On January 31, 2014, U.S. President Barack Obama issued a memorandum certifying that U.S. Armed Forces participating in the United Nations military operation in Mali “are without risk of criminal prosecution or other assertion of jurisdiction by the International Criminal Court.” According to the press release, Mali entered into an agreement pursuant to Article 98 of the Rome Statute, which prevents the ICC from proceeding with a request for surrender if it would require the state in question to “act inconsistently with its obligations under international agreements.”