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ICC complaint to be filed against Tedros Adhanom

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Tedros bijgesnedenWHO diplomatic immunity no shield for international crimes as Ethiopian foreign minister.

A criminal complaint will be filed with the International Criminal Court prosecutor against WHO Director-General Tedros Adhanom on Tuesday, Dec. 1, 2020, at 5 p.m. GMT+1.

  • The complaint charges Dr. Tedros with individual and Superior/Command responsibility under the Rome Statute for genocide and crimes against humanity committed when Dr. Tedros was Ethiopian foreign minister and a member of the Tigrayan People’s Liberation Front (TPLF) Executive Committee 2012 to 2016.
  • Ethiopia expert, author and prominent Tedros critic David Steinman will file the complaint.
  • Mr. Steinman will read a statement and take questions at a virtual press conference hosted by the Hague Nieuwspoort on Tues., Dec. 1, 2020 at 5 p.m. GMT +1.



Filed: Dec. 1, 2020, 5 PM GMT+1

Preliminary Statement

This Communication is a criminal complaint that Dr. Tedros Adhanom Ghebreyesus (“Tedros”), presently employed as the Director-General of the World Health Organization (“WHO”), is liable for Crimes against Humanity and/or Genocide (collectively, “Crimes”) pursuant to the Rome Statute. The Crimes were committed by Tedros himself, jointly with others, and/or by effectively controlled Ethiopian security forces, civil servants or regional paramilitaries and local police (“Subordinates”) for whom he shares liability when he was a senior Ethiopian official before his employment by the WHO.


From May 1991 to April 2018, the Tigrayan People’s Liberation Front (“TPLF”), an ethnic based political organization, effectively controlled Ethiopia’s national and regional governments and Subordinates. The TPLF’s hold on power in Ethiopia relied on election fraud, violence, and intimidation.

Most power with respect to setting government policy and/or control over Subordinates was concentrated in an eleven-person TPLF Executive Committee that was reduced to nine persons in 2018.

Prior to his 2017 election as director-general of the WHO, Tedros was, from 2012-2016, Ethiopia’s third highest official as foreign minister and an influential member of the TPLF Executive Committee. One 2013 media report describes him thusly: “With the retirement of the old guard within the Tigrayan People’s Liberation Front (TPLF), Tedros Adhanom Ghebreyesus is one of three influential newcomers at the helm of Tigrayan politics in the emerging post-Meles-Zenawi era.” [emphasis added]

Anyone “at the helm” of Tigrayan politics in that period had a substantial role in formulating government policy and shared effective control over Subordinates. In doing so, Tedros joined other senior TPLF officials in a common plan and purpose to use Subordinates to maintain the TPLF’s illegitimate hold on power.

His personal responsibility for Subordinates’ actions during that period therefore cannot be separated from that of the government’s.

Government Control Over Security Force Subordinates 2013-2015

The U.S. State Department 2013, 2014 and 2015 Human Rights Practices Report for Ethiopia state, “Authorities generally maintained control over the security forces… Security forces committed human rights abuses.”

It may therefore logically be inferred that Crimes committed by Ethiopian security forces between 2013 and 2015 were generally done by Subordinates effectively controlled by Ethiopian authorities that included Tedros.

Government Control Over Security Force Subordinates in 2016

With respect to 2016, Tedros’ last year in power, U.S. State Dept. Human Rights Practices Report for Ethiopia states that, “Civilian authorities at times did not maintain control over the security forces, and local police in rural areas and local militias sometimes acted independently.”

Even if one gives the government the benefit of a doubt and, arguendo, liberally assumes all the reported 2016 Crimes such as “ excessive force against protesters throughout the year, killing hundreds and injuring many more… arbitrary killings; disappearances; torture and other cruel, inhuman or degrading treatment or punishment,” were committed by uncontrolled security, police or militia elements, other documented Crimes in that report were of a type which the government facially did control. This latter category included, but was not limited to, “unfair government tactics, including intimidation of opposition candidates and supporters…more than 10,000 persons were believed still to be detained…. harsh and life-threatening prison conditions; arbitrary arrest, detention without charge, and lengthy pretrial detention… infringement on citizens’ privacy rights, including illegal searches; a lack of participatory consultations and information during the implementation of the government’s “villagization” program; restrictions on civil liberties including freedom of speech and press, internet freedom, academic freedom and of cultural events, and freedom of assembly, association, and movement; interference in religious affairs; only limited ability of citizens to choose their government; … restrictions on activities of civil society and NGOs…”

Therefore, Ethiopian senior government leadership, including Tedros, controlled Subordinates who committed one or more Crimes in 2016 in addition to those committed 2013-2015.

Control Over Subordinate Civil Servants

Civil service Subordinates of Tedros also committed Crimes by carrying out a government policy of inequitable ethnic discrimination in the distribution of public goods necessary to sustain life, such as food aid, investment, agricultural inputs, and healthcare.

Tedros’s civil service Subordinates also maintained and perpetuated an apartheid system.

Liability for Somali Regional Police

The 2013-2016 U.S. State Department Human Rights Practices Reports for Ethiopia also state that the Somali Region Special Police, also known as the “Liyu ,” “sometimes acted independently” in committing Crimes. However, the regime’s actual control of the Liyu, and knowledge of the Liyu’s Crimes, were demonstrated in 2018 when reformist prime minister Abiy Ahmed came to power. Abiy arrested the administrator of the Somali region, Abdi Omar (a.k.a. Abdi Illey), who had used the Liyu to terrorize the local population, and informed the public about the Liyu’s Crimes. Abiy also reined in other police and local militia.

Abiy’s demonstrated ability to control such forces proved that the predecessor Ethiopian regime which Tedros co-led could have controlled them too. It may thus reasonably be inferred that Tedros and his co-leaders also could have stopped—or at least tried harder to stop–some or all the Crimes by Somali Regional Special Police and other local militias and police but failed to do so.

Some liability for the Crimes of the Somali Regional Police, local police and local militias committed 2013 to 2016 must therefore be apportioned to Ethiopia’s federal government in which Tedros played so influential a part.

Knowledge of an Ongoing and Predictable Pattern of Crimes

It was impossible for an Ethiopian foreign minister, TPLF Executive Committee member and long-term TPLF member to be unaware that the TPLF had been committing Crimes for a long time and would probably continue to do so as long as it remained in power.

For example, the annual human rights reports listed in the Supplementary Evidence section below cover Tedros’ four years in power. (2012 is excluded because he assumed his post near its end.) However, one only need google the Amnesty International, Human Rights Watch and US State Department Ethiopia Human Rights reports for the 22 years of TPLF rule preceding Tedros’ ascension to power, during nine of which Tedros himself also served as Deputy Minister and Minister of Health, to see the prevalence and trend with respect to Crimes.

During the long course of Tedros’ rise through the ranks of TPLF officialdom, TPLF Crimes were often reported in well-known and popular media such as Ethiopian Satellite Television (ESAT), Voice of America, BBC, Deutsche Welle, Washington Post, New York Times, Ethiopian Review and many more.

Many TPLF Crimes were widely known and discussed daily by the general Ethiopian public since 1991.

The inevitable discussion of governmental affairs with other senior Ethiopian leadership, foreign diplomats and politicians also had to make Ethiopia’s foreign minister aware that his government’s Crimes were frequent and ongoing.

As a senior leader and Executive Committee member, Tedros had to receive intelligence briefings that included mention of Crimes committed by Subordinates, himself and/or jointly with others.

International human rights activists often wrote letters to Ethiopia’s government concerning human rights cases.

It was therefore impossible for any educated Ethiopian, especially a highly educated, well connected, and powerful top leader like Tedros, to be unaware of the long, ongoing, and predictable pattern of TPLF Crimes.

Throughout his tenure as a senior Ethiopian leader, Tedros therefore obviously knew or consciously disregarded information that clearly indicated that his Subordinates were committing, or were about to commit more, Crimes.

Failure to Take Necessary Measures

The above-mentioned U.S. State Department Human Rights Practice Reports for 2013, 2014, and 2015, and, to a lesser extent, 2016 establish that a pattern of Crimes existed of which Tedros had to be aware.

The same reports also show that Tedros could have stopped—or at least could have reasonably tried harder to stop– the documented Crimes by Subordinates during the aforesaid period but failed to do so.

For example, the U.S. State Department Country Reports on Human Rights Practices for 2013-2016 state, “Impunity was a problem. The government, with some reported exceptions, usually did not take steps to prosecute or otherwise punish officials who committed abuses other than corruption.” [emphasis added]

Obviously, despite his evident knowledge of the well-publicized Crimes committed and reasonably expected to be committed in future by Subordinates, Tedros never resigned.

He never spoke out or objected publicly to any Crimes, including from the start of his prominent government service in 2003 as Deputy Health Minister.

Thirteen years of silence and active cooperation with a regime shows constructive support for that regime’s policies and actions.

Tedros’s acts of commission and omission demonstrate that he failed to take all necessary and reasonable measures within his or her power to prevent or repress the commission of Crimes or to submit the matter to the competent authorities for investigation and prosecution as required under Article 28.

To the contrary, the abovementioned actions by Tedros demonstrate his wholehearted and willing adherence to, and support, for TPLF policies, actions and Subordinates that caused, directed, facilitated, or enabled Crimes.

Genocides Committed by Tedros’ Subordinates in Violation of Article 6

The Supplementary Evidence shows that Genocides by Tedros’ Subordinates included:

(a) Killing, and causing serious bodily and mental harm to, members of the Amhara, Konso, Oromo and Somali tribes with intent to destroy those tribes in whole or in part. (For proof, see following section and Supplementary Evidence below.) (b) Ethnic discrimination in the allocation of life-saving public goods despite knowledge that their denial would cause the disproportionate and avoidable death and injury of political or non-Tigrayan ethnic groups. (For proof, see following section)

(c) Imposing measures intended to prevent births within the Amhara tribe. (For proof, see (g) in following section.)

Tedros’ Crimes therefore fall within the jurisdiction of the ICC under Article 6.

Crimes Against Humanity Committed by Tedros’ Subordinates in Violation of Article 7

The Supplementary Evidence to follow shows that the four-year period in which Tedros co-led Ethiopia’s government was marked by widespread or systematic Crimes Against Humanity by Subordinates directed against the Amhara, Oromo, Somali, and Konso tribes, members of opposition parties and other civilian populations, with knowledge of the attack. These included: (a) MURDER of political dissidents. See additional reports here, here, here and here. (Also see Supplementary Evidence below) (b) Intentional infliction of conditions of life, inter alia ethnic discrimination in the allocation of life-saving public goods despite knowledge that such action would bring about the partial destruction of non-Tigrayan populations and members of opposition political parties amounting to EXTERMINATION. (See also here, Sec. B, para. 3: “The government favors Tigrayan ethnic interests in economic and political matters, and the Tigrayan People’s Liberation Front dominates the EPRDF [federal government].”) (c) FORCIBLE TRANSFER of populations to make way for real estate transactions benefitting the TPLF political elite. See also here, here and here. (d) Unlawful imprisonment, including children, in cruel and inhuman conditions that violated fundamental international law. (Also see Supplementary Evidence below) (e) TORTURE of political prisoners. (See additional reports here, here and here and Supplementary Evidence below. Also see putting political prisoners in cells with wild animals by Liyu police.) (f) Mass RAPE by Ethiopian soldiers and/or controlled regional paramilitaries, including “break and rape” (the practice of rape after breaking limbs). (Also see Supplementary Evidence below) (g) FORCED STERILIZATION of Amhara women. (h) ENFORCED DISAPPEARANCE of persons kidnapped or murdered by security or paramilitary forces. (See p. 1 “hundreds, likely more, have been victims of enforced disappearances.” Also see Supplementary Evidence below) (i) Intentional and severe deprivation of fundamental rights of non-Tigrayan ethnic and members of opposition parties contrary to international law by reason of the identity of the group or collectivity amounting to PERSECUTION. (Also see Supplementary Evidence below showing the Crimes were disproportionately committed against non-Tigrayans.)

(j) Systematic oppression and domination by the TPLF over Ethiopia’s other ethnic groups with the intention of maintaining the TPLF regime amounting to APARTHEID. (Facially evident from political disenfranchisement of non-Tigrayans in an arrangement of “States…structured on the basis of settlement patterns, language, identity and consent of the people.” Article 46 (2) of the “Ethiopian” (actually, TPLF-imposed) constitution. (Also see Supplementary Evidence below)

(k) OTHER INHUMANE ACTS, such as Subordinates’ beating, slapping, kicking, threatening, and intimidating members of political opposition parties that intentionally caused great suffering, or serious injury to body or to mental or physical health. (See Supplementary Evidence below for examples.)

Many of the abovementioned Crimes occurred in a pattern, volume and duration that amounted to widespread or systematic attacks directed against a civilian population,

with knowledge of the attack or inhumane acts of a similar character intentionally causing great suffering, or serious injury to body or mental or physical health.

Tedros’ Crimes therefore fall within the jurisdiction of the ICC under Art. 7.

Tedros’ Crimes Were Part of a Plan or Policy Pursuant to Article 8(1)

Under Tedros, Crimes were no mere isolated incident. Crimes committed by Tedros and/or his Subordinates were so widespread, frequent and predictable as to demonstrate the existence of a “plan or policy or a part of a large-scale commission of such Crimes” that demands prosecution pursuant to Article 8(1) of the Rome Treaty.

Firsthand Evidence

The files of the major human rights organizations are filled with firsthand testimony by victims of Tedros’ Subordinates with names and contact information. Here, for example, is one of many available firsthand accounts by torture victims.

Many more firsthand witnesses can be found by investigators, inside and outside Ethiopia, particularly if witness protection is available.

There is direct, open source, photographic and video evidence of Crimes by Tedros’ Subordinates, including murder and torture, in news media and the files of human rights organizations such as Human Rights Watch.

There is at least one firsthand eyewitness to kidnapping arrangements made by Tedros, a former bodyguard.

Supplementary Evidence of Superior Liability

Taken as a whole, especially in the context of the twenty-two years of prior human rights reports documenting similar Crimes (omitted here but available online), the following annual human rights reports for 2013-2106 demonstrate a pattern of Crimes so systematic, widespread, and predictable as to manifest a permissive, intentional government policy often carried out by Tedros’ Subordinates: Amnesty International USA Annual Report Ethiopia 2013 Amnesty International Report Ethiopia 2014/2015 Amnesty International Country Report Ethiopia 2016/2017 Human Rights Watch Country Report for Ethiopia 2013 Human Rights Watch Country Report for Ethiopia 2014 Human Rights Watch Country Report for Ethiopia 2015 Human Rights Watch Country Report for Ethiopia 2016 U.S. State Dept. Country Report on Human Rights Practices: Ethiopia 2013 U.S. State Dept. Country Report on Human Rights Practices: Ethiopia 2014 U.S. State Dept. Country Report on Human Rights Practices: Ethiopia 2015 U.S. State Dept. Country Report on Human Rights Practices: Ethiopia 2016

See also: The Amhara Genocide Ignored by the World (Please refer only to Crimes 2013-2015.) ETHIOPIA: ETHNIC OROMOS ARRESTED, TORTURED AND KILLED BY THE STATE IN RELENTLESS REPRESSION OF DISSENT

Supplementary Evidence of Individual Responsibility and Mens Rea

As foreign minister and Executive Committee member, Tedros advised, shared information with, guided and helped manage the Ethiopian government despite his knowledge that: a) it often committed Crimes and b) was likely to do so again in the future. Tedros personally arranged the widespread and systematic kidnappings of hundreds of Ethiopian dissidents in Yemen. This news account is corroborated by the pattern of kidnappings that began after the meeting. These included kidnapping of dissident and British citizen Mr. Andy Tsege, from Yemen while in transit and rendering him to death row. Tedros suppressed and withheld vital information about his people’s humanitarian needs by peddling fake statistics that only 29% of Ethiopians lived in poverty under the EPRDF and attempted to cover up a famine in order to protect his government’s reputation. His acts contributed to the loss of many lives by delaying or distorting effective international response. Tedros’ failure to report, stop, prevent, or even try to prevent Illicit Financial Outflows controlled by the government caused the waste of life-saving foreign aid from signatory states.

Tedros misrepresented his country’s human rights situation to foreign donors and publics who might otherwise have reduced or curtailed their funding if they had known the truth. In this 2015 CNN interview, for example, Tedros is on tape attempting to “spin” the EPRDF’s human rights record. (CNN interview) Here, on his own blog, he attempts to whitewash a 2016 massacre. Here, Amnesty International exposes the falsity of his claim that “Ethiopia has won the respect and trust of the world” for human rights.


Tedros’ misrepresentation, withholding, and suppression of vital information about Ethiopia’s human rights situation helped himself, colleagues and Subordinates who had committed Crimes to hide their guilt and avoid accountability. His fraudulent conduct facilitated and enabled the TPLF’s Crimes by polishing the regime’s international image and deflected foreign and domestic attempts to hold the government accountable. It perpetuated the government’s abuses by helping the regime obtain foreign loans and grants under false pretenses. He was the charming public face of a homicidal dictatorship and played a major role in keeping it afloat.

Tedros’ Superior Responsibility for Crimes Against Humanity and Genocide Committed by His Subordinates in Violation of Article 28

The foregoing shows that as Ethiopia’s third highest official and TPLF Executive Committee member during the period in question, Tedros:

a. jointly shared effective control over military, paramilitary and civilian Subordinates.

b. knew, or consciously disregarded information which clearly indicated, that his Subordinates were committing or were about to commit Crimes within the jurisdiction of the Court.

c. individually or jointly had effective responsibility and control of activities which the Crimes concerned; and

d. failed to take all necessary and reasonable measures within his power to prevent or repress said Crimes’ commission or to submit the matter to the competent authorities for investigation and prosecution.

Tedros therefore is criminally responsible for one or more Crimes committed by Subordinates under the Doctrine of Superior/Command Responsibility per Article 28.

Tedros’ Individual Responsibility for Crimes Against Humanity and Genocide Committed in Violation of Article 25

25(3)(a) of the ICC Statute extends to “responsible,” or non-innocent, agents. The modality of “control over the organization,” has been found suitable to address the involvement of high-level individuals who usually leave the physical commission of violent Crimes to lower level perpetrators.

The ICC thus has jurisdiction over Tedros as a natural person pursuant to Article 25 because he:

(a) committed a Crime within the jurisdiction of the Court.

(b) committed such a Crime, as an individual, jointly with another or through another person.

(b) ordered, solicited, or induced the commission of such a Crime which in fact occurred or was attempted.

(c) for the purpose of facilitating the commission of such a Crime, aided, abetted, or otherwise assisted in its commission or its attempted commission, including providing the means for its commission. For example, Tedros shared responsibility and control over funding of security and paramilitary forces that committed Crimes. He helped obtain foreign grants, loans or other forms of foreign support that were used to perpetrate Crimes directly or indirectly. He also deflected international criticism in a way that made it easier for Crimes to be committed.

(d) contributed to the commission or attempted commission of one or more Crimes by a group of persons acting with a common purpose. Such contribution was intentional and was either: (i) made with the aim of furthering the criminal activity or criminal purpose of the group, where such activity or purpose involved the commission of a Crime within the jurisdiction of the Court; and/or (ii) was made in the knowledge of the intention of the group to commit the Crime.

Tedros therefore is criminally responsible for one or more Crimes committed by Subordinates under the Doctrine of Individual Responsibility per Article 25.

Tedros’ Mental Element Pursuant to Article 30

Tedros’ own words and deeds on the record demonstrate that he:

(a) meant to engage in his conduct, and

(b) meant to cause the expected consequences or was aware that they would occur in the ordinary course of events.

Recent interpretations of Articles 25 and 30 of the ICC Statute by the Pre-Trial Chambers of the International Criminal Court demonstrate that the Court adopts a broad interpretation of the common plan or agreement element.

Under that interpretation, or even a narrower one, Tedros is criminally responsible and liable for punishment for Crimes within the jurisdiction of the Court because the Crimes’ material elements were committed with his intent and knowledge.

Injuries to Ethiopians Caused by Tedros’ Crimes

It is no exaggeration to say that millions of Ethiopian and other nationals’ lives were negatively impacted by Tedro Crimes.

Hundreds of thousands of victims, many of them children, died or, in many cases, suffered permanent physical or psychological harm as a result of torture, persecution, extermination, genocide, unlawful imprisonment and other Crimes by Subordinates directed against them, family members, caregivers or family breadwinners.

It may reasonably be inferred that thousands of impoverished Ethiopians suffered or died because of Tedros’ misrepresentation of Ethiopia’s economic statistics that delayed or distorted foreign aid.

The billions of dollars siphoned out of Ethiopia’s economy by political elites and their business partners as Illicit Financial Outflows, approximately 10 to 15 billion dollars of which took place while Tedros co-led the country, delayed the country’s achievement of several Millennium Development Goals. On the ground, that delay meant thousands of deaths, many or most of them infants or children.

Ethnic discrimination in the distribution of life saving public goods under Tedros may reasonably be inferred to have cost, or otherwise negatively impacted, hundreds of thousands or even millions of lives among non-Tigrayan tribes.

Injuries to Member States of the Rome Statute

Tedros’ Crimes affected one or more member states by adding to their refugee flows.

Tedros’ Crimes affected one or more member states by causing the waste of foreign aid with the exacerbation of Ethiopian’s humanitarian needs.

Tedros’ Crimes affected one or more member states by causing the abuse of foreign aid that relied on Ethiopian adherence to human rights norms.

Some Ethiopian residents of member states, who lived in Ethiopia during the years of Tedros’ co-rule, suffer to this day from physical or psychology injury caused by Tedros or his Subordinates.

The kidnapping of Mr. Andy Tsege and psychological traumatization of Mr. Tsege’s family injured citizens of member state The United Kingdom.

By concealing his Crimes, Tedros subjected member states to Covid-related harm that might have been avoided if his character had been known before his election to lead the WHO.

The ICC Has Jurisdiction

This complaint is based on Jus Cogens, Ergam Omnes, customary international law

and international treaties, especially the Rome Statute of the International Criminal Court (1998).

Tedros’ diplomatic status is irrelevant to the ICC under Article 27 of the Rome Statute (“Irrelevance of official capacity”).

The Prosecutor may initiate investigations proprio motu based on information on Crimes within the jurisdiction of the Court.

In respect of Articles 12 and 13 of the Rome Statute, the Court may exercise its

jurisdiction over international Crimes if its jurisdiction has been accepted by the State on

the territory in which the Crimes were committed. One or more countries injured by the above-described Crimes are signatories to the Rome Statute, including Switzerland where Tedros resides, works and is often present.

Despite Ethiopia being a non-signatory to the Rome Statute, the ICC has territorial jurisdiction over Tedros’ Crimes in Ethiopia under the “Effects Doctrine” which gives the ICC jurisdiction when a signatory state has been injured in some way by the crime in the non-signatory state (Ethiopia). See S.S. Lotus (Fr. V. Turk.), 1927 P.C.I.J., (Ser. A), No. 10 (noting that many countries will find jurisdiction for criminal acts done in another state if their effects are felt within its borders); United States v. ALCOA, 148 F.2d 416, 443 (2d Cir. 1945) (noting that “any state may impose liabilities, even upon persons not within its allegiance, for conduct outside its borders that has consequences within its borders, which the state reprehends”).

In the context of the ICC, application of the Lotus principle would mean that sovereign states are free to collectively establish an international jurisdiction applicable to the nationals of non-party states unless it can be shown that this violates a prohibitive rule of international law. So long as states have a legitimate interest in establishing such an arrangement, the question is simply whether any international legal rule exists that would prohibit it. No such rule exists.

The perpetrators of the core Crimes under the ICC’s jurisdiction are considered hostis humani generis (enemies of all humankind) and the Crimes themselves (even when committed in an internal conflict) are considered a threat to international peace and security. Thus, there are no special features of territorial jurisdiction that would as a matter of policy preclude the delegation of territorial jurisdiction to an international criminal court.

At least one legal expert asserts that “a close examination of the text of the European Convention, its legislative history, and the writings of experts on its application reveal that the Convention does in fact permit transfer of proceedings in the absence of the consent of the state of nationality.” The ICC’s Jurisdiction Over the Nationals of Non-Party States: A Critique of the U.S. Position, Scharf, Michael P., Case Western Reserve University School of Law Scholarly Commons, 2001.

Furthermore, one of the bases for the precedent Nuremberg Tribunal’s jurisdiction was the universality principle collectively exercised on behalf of the Allied Nations.

Crimes for which Tedros is liable were therefore within the jurisdiction of the Court at the time they took place, pursuant to Article 22 (Nullum crimen sine lege)

In addition, the ICC Prosecutor should ask the Federal Democratic Republic of Ethiopia to refer Tedros to the ICC on an ad hoc basis. Article 87 provides for cooperation with the ICC by non-party states. It stipulates that the Court “may invite any State not party to this statute to provide assistance under this Part on the basis of an ad hoc arrangement, an agreement with such State or any other appropriate basis.”

Tedros’ Presence on the Soil of a Signatory State

Tedros is in Switzerland, a signatory state to the Rome Statute, or is expected to return there soon. Tedros also sometimes visits other state signatories to the Rome Statute.


Tedros’ Superior and Individual liability for Crimes is supported by evidence.

Investigation and prosecution of him by the Prosecutor of the ICC would be a just and appropriate response to Tedros’ grave Crimes that caused so much suffering.

Investigation and judgment by the ICC concerning Tedros’ Crimes could contribute to the field of international criminal law and establish an important precedent.

Therefore, the Prosecutor is requested herewith to investigate, issue an arrest warrant for, and prosecute Tedros because he violated the Rome Statute, injured signatory states thereto, and the ICC has jurisdiction over him.

The Prosecutor is also requested to ask the Federal Democratic Republic of Ethiopia to refer Tedros to the ICC.


The individual communicating this information, Mr. David Steinman, is an Ethiopia expert of American nationality. A Wharton-trained economist and former consulting expert to the U.S. National Security Council on democracy promotion, he was senior foreign adviser to Ethiopia’s main opposition coalition. Mr. Steinman exposed TPLF Crimes and corruption in the Washington Post,, New York Times, The National Review, New Europe and other media. He first called for Tedros and other senior TPLF leadership to be held accountable for Crimes in the nonfiction afterword to his historical novel about Ethiopia’s human rights struggle, Money, Blood and Conscience.


I affirm the foregoing is true to the best of my knowledge.



_____ Date: Dec. 1, 2020

David Steinman