By Alemayehu G. Mariam
Note: This is the fourth installment in a series of commentaries I intend to offer on U.S. foreign policy (or lack thereof as some would argue) in Ethiopia. In this piece, I argue that the Obama Administration’s recently announced Kleptocracy Asset Recovery Initiative to go after corruption in Africa and elsewhere could prove to be an extraordinarily effective tool to improve human rights on the continent. By focusing on corruption, the Obama Administration could reasonably demand good governance practices of African “leaders” while maintaining cooperation on counter-terrorism and security issues.
The Africa Kleptocracy Project
In June 2008, when presidential candidate Barack Obama was a few months away from electoral victory, I warned those dictators who survive by pickpocketing the American tax payer of the arrival of a “new sheriff” in town and advised them to clean up their acts and “shape up”[1]: “A new sheriff is coming to town. He does not carry a six-shooter but carries a law book. And he’s laying down the law for all the tin-pot dictators of the world.” In April 2009, I “read the tea leaves”[2] again and urged Africa’s panhandling dictators to “ride out before the big roundup” because the “new sheriff and posse are in town.” I am glad to say I read the tea leaves just right.
Barack’s Posse was a little late but finally showed up in Kampala, Uganda last week to lay down the law to Africa’s top kleptocrats (thieves masquerading as “heads of state”) gathered at their annual summit. President Obama’s “undersheriffs”, Attorney General (A.G) Eric Holder and Johnnie Carson, U.S. Assistant Secretary for African Affairs, told the huddled kleptocrats that a special Kleptocracy Asset Recovery Initiative (KARI) has been established in the U.S. Justice Department to recover the money they and their criminal cohorts have stolen from their citizens and restore it to its intended use:
I am pleased to announce that the U.S. Department of Justice is launching a new Kleptocracy Asset Recovery Initiative aimed at combating large-scale foreign official corruption and recovering public funds for their intended – and proper – use: for the people of our nations. We’re assembling a team of prosecutors who will focus exclusively on this work and build upon efforts already underway to deter corruption… I know that prosecution is not the only effective way to curb global corruption. We will continue to work with your governments to strengthen the entire judicial sector… We must also work with business leaders to encourage, ensure and enforce sound corporate governance. We should not, and must not settle for anything less… As many here have learned — often in painful and devastating ways — corruption imperils development, stability, competition and economic investment. It also undermines the promise of democracy… Like President Obama, I believe that the 21st century will be shaped by what happens here in Africa. Your security and prosperity, the health of your people and the strength of your civil society, will have a direct and profound impact on the world’s communities and on the advancement of human rights and human progress everywhere.
A couple of months ago, A.G. Holder addressing the 35-nation Organization for Economic Cooperation and Development in Paris said:
Put simply, corruption undermines the promise of democracy. It imperils development, stability and faith in our markets. And it weakens the rule of law. Corruption erodes, even destroys, the faith of citizens in their governments. As I speak, a corrupt official somewhere is enjoying undeserved and illegal proceeds. He may be driving a brand-new luxury car. She may be filling her off-shore bank account with tainted cash. They may be traveling first-class on all-expenses-paid holidays. Bribery in international business, for example, may center on shell companies and wire transfers, but no matter where — or how — it happens, the corrosive result is the same: stymied development, lost confidence and distorted competition. The result is unfairness, not justice; the consequence is economic decay, not development.
African Kleptocrats as Organized Criminals (Mafia)
In my commentary “Africorruption, Inc.”, I argued that the business of African governments is corruption.[3] In other words, the majority of African “leaders” seize political power to operate sophisticated criminal enterprises to loot their national treasuries and resources. President Obama’s approach to dealing with corrupt African governments is consistent with the informed view that corruption is not only the lifeblood of African dictatorships but also the most important single factor that accounts for gross violations of human rights and violent suppression of democratic institutions on the continent. Just like any organized criminal enterprise, be they street-level or Mafia-style gangsters, African kleptocrats have used threats, fear, intimidation and violence to maintain and perpetuate their corrupt financial empires. In that context, A.G. Holder’s announcement was nothing short of breathtaking. It was as though he was addressing the national convention of the “Commissione” of all the Mafia families from New York City, Chicago, Detroit, Miami, Atlantic City, Las Vegas, St. Louis, Los Angeles and Philadelphia. In Kampala, he was talking directly to the African equivalents of the Godfathers of the Bonnano, Columbo, Gambino, Genovese, and Lucchese crime families in one place. It was almost surreal.
Though A.G. Holder told the African kleptocrats that he has a posse of special corruption prosecutors saddled up, he omitted telling them what tools he would be using to bring them to justice. They can rest assured that he will be coming after them armed with the Racketeer Influenced and Corrupt Organizations Act (commonly referred to as the RICO Act or RICO; 18 U.S.C. § 1961–1968). RICO was originally enacted to prosecute the Mafia and others actively engaged in organized criminal activity. Over the years its use has been expanded to cover corporate and other crimes; and now its application is likely to be expanded even further to go after the corrupt and thieving African dictators who launder hundreds of millions of dollars every year in the U.S. buying businesses and homes and making “investments” in legitimate commercial enterprises. Section 1962 of RICO provides in part:
(a) It shall be unlawful for any person who has received any income derived, directly or indirectly, from a pattern of racketeering activity… to use or invest, directly or indirectly, any part of such income, or the proceeds of such income, in acquisition of any interest in, or the establishment or operation of, any enterprise which is engaged in, or the activities of which affect, interstate or foreign commerce. (b)… through a pattern of racketeering activity… to acquire or maintain, directly or indirectly, any interest in or control of any enterprise which is engaged in, or the activities of which affect, interstate or foreign commerce… (c) It shall be unlawful for any person employed by or associated with any enterprise engaged in, or the activities of which affect, interstate or foreign commerce, to conduct or participate, directly or indirectly, in the conduct of such enterprise’s affairs through a pattern of racketeering activity… (d) It shall be unlawful for any person to conspire to violate any of the provisions of subsection (a), (b), or (c) of this section.
Simply stated, African kleptocrats who rob their nations blind and bring their stolen loot to the U.S. to launder it will be tracked down and forced to disgorge and face jail time as well. What is potentially devastating to African kleptocrats is the fact that a RICO charge could be brought not only against them, but also their associates, business partners, investors, and any others in the U.S. or elsewhere who “directly or indirectly” facilitate their criminal enterprises. The penalties are severe: up to $25,000 and 20 years in prison per racketeering count. The racketeers must give up all of the gains from the criminal activity including the hundreds of millions tucked away in U.S. banks. RICO also allows private individuals damaged by the racketeer to file a civil suit and collect treble (three times) damages if they are successful. Proving a RICO charge in court is considered to be relatively easy as it focuses on “patterns” of behavior as opposed to criminal acts. Since conspiracy is one of the charges that could be brought in a RICO case, the kleptocrats’ underlings, accountants, business associates and partners and collaborators could be prosecuted.
Fixing Human Rights Violations by Prosecuting Kleptocrats
A.G. Holder says the Obama Administration is committed to battling corruption as “one of the great struggles of our time.” Holder’s words, if translated into concrete action could have a huge impact not only on governance in Africa but also in improving human rights protections. Corruption is fundamentally a human rights issue. As Peter Eigen, founder and chairman of Transparency International has argued, “[C]orruption leads to a violation of human rights in at least three respects: corruption perpetuates discrimination, corruption prevents the full realisation of economic, social, and cultural rights, and corruption leads to the infringement of numerous civil and political rights. Beyond that, corruption undermines the very essence of the rule of law and destroys citizens’ trust in political leaders, public officials and political institutions.”
The fascinating thing about the Obama Administration’s approach is its creative use of U.S. criminal statutes to deal with African dictators as organized criminal enterprises. Simply stated, the Administration has decided to deal with African dictators as Mafia bosses! If the U.S. could effectively investigate, vigorously prosecute and aggressively seize the assets of Africa’s kleptocrats, the continent may finally begin to see significant improvements in human rights and governance, a dramatic reduction in corruption and generate significant resources from recovered assets for investment in infrastructure and other social programs for the African population.
As I have previously documented[3], Transparency International [TI] (the global coalition against corruption) in its 2009 Corruption Perceptions Index (CPI) again bestowed upon Africa the dubious honor of being Kleptocracy Central, the continental home of the world’s most corrupt governments in the world. Leading the parade of kleptocracies are the regimes in Ethiopia, the Sudan, Zimbabwe, Equatorial Guinea, Kenya and the warlords of Somalia. These countries scored an atrocious 3.0 or less on the index. In certain countries, the corruption trend appears to be irreversible. For instance, in 2002, Ethiopia received a dismal score of 3.5 on the corruption index. In 2009, eight years after the ruling regime had established the “Federal Ethics and Anti-corruption Commission” (FEAC) with great fanfare and after periodic reports of “major accomplishments” in combating corruption, Ethiopia’s score dropped to an abysmal 2.7.
Publicly-owned assets are acquired in Ethiopia by regime-supporters or officials through illegal transactions and fraud. Banks loan millions of dollars to front enterprises owned by regime officials or their supporters without sufficient or proper collateral. Businessmen must pay huge bribes or kickbacks to participate in public contracting and procurement. Those involved in the import/export business complain of shakedowns by corrupt customs officials. The judiciary is thoroughly corrupted through political interference and manipulation as evidenced in the various high profile political prosecutions. Ethiopians on holiday visits driving about town complain of shakedowns by police thugs on the streets. Even the U.S. State Department spokesman Ian Kelley stated last year that the U.S. is investigating allegations that “$850 million in food and anti-poverty aid from the U.S. is being distributed on the basis of political favoritism by the current prime minister’s party.”
Over the past three years, high profile corruption cases in Ethiopia have been reported in the media. In one case, it was established that “USD$16 million dollars” worth of gold bars simply walked out of the bank in broad daylight. The official “anti-corruption” agency described the heist as a “huge scandal that took place in the Country’s National Bank and took many Ethiopians by surprise [in which] corruptors dared to steal lots of pure gold bars that belonged to the Ethiopian people replacing them with gilded irons… Some employees of the Bank, business people, managers and other government employees were allegedly involved in this disastrous and disgracing scandal.” In another case involving a telecommunications deal with the Chinese, a high level regime official was secretly tape recorded trying to extort kickbacks for himself and other regime officials. The same “anti-corruption” agency reported that “there was another big corruption case at the Ethiopian Telecommunications Corporation that took many Ethiopians by surprise” which involved the “competitive tendering for the supply of telecommunication equipment.” After an investigation, FEAC “found out that nearly 200 million USD has been lost to corruption through the entire fraudulent and corrupt process.” No high level official in good standing with the regime has ever been investigated or prosecuted for corruption.
The poor and powerless bear the brunt of corruption in Africa. The devastating impact of corruption on the continent’s poor becomes self-evident as political leaders and public officials siphon off resources from critical school, hospital, road and other public works and community projects to line their pockets. As for President Obama, it seems that he has finally found the silver bullet to deal with Africa’s corrupt thugs. In a pun, no more cash and KARI for Africa’s kleptocrats.
To be continued….
FREE BIRTUKAN MIDEKSSA AND ALL POLITICAL PRISONERS IN ETHIOPIA.
[1] http://www.ethiomedia.com/all/6070.html
[2] http://www.abugidainfo.com/?p=8693
[3] http://www.huffingtonpost.com/alemayehu-g-mariam/africorruption-inc_b_367268.html
7 thoughts on “Steel Vises, Clenched Fists and Closing Walls (Part IV)”
MEMO FROM DAKAR
White House Party for Africa Leaves Out Leaders
By ADAM NOSSITER
Published: August 5, 2010
The New York Times
DAKAR, Senegal — Many of Africa’s leaders have spent part of their summer shuttling between capitals, congratulating one another on 50 years of independence. One capital they will not be visiting together is Washington.
President Obama convened a forum this week to celebrate the 50th anniversaries of 17 African nations, but he did not invite a single African leader to help him do so. Was this, as the African news media and independent commentators see it, an expression of distaste for abusive rulers? Was it an extension of Mr. Obama’s own conviction — already enunciated — that bad government is at the heart of the continent’s woes and that “Africa doesn’t need strongmen, it needs strong institutions”?
The State Department denies such an intent behind the forum, noting that American officials meet with African leaders in other settings.
Nonetheless, commentators on the continent and in the West note a sharp contrast between this week’s event in Washington and the summer’s other major 50th anniversary observance in a Western capital: Paris.
At a celebration on July 14, Bastille Day in France, President Nicolas Sarkozy was flanked by the leaders of Cameroon and Burkina Faso, Paul Biya and Blaise Compaore, who have been sharply criticized on human rights and governance, while 11 other African heads of state, some with equally dubious records, joined him on the reviewing stand.
There, they surveyed a parade of uniformed troops from African armies, some of which had taken part in large-scale abuses over the previous decade. The Senegalese press, for one, was roundly critical of the event. Not only did it dress down the African leaders for heeding the call of the ex-colonial ruler (the irony of celebrating African independence in the seat of a former colonial power was lost on few observers), but it also criticized Mr. Sarkozy for hosting presidents who mistreat their citizens.
Unlike the French president, Mr. Obama stands no risk of being photographed in the company of rulers accused of flouting democracy and human rights. By contrast, he summoned 115 under-35s from civil society, journalism and business to a “President’s Forum With Young African Leaders” this week to help him in “looking forward,” as a State Department official put it.
“We’ve got to look for the next generation of leaders,” said Bruce Wharton, deputy assistant secretary for public diplomacy.
On Tuesday, Mr. Obama bluntly addressed issues of corruption and press freedom in speaking to the group at the White House, saying that “sometimes the older leaders get into old habits, and those old habits are hard to break.”
When asked about President Robert Mugabe of Zimbabwe, Mr. Obama told the young people at the forum, “I’ll be honest with you — I’m heartbroken when I see what’s happened in Zimbabwe. I think Mugabe is an example of a leader who came in as a liberation fighter and — I’m just going to be very blunt — I do not see him serving his people well. And the abuses, the human rights abuses, the violence that’s been perpetrated against opposition leaders I think is terrible.”
African news organizations read the president’s forum as having more to do with the current generation of leaders than with those he invited, seeing it as a rebuke to the older generation.
“50th Anniversary of African Independences: Barack Obama snubs the African dictators,” read a headline in the Cameroonian newspaper Le Messager.
Mr. Obama is giving a “kick in the nose to African leaders, whom he seems to be royally snubbing,” said the Fasozine of Burkina Faso.
Here in Senegal, the newspaper Walfadjri ran a headline saying, “Obama snubs Wade and company and unrolls the red carpet for civil society,” referring to President Abdoulaye Wade of Senegal. So desirable is the association with Mr. Obama that Mr. Wade’s government once put a notice on the front page of a local newspaper saying merely that the Senegalese president had spoken with the American president on the telephone, without divulging the conversation’s contents.
“The American president is extremely sensitive on the subject of democracy,” said another Senegalese paper, Kotch. “Proof: he’s going to celebrate the 50th anniversaries of African nations without inviting a single head of state.”
Mr. Obama has made an overt pitch for the more widespread diffusion of democracy on the continent before, a gesture often recalled in the African media. In a speech to the Ghanaian Parliament in July 2009, the president said it was a “fundamental truth” that “development depends on good governance. That is the ingredient which has been missing in far too many places, for far too long.” Mr. Obama added that it was up to Africans themselves to add this “ingredient.”
Mr. Obama’s choice has been met with frosty silence, mostly, in African presidential palaces. But it clearly has the potential to sting. Governments lacking internal legitimacy on the continent often derive their credibility from international recognition, from going to conferences, and being met and greeted by other heads of state, as scholars are increasingly pointing out.
“International recognition endows African state actors with a domestic power of command,” wrote Pierre Englebert, a professor of politics at Pomona College, in his recent book “Africa: Unity, Sovereignty & Sorrow.”
The absence of presidents and their retinues at the Washington gathering is thus seen as no accident.
“By refusing to invite them, and welcoming them in Washington, Obama is clearly telling them, ‘If you want to engage with us, you have to behave,’ ” said Mamadou Diouf, director of the Institute of African Studies at Columbia University. “It’s a way of questioning the choice made by Sarkozy.”
Other analysts agreed. “You take one look at Sarkozy and his buddies, that’s not the picture Obama wants to convey,” said J. Stephen Morrison, an Africa expert at the Center for Strategic and International Studies in Washington.
A French Foreign Ministry official rejected the widespread criticism of Mr. Sarkozy, calling it “a sterile polemic.”
“The two initiatives are complementary,” the official, who was not authorized to speak publicly on the matter, said of the two approaches taken by Mr. Sarkozy and Mr. Obama. “A country can’t be reduced just to its leaders and civil society. For a democracy to function, you need both.”
As for the general populace, though, Mr. Obama’s choice has been “saluted by African public opinion,” said a Senegalese opposition leader, Abdoulaye Bathily, “because the emerging forces are not to be found in the leadership, but in the civil society movement.” Mr. Bathily added: “The leaders have failed the African people.”
Prof Alemayehu,
You’re sounding triumphant for nothing. It serves no purpose to keep feeding our people false hopes. If you are not one of those who have been totally brainwashed by Western (mis)education, you at some point will have to recognize that the US cares squat for Africa’s well-being.
Look at their hypocratic reaction when Meles stole the Ethiopian elections in broad daylight — they wined and dined with him in Canada a few weeks later at the G-20 conference. Bertukan will probably be tortured to insanity and finally die in jail while the US pontificates about the house arrest of the leader of the opposition in Burma.
Is there a clearer example for the fact that all the sermons about democracy and human rights in Africa are just selective weapons they use to destablize governments that they dislike? Do you think they would have invited someone like Muguabe to the G-20 conference? And who of the two is the most shameless and ruthless dictator — Muguabe or Meles?
Actually, there is nothing genuine about the new sermons regarding corruption. It is simply a shift in weapon of mass deception. The US and the West now realize that few in Africa and the civil society community any longer take their sermons about democracy and human rights seriously, considering the fact that they themselves are the the backers of monsters regimes such as Meles Zenawi’s. So the need for a new theme for the US to regain the moral highground. KARI is the new empty slogan. Meles Zenawi will be allowed to continue looting Ethiopia, as he has been allowed and bankrolled to repress and balkanize the country, unless and until educated Ethiopians like you stop feeding Ethiopians false hopes and fight like their forefathers to save their country.
Thoughtful article with foresight.
1. Ethiopia’s is not a mere case of kleptocracy but a systemic and monstrous robbery with biblical proportion, when all said and done, leaves the lives of significant population drastically changed.
2. As long as the businessmen, investors and banks have their way, nothing is going to happen to the cleptocrats or kleptarats. After all, these powers turned China and India into superpowers on the expense of the rest of the world. In the case of U.S against Swiss Bank UBS, nothing of substance so far.
http://xrl.us/bhvo4v
LIST OF SWISS BANKS
* Swiss Private Bank.com
*AIG Private Bank
* Anker Bank
* Arab Bank (Switzerland)
* Banca del Gottardo
* Banca della Svizzera Italiana (BSI)
* Banca di Credito e Commercio
* Banca Monte Paschi (Suisse)
* Banca Unione di Credito
* Bank am Bellevue
* Bank Hofmann AG
* Bank Jacob Safra
* Bank Julius Baer
* Bank Leu Ltd
* Bank of New York – Inter Maritime Bank
* Bank Pictet & Cie
* Bank Sarasin
* Bank von Ernst & Cie AG
* Bank Vontobel J. & Co. AG
* Banque Alternative Suisse
* Banque Bonhôte & Cie SA
* Banque de promotion cofalys
* Banque Diamantaire Anversoise (Suisse)
* Banque Edouard Constant
* Banque Franck SA – Johnson International Group
* Banque Galland et Cie SA
* Banque Hottinger et Cie
* Banque MeesPierson Gonet SA Swiss Bank Account
* Banque Muli Commerciale
* Banque Pasche
* Banque Piguet & Cie SA
* Banque SCS Alliance
* Banque Unexim (Suisse)
* Bumann & Cie Online
* BFC (Banque Financière de la Cité)
* BNP Suisse SA
* Bordier & Cie
* Caisse d’épargne du district de vevey
* CIM Banque
* Clariden Bank
* Coop Bank
* Crédit Agricole Indosuez (Suisse) SA
* Crédit Lyonnais Suisse
* Credit Suisse Group
* Darier Hentsch & Cie
* Discount Bank and Trust Group
* E. Gutzwiller & Cie
* Ferrier Lullin et Cie SA
* FinansBank
* Gonet & Cie
* Habib Bank AG Zurich
* Hentsch Henchoz & Cie
* Kantonalbank (German, French:Banque Cantonale, Italian: Banca Cantonale)
o Aargauische Kantonalbank (AKB)
o Appenzeller Kantonalbank (APPKB)
o Banca dello Stato del Cantone Ticino (BancaStato)
o Banque Cantonale de Berne (BEKB/BCBE)
o Banque Cantonale de Fribourg (FKB)
o Banque Cantonale de Genève (BCGE)
o Banque Cantonale du Jura (BCJU)
o Banque Cantonale du Valais (BWKB)
o Banque Cantonale Nechâteloise (BCN)
o Banque Cantonale Vadoise (BCV)
o Basellandschaftliche Kantonalbank (BLKB)
o Basler Kantonalbank (BKB)
o Glarner Kantonalbank (GLKB)
o Graubündern Kantonalbank (GKB)
o Luzerner Kantonalbank (LUKB)
o Nidwaldner Kantonabank (NWKB)
o Obwaldner Kantonalbank (OWKB)
o St.Galler Kantonalbank (SGKB)
o Shaffauser Kantonalbank (SHKB)
o Schwyzer Kantonalbank (SZKB)
o Thurgauer Kantonalbank (TKB)
o Urner Kantonalbank (URKB)
o Zuger Kantonalbank (ZugerKB)
o Zurcher Kantonalbank (ZKB)
* Kanz Bank
* La Roche & Co Banquiers
* Lombard, Odier & Cie
* Maerki, Baumann and Co. AG
* MigrosBank
* Mirabaud & Cie
* Morval & Cie SA Banque
* Rabo Robeco Bank
* Rahn & Bodmer Banquiers
* S&B Investment Bank
* SG Ruegg Bank
* Skandia Bank (Switzerland) AG
* Solothurner Bank (Soba)
* Swiss National Bank
* Swissnetbank.com AG
* UBS AG
* Union Bancaire Privée
* Union Suisse des Banques Raiffeisen (USBR)
* Valiant Bank
* Volkbank Bodensee AG
* Wegelin & Co
In the sixties and seventies, the vermins or better known as snakes, would spray their sharp words, which spelled out as “Feudal” and “Adhari” among many, invectives that apparently worked for them all the way several decades later. One of their accusation was that the king stole eleven billion dollars, a charge that never substantiated and a figure that they themselves are no doubt approaching in accumulating, and a complicity we have been part of all these years.
Racketeering/RICO
Federal and state racketeering, profiteering, and RICO (Racketeer-Influenced and Corrupt Organization) laws make it illegal for criminal organizations to profit from any legitimate business operations. Many of these laws allow for the confiscation and seizure of the criminal organization’s legitimate enterprise assets, and are typically used against known “organized crime” groups. The goal is to cripple the operation financially, and cut off sources of cash that support ongoing criminal activity.
http://criminal.findlaw.com/crimes/a-z/
Crimes against humanity, as defined by the Rome Statute of the International Criminal Court Explanatory Memorandum, “are particularly odious offences in that they constitute a serious attack on human dignity or grave humiliation or a degradation of one or more human beings. They are not isolated or sporadic events, but are part either of a government policy (although the perpetrators need not identify themselves with this policy) or of a wide practice of atrocities tolerated or condoned by a government or a de facto authority. Murder; extermination; torture; rape, political, racial, or religious persecution and other inhumane acts reach the threshold of crimes against humanity only if they are part of a widespread or systematic practice. Isolated inhumane acts of this nature may constitute grave infringements of human rights, or depending on the circumstances, war crimes, but may fall short of falling into the category of crimes under discussion.”
The Rome Statute Explanatory Memorandum states that crimes against humanity
are particularly odious offenses in that they constitute a serious attack on human dignity or grave humiliation or a degradation of one or more human beings. They are not isolated or sporadic events, but are part either of a government policy (although the perpetrators need not identify themselves with this policy) or of a wide practice of atrocities tolerated or condoned by a government or a de facto authority. However, murder, extermination, torture, rape, political, racial, or religious persecution and other inhumane acts reach the threshold of crimes against humanity only if they are part of a widespread or systematic practice. Isolated inhumane acts of this nature may constitute grave infringements of human rights, or depending on the circumstances, war crimes, but may fall short of meriting the stigma attaching to the category of crimes under discussion. On the other hand, an individual may be guilty of crimes against humanity even if he perpetrates one or two of the offences mentioned above, or engages in one such offense against only a few civilians, provided those offenses are part of a consistent pattern of misbehavior by a number of persons linked to that offender (for example, because they engage in armed action on the same side or because they are parties to a common plan or for any similar reason.) Consequently when one or more individuals are not accused of planning or carrying out a policy of inhumanity, but simply of perpetrating specific atrocities or vicious acts, in order to determine whether the necessary threshold is met one should use the following test: one ought to look at these atrocities or acts in their context and verify whether they may be regarded as part of an overall policy or a consistent pattern of an inhumanity, or whether they instead constitute isolated or sporadic acts of cruelty and wickedness.
Building of the International Criminal Court in The Hague, Netherlands:
http://xrl.us/bhvvk9
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