On November 10, 2020, International Criminal Court (ICC) Chief Prosecutor Fatou Bensouda warned [3] the UN Security Council that the failure of States and parties to arrest and surrender fugitives constitutes a “major stumbling block” in obtaining justice for atrocity crime victims throughout Libya. While the warring Libyan parties signed a ceasefire agreement on October 23, 2020, the Prosecutor noted two investigations and “deeply disturbing” reports of recent actions that constitute crimes under the Rome Statutes. Prosecutor Bensouda stated, “Victims of atrocity crimes in Libya must be reassured that, notwithstanding any ceasefire or future agreement, individuals alleged to be responsible for serious crimes . . . will be promptly arrested and surrendered.”