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On May 30, 2012, the Appeals Chamber of the ICC unanimously dismissed an appeal by the prosecution in the case against Callixte Mbarushimana. Mr. Mbarushimana was charged with various war crimes and crimes against humanity, including contributing to the implementation of a common plan to attack civilians of the Democratic Republic of the Congo, as well as using murder, widespread and brutal rape, torture, and destruction of property as a way to “blackmail the international community and to extort concessions of political power in exchange for ending atrocities”[2]. The crimes attributed to Mr. Mbarushimana were related to his alleged responsibility as Executive Secretary of the Forces démocratique pour la libération du Rwanda (FDLR).[3]