On June 21, 2016, the European Court of Human Rights Grand Chamber held [3] in Al-Dulimi and Montana Management Inc. v. Switzerland that in its implementation of Security Council Resolution 1483 [4], Switzerland violated the applicants’ right to a fair hearing under Article 6 of the European Convention on Human Rights [5]. Resolution 1483 imposed an obligation on states to “freeze without delay” the financial assets of individuals or entities connected with the government of Saddam Hussein. Pursuant to this resolution, Switzerland froze the applicants’ Swiss assets. The applicants challenged the government’s actions in domestic courts, which dismissed the actions on the grounds that the government was bound by Security Council resolutions under Article 25 of the UN Charter [6]. The applicants then lodged their complaint with the Court, arguing that the confiscation of their assets violated the right to a fair hearing. The government countered that it faced a conflict between its UN Charter obligations and its Convention obligations; that the conflict could not be resolved because there was no room to maneuver in the implementation of the Council’s resolution; and that, pursuant to Article 103 of the UN Charter, its Charter obligations prevailed. The Court found that given the UN’s purposes (among them achieving “international co-operation in . . . promoting and encouraging respect for human rights”), “there must be a presumption that the Security Council does not intend to impose any obligation on member States to breach fundamental principles of human rights.” The Court went on to find that “where a resolution . . . does not contain any clear or explicit wording excluding the possibility of judicial supervision of the measures taken for its implementation, it must always be understood as authorising the courts of the respondent State to exercise sufficient scrutiny so that any arbitrariness can be avoided.” The Court thus found that there was no conflict between the UN Charter and the Convention compelling a hierarchy analysis under Article 103 of the Charter. Moreover, because Switzerland did not provide the applicants a genuine opportunity to scrutinize whether the decision to have their assets frozen was arbitrary, it violated the applicants’ right to a fair hearing under of Article 6 of the Convention.