuting the crime of aggression. It had been argued by some theorists that the UN Charter required the Security Council to determine the occurrence of an act of aggression; prior to any prosecution. Nevertheless, it can be presumed that the UN Charter permits prosecution of the crime of aggression, in instances where there had been no previous findings of such crimes by the Security Council17. Adoption of Article 23 of the draft Statute in its entirety would have compelled the ICC, which by no stretch of the imagination can be construed to be an organ of the UN, to faithfully adhere to the instructions and injunctions of the UN Security Council. However, this Article has not been wholly adopted while designating the International Criminal Court. Such implementation would have forced the ICC to defer to the UN Security Council, while addressing issues pertaining to international peace and security. This would have seriously curtailed the functioning of the ICC, whose principal activity is the taking up of such cases18. The Security Council adopted Resolution 1422 in July 2002. By adopting this Resolution, the Security Council had limited the operational scope of the International Criminal Court. The Security Council required the ICC to discontinue any investigation or prosecution in States that was not a party to the ICC Statute. Specifically, the ICC should not initiate any investigation or prosecution of criminal acts or omissions by extant or past officials, during any operation sponsored or authorised by the United Nations. This request was made in accordance with the provisions of Article 16 of the ICC Statute. This initiative permits the Security Council to make requests in resolutions adopted under Chapter VII of the UN Charter, seeking a deferment of investigation or prosecution by the ICC for twelve months19. There are several exclusive determination schemes, wherein the Security Council has to determine that there had been an act of aggression. This is a precondition for prosecution with regard to that crime. However, these exclusive determination schemes are at divergence with some important principles of the UN Charter. Exclusive determination schemes weaken the sovereign status of countries. This, in turn, bestows an undesirable judicial role upon the Security Council. Moreover, they pose a threat to the Article 39 power of the Security Council in determining the existence of aggression20. It has been contended by some scholars that Article 39 of the UN Charter provides an exclusive determination scheme. This Article exclusively provides the power to the Security Council to the extent of determining aggression and suppressing it. Nevertheless, Article 39 cannot be interpreted as preventing other bodies from determining aggression outside the context of the Security Council’s power to suppress aggression21. The UN Charter allows other bodies to determine the crime of aggression in specific situations. Article 39 of the UN Charter indicates that it would be inappropriate to expect the Security Council to determine the existence of state aggression. The ICJ had in the past determined the existence vel non of aggression, by establishing an armed attack under Article 51 of the UN Charter as vel non of aggression22. Consequently, the ICC should seek the advice of the ICJ, while addressing instances of aggression. However, the absence of such advisory opinion should not hinder further proceedings. Similarly, the Security Council must be provided with additional powers, in respect of aggression cases, which transcend its powers to suspend the proceedings of the ICC under Article 16 of the ICC23. The reality is that it is impossible to introduce measures into the ICC Statute that would deprive them of the right to prevent prosecution of the crime of aggression The international tribunal for the erstwhile Yugoslavia was established by a UN Security Council resolution. Its principal objectives were to prevent war crimes and to prosecute the perpetrators of heinous transgressions in the former Yugoslavia. As such, the establishment of such tribunals is to deprive civilian and military leaders from immunity to punishment for crimes. Such withholding of immunity acts as a major deterrent to the recurrence of crimes against humanity. The essence of these goals is to ensure that the principal human rights offenders are prosecuted in a timely manner. In instances, where conflicts are in progress, investigation and necessary action should be taken as expeditiously as possible, in order to dissuade the perpetrators of such crimes24. Article 16 of the Rome Statute empowers the UN Security Council to request the ICC to defer an investigation or prosecution for a year, provided such request is made under the Chapter VII of the UN Charter powers. Requests for such deferment can be renewed by the UN Security Council, as long as the conditions that had necessitated the original request for deferment continue. In this manner, the UN Security Council exercises control over the ICC’s investigations25. Any request for a deferral by the UN Security Council has to be justified, in accordance with the stipulations in Article 16 of the Rome Statute. In accordance with Article 39 of the UN Charter, this implies that it should be the considered opinion of the UN Security Council that there had been threat to or breach of the peace, or that an act of aggression had transpired, which justifies the necessity of making such request to the ICC. Although the Security Council is empowered by Article 16 of the UN Charter to defer cases, the United Nations is the legal entity with whom this power has been vested. The Security Council merely exercises this right on its behalf. The UN Charter does not contain any specific provision that confers the right to defer proceedings upon the Security Council. Consequently, in July 2002, the Security Council adopted a Chapter VII Resolution, whereby it requested a deferral, in accordance with the provisions of Article 16 of the Rome Statute26. The immensity of the UN Security Council’s power can be estimated from the fact that it can call for a referral, whilst simultaneously abstaining from defraying the expenses incurred, which is at marked variance with the funding provisions of the Rome Statute. The undertaking of issues relating to peace and security by the ICC seems to be paradoxical. However, it is possible to rationalize the continuation of a criminal justice system, with the reason that in its absence chaos would reign supreme. Nevertheless, there is marked disparity between what should constitute the primary focus of a criminal court, namely to arrive at the guilt or otherwise of individual suspects, and being chiefly concerned with issues relating to collective security27. For instance, it was extremely doubtful whether prosecution by the ICC of the UN’s personnel and peacekeepers in Darfur would have an adverse effect on peace. Moreover, it was improbable that the abstention of prosecution of such personnel would engender peace and security in that place28. These reasons could have been cited by the ICC in contesting the UN Security Council’s deferral request, but such a challenge, on account of the vast discretionary powers of the latter, would have met with failure. While Article 13 of the Rome Statute permits the ICC to exercise jurisdiction, as a result of the Prosecutor’s initiative, referral by a State Party or the Security Council; Article 16 provides the Security Council with the right to pass a resolution that defers prosecution or investigation by the ICC. It has been contended by the US that Security Council’s principal duty of preserving peace and security at the international level, is hindered by the Rome Statute. The argument put forth by the US states that the possibility of the ICC initiating investigation or prosecution, in the absence of authorization by the Security Council, is tantamount to the subversion of the role to be enacted by the Security Council as provided for in the UN Charter29. This contention has been deemed to be specious, because it attempts to defeat the very purpose for which the ICC had been proposed. As such, the delegates at Rome were at pains to emphasize that subordinating the ICC to any political institution, especially the Security Council, would render the institution of the ICC meaningless. Rendering the ICC incapable of exercising independent authority, would be at variance with the cardinal democratic notion of independence of the judiciary. The US had attempted to reduce the ICC to a mere non – judicial institution30. Despite the justification for the Security Council to be the guardian of international peace and security, interference with the functioning of the ICC, would lead to serious travesties of justice. Subsequent to the Rome Statute, the UN Security Council was empowered to postpone an investigation or prosecution, in addition to making a referral to the ICC for taking up a case. Regarding the right of the Security Council to proscribe an investigation, some delegates at Rome submitted that only the Prosecutor should be permitted to initiate an investigation, subsequent to specific Security Council authorization. However, the majority of the States opposed this proposal, contending that this initiative would destroy the judicial independence of the ICC31. Moreover, it was held by some 11 States that the Security Council’s veto power should be rescinded. Such a measure would have gone a long way towards upholding the ICC’s judicial independence. However, the ICC would have been made totally unaccountable to the Security Council. A way out of this impasse was suggested by Singapore’s compromise proposal, which after a few unimportant changes, emerged as the final version of Article 1632. Instances Evidencing the Absence of Coordination Between the ICC and the UN Security Council It is an indisputable fact that the international community is beleaguered by inequity. A telling example of this is provided by the UN Security Council, whose permanent members exercise their veto power to further their selfish interests, even at the cost of vanquishing justice. The distinct bias apparent in international criminal law can be chiefly attributed to politicians, who exercise their power through the decision making bodies like the UN Security Council. Consequently, the blame for engendering discriminatory behaviour in international criminal law falls squarely on the shoulders of politicians, irrespective of their vehement declarations of ensuring national interests. With Kosovo, it became evident that the UN Security Council was not all that effective in preventing human rights violations and war crimes. Consequently, temporary criminal courts, establishment of immunity zones and a permanent tribunal to address atrocities, do not address all the problems thrown up by such incidents. There should be a popular demand for justice, which in turn would bring about the establishment of additional institutions. In the absence of such measures, the principal resistance to human rights violations would be provided by unilateral or multilateral interventions33. Such interventions have acquired sufficient notoriety, and their very legality has at times been suspect. In the main, such interventions have been seen to further vested interests There has always been a deep conflict between those who believe in achieving their objectives by the employment of force, such as the US; and countries like Canada that have clamoured for engendering the rule of law, all over the world. The International Criminal Court was instituted with the express objective of bringing to justice, perpetrators of crimes; such as war crimes, crimes against humanity and genocide. It steps in whenever the domestic judicial framework proves unequal to the task of investigating and prosecuting persons responsible for such grave crimes34. The ICC is also expected to deal with criminal aggression. However, this entailed concurrence by the nations regarding the definition of aggression The Council can request the ICC to delay or suspend prosecution proceedings. In July 2002, the Security Council adopted Resolution 1422, which served to grant immunity to US personnel for their acts of omission and commission in Bosnia and Herzegovina. However, the Resolution was not renewed in the year 2004, on account of strong opposition from France and several other members of the Security Council35. In an unexpected move, the Security Council referred the Darfur conflict to the ICC to initiate investigation and undertake necessary action. This development discloses the subtle relationship between the Security Court and the International Criminal Court; which has been strengthened by the efforts of the Council and frequent referrals. These developments engender optimism regarding the engagement of the issue of aggression36. This issue stands to be resolved in a satisfactory manner, and the rule of law and justice will prevail all over the world. The UN Security Council has established and directs the International Criminal Court in its operations. In accordance with the UN Charter only the Security Council has the power to establish international tribunals or courts. For instance, the Security Council established the ICTY and ICTR to deal with the atrocities and genocide in the former Yugoslavia and Rwanda, respectively. They are also international criminal courts established for the purpose of investigation and prosecution of perpetrators of crimes prohibited by international humanitarian law and for breach of human rights. The UN Security Council operates on the basis of universal concurrence of is members or veto by its permanent members37. As such, there can be no prosecution by the ICC, if any permanent member of the UN Security Council opposes it. This aspect renders the ICC vulnerable to criticism, because its opponents state that the Court lacks jurisprudence to address crimes and a proper legislature to define the components of a crime, beyond the Nuremberg Principles. In order to prevent arbitrary prosecutions by the ICC, a few Articles were introduced, which established a number of authorities. For instance, Article 53 sets out the Initiation of an Investigation. Article 15 establishes a Prosecutor, and Article 42 establishes the Office of the Prosecutor. In addition, Article 36 pertains to the Qualifications, Nominations, and Election of Judges; whilst Article 56 establishes the Role of the Pre-Trial Chamber. All these bodies act as gatekeepers for prosecutions by the ICC38. These gatekeepers play a very important role in the enforcement of human rights, by reducing the workload of the ICC. Such curtailment is essential, on account of the wide range of events, in which the ICC can intervene. The role of these gatekeepers is similar to that of the European Commission of Human Rights (ECHR)39. The apprehension, on the part of some countries, resulted in their seeking a predominant function for the Security Council in the Rome Statute. The chief concern was that the ICC would usurp the Security Council’s avowed task of preserving peace and security at the international level. Accordingly, a compromise was arrived at, whereby the Security Council was empowered to thwart ICC action. Article 16 of the Rome Statute states that the UN Security Council can adopt a resolution under its Chapter VII powers to defer an investigation or prosecution by the ICC for renewable periods of 12 months. This cannot be contested by the ICC, and it serves to prevent prosecution by the ICC, which could defeat diplomatic initiatives deemed to be essential for preserving international peace40. Conclusions The UN Security Council should ensure the implementation of international humanitarian law. The primary purpose of the United Nations is to protect and promote human rights; therefore, it is essential for the UN Security Council, as an organ of the United Nations, to protect human rights. In fact, it is the fundamental duty of the Security Council to strive for the promotion and protection of human rights, all over the world; hence, it should act in a manner that promotes human rights. The jurisdiction provided to the International Criminal Tribunal for the former Yugoslavia, confirmed that the primary objective of the United Nations was to ensure the proper implementation of international humanitarian law. Unfortunately, the UN Security Council is attempting to provide impunity to some of the countries that take part in the operations carried out by the United Nations. Such grant of impunity results in increased breaches of human rights on their territories and the infringement of international humanitarian law. As such, the UN Security Council is not authorised to provide such impunity. Arriving at a proper balance between judicial accountability and judicial independence is indispensable. In the context of the Security Council’s power to defer an investigation or prosecution, the Rome Statute has provided such balance. Although, the Security Council cannot be deemed to be a gatekeeper to the ICC, it can defer investigation or prosecution. It has been argued that the Security Council cannot abuse its power to postpone investigation or prosecution. There is no clash of interests between the ICC and the UN Security Council. It is the cardinal endeavour of the ICC to engender respect for human rights and international humanitarian law; which in turn, augurs well for freedom, justice and rule of law, and security. Furthermore, the ICC’s objective is to preserve international peace and buttress international security41. Consequently, it would be incorrect to describe the ICC as a judicial institution that merely attempts to deprive the perpetrators of serious crimes of impunity. The ICC and tribunals of the future stand to be accused of being partisan and therefore unequal to the task of dispensing justice impartially. This is borne out by the fact that some members of the RPF were indicted by the ICTR, while allowing the powerful and influential to escape prosecution. The Human Rights Commission became ineffective, with the spread of information that it was behaving in a biased manner. The founders of the UN had attempted “to save succeeding generations from the scourge of war, which twice in [their] lifetime has brought untold sorrow to mankind.” They wanted to prevent the recurrence of tyranny and crimes of aggression perpetrated during the Nazi regime. The heinous crimes, the indiscriminate killings of people, the barbaric and indiscriminate destruction of races and property, during that terrible period, were some of the worst moments in the history of mankind. These crimes should not be permitted to be perpetrated by any other individual42. All said and done, the fact remains that the UN Security Council does not permit the free and perhaps fair functioning of the ICC. The UN Security Council, specifically the permanent members, has its own commitments and vested interests to uphold. Thus, US and UK excesses in Iraq are merely glossed over, whilst the perceived crimes of a Saddam Hussein are accorded the maximum attention and subsequently, punished in an extreme and inhuman manner. Bibliography Adamantios Th. Vassilakis, 12 June 2003, The proposed renewal of the provisions of Security Council Resolution 1422 (2002), retrieved on 22 July 2009 from http://www.iccnow.org/documents/EUGreece1422Stmt12June03.pdf Clapham, Andrew., Damaska, Mirjan., Harmon, Mark., Morrison, Howard., Rishmawi, Mona., Møse, Erik., and Zappalà, Salvatore. (2009) ‘Discussion.’ Journal of International Criminal Justice 7, (1) 103 – 111 Daniel D. Ntanda Nsereko, (2007), The Relationship between the International Criminal Court and the United Nations Security Council, retrieved on 12 July 2009 from http://www.zis-online.com/dat/artikel/2007_13_186.pdf Dominic McGoldrick, Peter J. Rowe, Eric Donnelly. (March 2004) The permanent international criminal court 97, Hart Publishing Editors., (Jan., 1999) ‘Developments in International Criminal Law.’ The American Journal of International Law 93, (1) 2 Eileen Skinnider, March 2006, Ensuring the Independence of the International Criminal Court, retrieved on 22 July 2009 from http://www.icclr.law.ubc.ca/Publications/Reports/ES%20paper%20-%20ICC%20and%20China.pdf Elias O.; Quast A., 2003, The relationship between the Security Council and the International Criminal Court in the light of Resolution 1422 (2002), retrieved on 11 July 2009 from http://www.ingentaconnect.com/content/mnp/nail/2003/00000003/F0020002/art00001?crawler=true George P. Fletcher Cardozo, 1 July 2006, Criminal Law, The ICC – Two Courts in One?, Journal of International Criminal Justice, ICJ 43 (428) Heather Cash, Spring, 2007, Note: Security Council Resolution 1593 and Conflicting Principles of International Law: How the Future of The International Criminal Court Is At Stake. The University of Louisville Brandies Law Journal International Criminal Court (ICC), (2009), retrieved on 11 July 2009 from http://www.fidh.org/-ICC- Malgosia Fitzmaurice & Olufemi Elias, 2009, Contemporary issues in the law of treaties, Eleven International Publishing. Mark S. Stein, (2005), The Security Council, the International Criminal Court, and the Crime of Aggression: How Exclusive is the Security Council’s Power to Determine Aggression? Retrieved on 11 July 2009 from http://papers.ssrn.com/sol3/papers.cfm?abstract_id=888201 Roger Dittmann, 1998, The Statute Treaty Route to World Rule of Law and Global Human Rights: The Strategy to Establish the International Criminal Court, retrieved on 13 July 2009 from http://faculty.fullerton.edu/rdittmann/ICC/ICC18a.DOC Ronli Silfris, 2008, Weighing Judicial Independence against Judicial Accountability: Do the Scales of the International Criminal Court Balance?, Chicago-Kent Journal of International and Comparative Law. Tara Ashtakala & Fergus Watt, (2002), The war of words over the International Criminal Court: American “might” versus international “right”, retrieved on 6 July 2009 from http://www.ploughshares.ca/libraries/monitor/mond02f.html Vera Gowlland-Debbas, (2001), The Relationship between the Security Council and ICC, retrieved on 10 July 2009 from http://www.globalpolicy.org/component/content/article/164/28588.html Read More