On June 9, 2014, Pre-Trial Chamber II of the International Criminal Court (the Court) unanimously confirmed [3] the charges against Bosco Ntaganda, the former alleged deputy chief of the staff of the Forces Patriotiques pour la Libération du Congo (FPLC), and committed him for trial before a Trial Chamber. Ntaganda is charged with eighteen counts of war crimes and crimes against humanity, relating to the activities in Ituri Province, Democratic Republic of the Congo, between August 2002 and December 2003. According to the press release [4], the Court found that “as part of the widespread and systematic attack against the non-Hema civilian population and in the context of the non-international armed conflict, the crimes with which Bosco Ntaganda is charged were committed during two specific attacks, in addition to war crimes committed by the UPC [Union des Patriotes Congolais]/FPLC throughout the conflict.”  The Chamber further found that Ntaganda “bears individual criminal responsibility” pursuant to different modes of liability under the Rome Statute [5], including direct perpetration, indirect co-perpetration, and ordering.