On December 31, 2015, the International Criminal Tribunal for Rwanda (ICTR) formally closed after twenty-one years and forty-five judgments delivered in an effort to hold those accountable for the genocide in Rwanda of more than 800,000 people. According to a news report [3], the Security Council, which had initiated the tribunal in 1994, issued a statement reaffirming its “strong commitment to justice and the fight against impunity.” The ICTR was the first international tribunal to adjudicate the crime of genocide, sentencing “61 people to terms of up to life imprisonment for their roles in the massacres which took place over the course of three months of bloodletting by Hutu extremists” and “played a pioneering role in setting up a credible international criminal justice system, producing a substantial body of jurisprudence on genocide, crimes against humanity, war crimes, and individual and superior responsibility.” It was the first “to define rape in international criminal law and to recognize rape as a means of perpetrating genocide” and “to hold members of the media responsible for broadcasts intended to inflame the public to commit acts of genocide.” The International Residual Mechanism for Criminal Tribunals, established in 2010, will “ensure that the ICTR’s closure does not leave the door open to impunity for the [eight ICTR-indicted] remaining fugitives.”