The effectiveness of universal jurisdiction
This year’s report demonstrates once again that universal and other forms of extraterritorial jurisdiction remain effective tools for pursuing accountability for international crimes. Between January and December 2025, 34 new cases were opened or made public, and 23 convictions were secured. This underscores the unique impact of universal jurisdiction within the international criminal justice ecosystem, both in the number of cases and perpetrators held accountable, and in the concrete access to justice it provides for victims.
In 2025, authorities in four new States – Kosovo, Peru, Poland and Türkiye – took steps to exercise universal and other forms of extraterritorial jurisdiction for the first time. Several cases also set important precedents: the first conviction for crimes committed in the context of the 2014 war in Eastern Ukraine; the first conviction for genocide through the transfer of children to another group; the first trial concerning the war crime of starvation; and the first conviction for crimes committed during the Second Congo War (1998-2003).
International justice at a crossroads
2025 was also marked by unprecedented attacks on international criminal justice. US-sanctions targeting the International Criminal Court (ICC) and other actors in relation to the situation in Palestine constitute direct attempts to shield the US and its allies, specifically Israel, from accountability, and risk depriving many people of what might be their last resort for justice.
A broader erosion of States’ commitment to universal accountability norms is also evident in the 2025 announcements by five States of their intention to withdraw from the ICC. This decline is also evident in the failure by certain States Parties to cooperate with the Court, specifically in executing ICC arrest warrants against individuals present on their territories.
The importance of synergies and of overcoming challenges
These developments risk entrenching double standards and eroding the credibility of international criminal justice. At a time where accountability mechanisms are strained, coordination and cooperation between different actors becomes more crucial than ever. This year’s UJAR demonstrates that, where such synergies exist, they can deliver concrete results.
At the same time, universal and other forms of extraterritorial jurisdiction’s effectiveness face limitations. Their effectiveness is shaped by power dynamics and depends on specialised units and adequate resources. Strengthening legal frameworks and capacities remains essential to closing widening accountability gaps.
Throughout 2025, a lack of prioritisation and coordination remained evident in the context of the Israeli military operation in Gaza. However, a few States took some initial steps, and civil society continued to be central in driving efforts to seek accountability.
Many contexts where international crimes continue to be committed on a mass scale remain largely absent in universal and extraterritorial jurisdiction practice. As pressure grows, States committed to the international rule of law must strengthen their capacity to act.
Read and download the UJAR 2026
About the UJAR 2026
The UJAR 2026 was researched and written by UpRights. It is produced as part of the “Global Initiative against Impunity for International Crimes and Serious Human Rights Violations: Making Justice Work” (GIAI). The GIAI is a global civil society-led programme, co-funded by the European Union, that promotes inclusive, integrated, comprehensive justice and accountability for serious human rights violations worldwide.
The UJAR 2026 has been produced with the financial support of the City of Geneva, the European Union, Oak Foundation and the Taiwan Foundation for Democracy. The contents of this publication are the sole responsibility of TRIAL International and can under no circumstances be regarded as reflecting the positions of the above-mentioned donors.
The artwork featured on the cover is part of a series of court sketches created by Augustin Guichot for TRIAL International during the trial of former Congolese rebel leader Roger Lumbala, which took place in Paris from 12 November to 19 December 2025.
]]>“Spear tried to assassinate me ten years ago. I survived but have been forced to live in exile separated from my family,” said Mr. Ali Mayo. “The U.S. government has a responsibility to ensure Spear and its operatives are brought to justice.”
In 2015, the United Arab Emirates (UAE) intervened in the Yemeni civil war as part of a regional coalition, backed by the United States. Under the guise of “counterterrorism” and as part of its intervention in the conflict in Yemen, the UAE targeted groups and individuals opposed to its interests, including Mr. Ali Mayo.
As alleged in the complaint, the UAE hired Spear to assassinate its political opponents as part of its military operations in Yemen. Spear founder and CEO, Defendant Abraham Golan, recruited highly skilled former members of the U.S. military, including former Navy SEAL Defendant Isaac Gilmore and former member of the U.S. Special Forces Defendant Dale Comstock. The UAE allegedly paid Spear $1.5 million a month for these services, with additional bonuses for successful killings. The defendants have all admitted to their roles in the assassination program and the attempt on Ali Mayo’s life.
“Spear recruited individuals trained at the expense of U.S. taxpayers to commit war crimes in Yemen, and used their U.S. training as marketing to land a lucrative contract with the UAE—a known human rights violator” said Ela Matthews, CJA’s Director of Partnerships and Justice Initiatives. On December 29, 2015, the complaint alleges, Spear planted explosive devices at Mr. Ali Mayo’s office building in an attempt to kill him and everyone in the building. Unbeknownst to them, Mr. Ali Mayo had fled minutes before the explosion. Following the assassination attempt, he fled Yemen.
“By failing to sufficiently regulate and prosecute the illegal actions of former U.S. military members, the U.S. is facilitating the sale of unchecked lethality to the highest bidder,” said CJA Legal Director Daniel McLaughlin. “Our government has a duty to regulate how former members of our military use their training and know-how, and a responsibility to hold them accountable when they break the law.”
More information on the case can be found here.
For media enquiries please contact:
Ela Matthews (London, UK): ematthews@cja.org, +447862 728 939
Daniel McLaughlin (California, USA): dmclaughlin@cja.org, +1 (415) 544-0444
About the Center for Justice & Accountability
The Center for Justice and Accountability (CJA) is a United States-based international human rights organization dedicated to working with communities impacted by torture, war crimes, crimes against humanity, and other serious human rights abuses to seek truth, justice, and redress using innovative litigation and transitional justice strategies. CJA has successfully brought cases against defendants such as the commander in charge of the Lutheran Church Massacre in Liberia, the military officer responsible for the assassination of Chilean activist and singer Víctor Jara, and Syria’s Assad regime for its targeted killing of war correspondent Marie Colvin and its campaign of torture in its detention centers.
]]>During the historic nine-day trial, the jury heard evidence that Mr. Alsheikh was the head of Adra Prison from about 2005 to 2008, where he ordered the torture of political dissidents and other detainees while overseeing an underground “Punishment Wing”, also known as Wing 13. Mr. Alsheikh and other prison officers brutally tortured detainees, including by beating them with batons and braided cables, strapping them to a device known as the “magic carpet”, and suspending them from ceiling pipes. The jury of 12 unanimously found Mr. Alsheikh guilty of torture and conspiracy to commit torture. Judge Hernán Vera who presided over the trial, will determine Mr. Alsheikh’s sentence at a hearing later this year. Mr. Alsheikh can appeal the verdict.
“Alsheikh’s conviction represents a critical milestone toward justice for us and other victims, and it is a pivotal moment for all those who have suffered within the Assad regime’s prison system,” said Khaled Abdul Malek, Center for Justice and Accountability (CJA) client and former Adra detainee who was tortured by Alsheikh. Nidal Shikhani, another CJA client who testified at trial about the abuses he suffered at Adra, said “For survivors like me, being heard in a court of law is not only about the past, it is also about dignity. It is about affirming that even after many years, the truth still matters and the suffering of victims cannot be ignored. Today represents the beginning of a broader accountability process, not the end.” CJA represents nine victims and witnesses in the case against Mr. Alsheikh, three of whom testified at trial.
Mr. Alsheikh was convicted under the extraterritorial Torture Act, which allow the U.S. government to arrest and prosecute individuals found within the United States for acts of torture committed abroad. This trial drew significant attention from human rights advocates, legal experts and Syrian civil society organizations as Mr. Alsheikh was the highest-ranking Assad regime official to be tried in person anywhere in the world, and only the fifth person tried since the Torture Act’s enactment in 1994. “At a time when human rights protections are under threat, this case is evidence that the U.S. legal system can offer a meaningful venue for accountability — that our institutions are still capable of delivering justice for survivors of atrocities.” said Ahmad Soliman, CJA staff attorney.
About the Center for Justice & Accountability
The Center for Justice and Accountability (CJA) is a United States-based international human rights organization dedicated to working with communities impacted by torture, war crimes, crimes against humanity, and other serious human rights abuses to seek truth, justice, and redress using innovative litigation and transitional justice strategies.
More Information
To learn more about CJA’s work on accountability for crimes in Syria, please see here.
Answers to frequently asked questions regarding the Alsheikh trial can be found here.
Or please contact:
Daniel McLaughlin, CJA Legal Director, dmclaughlin@cja.org
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Dear Friends,
As I prepare to step down as Executive Director of the Center for Justice and Accountability, I find myself reflecting on a simple truth that has guided our work: the most difficult challenges are always better tackled with friends by your side.
And what friends you have been. Together, we’ve fought alongside survivors seeking justice, achieved accountability where it seemed impossible, and built a community united by the belief that human rights matter everywhere, for everyone.
I am deeply grateful to our extraordinary staff, whose dedication and expertise inspire me daily; to our partners around the world who have trusted us and taught us; and to all of you who have supported this mission with your time, resources, and unwavering commitment.
As I move forward, I do so with tremendous optimism for CJA’s future. The organization is strong, the team is exceptional, and the need for this work has never been clearer. I am excited to join all of you as supporters of CJA as it writes its next chapter—because this community, these friendships, are what make the impossible possible.
Thank you for everything.
With deep appreciation,
Carmen Cheung Ka-man
p.s. I ask one final favor: consider making a donation to CJA today. Your support will ensure this vital work continues and grows in the years ahead. Thanks to a $100,000 matching challenge from our generous supporters, your donation will go twice as far.
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Rita Maran was a fierce advocate for human rights, a committed scholar, and one of CJA’s founding board members. Her life’s work—spanning activism, diplomacy, teaching, and research—embodied the principles at the heart of CJA’s mission: justice, accountability, and dignity for survivors of torture and grave human rights abuses.
From her early activism during World War II to her academic work on state violence and ideology, Rita never turned away from injustice. Her landmark book Torture: The Role of Ideology in the French-Algerian War revealed the systemic roots of brutality, a theme she carried into her work at CJA. She believed survivors not only deserved to be heard but to see justice done through the rule of law.
As a founding board member, Rita helped shape CJA into a global force for legal accountability, using the courts to pursue truth and redress where political will failed. Her moral clarity, deep compassion, and intellectual rigor laid a foundation that continues to guide the organization’s work today.
Rita is survived by her son, Drew (partner Sandie), and daughter Meredith (partner Denise); their four children, Peter Josie, Jesse, and Nick; six great-grandchildren: Josie’s two daughters Rumi and Indie, Nick’s daughter Nara, and Peter’s children, Axel Emme, and Rizzy; two nieces, Sara Lynn and Natalie; and their children.
Rita Maran leaves behind a legacy of action, courage, and unyielding dedication to human rights. CJA—and the broader movement for justice—is stronger because of her.
]]>During today’s sentencing hearing, Judge Christine M. Arguello, who presided over Mr. Correa’s trial in April, heard from victims about the impact the torture they experienced at the hands of Mr. Correa and other Junglers had on their lives and that of their families.
Yaya Darboe, a commanding officer in the Gambian Armed Forces, who had been tortured by Mr. Correa asked the Court to impose a 40-year sentence because Mr. Correa “must be held fully accountable for his actions. When I saw him in Colorado at the trial, he was smiling, showing no remorse. He tried to escape justice. He should not be allowed to do so.”
“Justice in this case is not only about punishment; it is about restoring faith in the rule of law for victims like me, and for the Gambian people,” said Demba Dem, a former member of The Gambia’s Parliament. “I am glad that Mr. Correa received a fair trial. It is more than I and many others received, but it is important for true justice.”
Mr. Correa was initially arrested in September 2019 by the U.S. Department of Homeland Security for overstaying an expired visa. A coalition of Correa’s victims, Gambian civil society organizations, and international human rights organizations, including the Center for Justice and Accountability (CJA) and TRIAL International called on the U.S. to investigate claims that Correa committed torture. This led to his indictment for torture in 2020. CJA now represents five of Mr. Correa’s victims in the criminal prosecution with co-counsel King and Spalding LLP.
In April, a unanimous jury found Mr. Correa guilty of torture and conspiracy to commit torture. At the trial, evidence established that Mr. Correa was a member of the Junglers, a notorious death squad in The Gambia. Victims and witnesses testified that following an attempted coup against former President Yahya Jammeh’s dictatorship in 2006, Mr. Correa and other Junglers brutally tortured suspected participants in the coup, including by beating them, suffocating them with plastic bags, and subjecting them to electric shocks.
“I pray that this sentence will send a resounding message to all purveyors of human suffering, that their cruelty will be met with severe punishment,” said Ramzia Diab, one of the Junglers’ victims and a survivor of torture. Ms. Diab is a former member of The Gambia’s Parliament, and former Gambian Ambassador to the Association of Southeast Asian Nations (ASEAN). “It will show that the rule of law can reach even those who once believed they were untouchable.”
The case comes at an important moment for The Gambia’s transitional justice process. In 2021, the Gambian Truth, Reconciliation and Reparations Commission (TRRC) concluded that former president Jammeh and 69 of his associates, including Mr. Correa, committed crimes against humanity in The Gambia. Most perpetrators have yet to be held accountable. Elizabeth Mendy, widow of former Gambian Armed Forces lieutenant colonel Pierre Mendy said: “The TRRC gave Pierre a chance to speak, but nothing concrete has come from it. Justice sleeps in The Gambia. The Junglers who fled hide abroad. Those who stayed walk freely.” She asked the court to sentence Correa to life imprisonment to send a message to The Gambia to find the courage to move ahead with prosecutions.
Last year The Gambia took significant steps towards justice, including passing legislation aimed at creating a war crimes tribunal in the Gambia and securing ECOWAS’s approval to establish the tribunal. Victims hope that The Gambia will act swiftly to establish its hybrid court to prosecute the remaining perpetrators identified in the TRRC report.
“This decision will resonate far beyond this courtroom,” said Tamsir Jasseh, one of Mr. Correa’s victims. He currently serves as advisor to the Gambian Police and spoke during today’s hearing. “The United States’ involvement in this case has already encouraged Gambian authorities to take accountability seriously. This trial is a catalyst, a jumpstart, for our nation’s journey toward truth, justice, and healing.”
About the Alliance of Victim-Led Organisations (AVLO)
The Alliance of Victim-Led Organisations (AVLO) is a coalition of Gambian civil society organizations that has been championing and representing the interests of victims of human rights violations in The Gambia.
About the Center for Justice & Accountability
The Center for Justice and Accountability (CJA) is a United States-based international human rights organization dedicated to working with communities impacted by torture, war crimes, crimes against humanity, and other serious human rights abuses to seek truth, justice, and redress using innovative litigation and transitional justice strategies.
About TRIAL International
TRIAL International is an international NGO fighting impunity for international crimes such as genocide, crimes against humanity, war crimes, torture, enforced disappearances and conflict-related sexual violence. Founded in 2002, it has offices in Switzerland, Bosnia and Herzegovina and the Democratic Republic of the Congo (DRC).
More Information
Read answers to Frequently Asked Questions here.
Or please contact:
U.S. Federal Court will be conducting sentencing hearing of former Jungler, Michael Sang Correa on August 22, 2025, in Denver, Colorado, USA.
On April 15, 2025, after a five-day trial in U.S. federal court, a Denver jury found Michael Sang Correa guilty of five counts of torture and one count of conspiracy to commit torture. Mr. Correa was a member of the Junglers, a notorious death squad in The Gambia.
Judge Christine M. Arguello, who presided over the trial, scheduled Mr. Correa’s sentencing for August 22, 2025. Mr. Correa faces up to 120 years in prison.
During the trial, victims and witnesses who traveled to Colorado from The Gambia testified that in 2006, Mr. Correa and other Junglers brutally tortured suspected participants in an attempted coup against former President Yahya Jammeh. Fatou Baldeh, Founder & CEO of Women in Liberation and Leadership (WILL), attended the trial. “It was very moving sitting in front of Mr. Correa and seeing the evidence presented by the prosecution,” she said. “The victims were afforded an opportunity to face their perpetrator, and you could see they got their power back.” Zainab Lowe, a prominent victims’ rights advocate in The Gambia, was also present in Denver for the trial. “The jury’s unanimous verdict was felt all the way in The Gambia” she said. “It sent a strong message that The Gambia must continue to work to ensure all Junglers are held to account and that other victims of human rights abuses get justice.”
At the sentencing hearing, both the prosecution and the defense will present arguments in support of the sentences they believe should be imposed. Some of Mr. Correa’s victims will have an opportunity to present statements describing how Correa’s s crimes impacted their lives. The U.S. government is recommending that Judge Arguello impose the maximum sentence of 120 years in prison.
“Correa’s conviction, together with a significant sentence will send a strong message to other Junglers and other human rights abusers, currently living with impunity that they will too face justice,” said Ayeshah Jammeh of the Gambian Center for Victims of Human Rights Violations and the Victim’s Podcast. “Correa’s sentencing also serves as a reminder to The Gambian government that there are still Junglers living freely in Banjul who must be brought to justice” said Muhammed Sandeng of the Solo Sandeng Foundation, “our government must follow through on its promise to establish a hybrid court to prosecute the remaining Jammeh-era perpetrators.”
After sentencing, Mr. Correa can appeal the jury’s verdict on limited grounds. For more information about Mr. Correa’s right to appeal, read our Frequently Asked Questions
About the Alliance of Victim-Led Organisations (AVLO)
The Alliance of Victim-Led Organisations (AVLO) is a coalition of Gambian civil society organizations that has been championing and representing the interests of victims of human rights violations in The Gambia
About the Center for Justice & Accountability
The Center for Justice and Accountability (CJA) is a United States-based international human rights organization dedicated to working with communities impacted by torture, war crimes, crimes against humanity, and other serious human rights abuses to seek truth, justice, and redress using innovative litigation and transitional justice strategies.
About TRIAL International
TRIAL International is an international NGO fighting impunity for international crimes such as genocide, crimes against humanity, war crimes, torture, enforced disappearances and conflict-related sexual violence. Founded in 2002, it has offices in Switzerland, Bosnia and Herzegovina and the Democratic Republic of the Congo (DRC).
More Information
Read answers to Frequently Asked Questions here.
Or please contact:
Obada, an American citizen, was detained in the Mezzeh Military Airport, where he was tortured until his family secured his release.
Obada’s arbitrary arrest and torture was not an isolated incident. During President Bashar al-Assad’s rule over Syria, the government enacted an extensive system of mass arrest, detention, interrogation, torture and murder. Syrian and international organizations have documented the torture-related deaths of roughly 15,000 individuals at the hands of the Assad regime since 2011 and the enforced disappearances of nearly 100,000 more. While the regime collapsed in December 2024, the fates of many who disappeared into Assad’s prisons are still unknown.
The court’s decision today is based on sworn testimony of more than 30 individuals who had been detained and tortured at the Mezzeh Military Airport and the expert reports of five international experts. In addition, the court heard live testimony from torture survivors and an expert on psychological torture. “Today’s ruling by a U.S. court is an important formal acknowledgment of the Assad regime’s brutal system of torture,” said Ruth Montiel, an attorney at Freshfields US LLP.
“Following Assad’s ouster, thousands of people were released from the regime’s vast network of prisons. However, over 100,000 detainees reportedly remain unaccounted for,” said CJA Senior Staff Attorney Daniel McLaughlin. “Today’s judgment is a reminder that it is critical that the new government in Syria and its international partners have important roles to play in advancing work aimed at discovering what has happened to those who disappeared in Assad’s prisons and supporting the detainees who survived.”
The Court will issue the reasons for its judgment and determine damages at a future date.
More information
More information on the case, including evidence from former detainees and international experts, can be found here. Learn more about CJA’s work on human rights in Syria here. Answers to frequently asked questions about the case can be found here.
For press inquiries, please contact:
Daniel McLaughlin: dmclaughlin@cja.org
About the Center for Justice & Accountability and its Partners
The Center for Justice and Accountability (CJA) is a United States-based international human rights organization dedicated to working with communities impacted by torture, war crimes, crimes against humanity, and other serious human rights abuses to seek truth, justice, and redress using innovative litigation and transitional justice strategies.
Freshfields is a global law firm with a long-standing track record of anticipating change, setting new standards and shaping the future of law. We successfully support the world’s leading national and multinational corporations, financial institutions and governments on complex and business-critical mandates when it matters most. Our 2,800-plus lawyers and other legal professionals are steadfast champions of our clients and we are proud to be recognized as a top-tier leader in the practice areas most important to clients around the world.
CJA owes a huge debt of gratitude to the coalition of justice-seeking organizations and individuals who contributed immeasurably to this case, including the Syrian Center for Media and Freedom of Expression (SCM) and the Syria Justice and Accountability Centre (SJAC), which facilitated the written testimony of 21 and 8 former detainees, respectively. Partners page to learn more about all of our partners’ work.
]]>“Correa’s trial and conviction represent an important milestone towards justice for his direct victims, and it is another step towards justice for all who suffered under Jammeh’s regime,” said Tamsir Jasseh, who currently serves as a senior advisor to the Gambian Police. “This verdict demonstrates that we can end impunity for the widespread abuses that took place during those years, both abroad and in The Gambia,” said Demba Dem, a former member of The Gambia’s Parliament. “This verdict is crucial for the healing of the victims and of Gambian society,” said Yaya Darboe, a commanding officer in the Gambian Armed Forces. All three men testified about the torture they endured at the hands of Mr. Correa.
The case against Mr. Correa was brought under the extraterritorial Torture Act, a federal law which allows the U.S. government to prosecute individuals found within the United States for acts of torture committed abroad. The case has drawn significant attention from human rights advocates and legal experts, as it is the first trial of a non-U.S. citizen under the Act. Mr. Correa is only the third person to be convicted under the Act since its enactment in 1994.
“This is a momentous trial, not only for The Gambia, but also for the United States. Countries have an obligation to investigate and prosecute perpetrators of international crimes who are found within their territory,” said Ela Matthews, Center for Justice and Accountability Senior Staff Attorney. “By prosecuting Correa, the United States has shown its commitment to fulfilling these obligations.”
Victims and Gambian civil society played a crucial role in ensuring that Mr. Correa was brought to justice, and that the trial received coverage in The Gambia. Jammeh regime victims traveled from The Gambia to Denver to observe the proceedings and 11 people testified.
According to Vony Rambolamanana, Senior Legal Advisor at TRIAL International: “Correa’s conviction, together with the recent convictions of former Jungler Bai Lowe in Germany and Gambian former Interior Minister Ousman Sonko in Switzerland, underscores the critical importance of universal and extraterritorial jurisdiction laws in bringing justice to survivors of international crimes committed in countries where impunity is rampant.”
In 2021, the Gambian Truth, Reconciliation and Reparations Commission (TRRC) concluded that former president Jammeh and 69 of his associates, including Mr. Correa, committed crimes against humanity in The Gambia. The vast majority of perpetrators have yet to be held accountable. Last year, The Gambia took significant steps towards justice, including passing legislation aimed at creating a war crimes tribunal in the Gambia and securing ECOWAS’s approval to establish the tribunal.
“Correa’s conviction is very significant in the quest for justice for victims of human rights violations, but many Junglers and other human rights abusers continue living in impunity. Some are even living freely in Banjul,” said Kadijatou Kuyateh, Press Relations Officer at the Alliance of Victim-Led Organisations. “The Gambia must act swiftly to establish its hybrid court to prosecute the remaining perpetrators identified in the TRRC report.”
About the Center for Justice & Accountability
The Center for Justice and Accountability (CJA) is a San Francisco-based international human rights organization dedicated to working with communities impacted by torture, war crimes, crimes against humanity, and other serious human rights abuses to seek truth, justice, and redress using innovative litigation and transitional justice strategies.
About the Alliance of Victim-Led Organisations (AVLO)
The Alliance of Victim-Led Organisations (AVLO) is a coalition of Gambian civil society organizations that has been championing and representing the interests of victims of human rights violations in The Gambia.
About TRIAL International
TRIAL International is an international NGO fighting impunity for international crimes such as genocide, crimes against humanity, war crimes, torture, enforced disappearances and conflict-related sexual violence. Founded in 2002, it has offices in Switzerland, Bosnia and Herzegovina and the Democratic Republic of the Congo (DRC).
More Information
Read answers to Frequently Asked Questions here.
Or please contact:
Read or download the full UJAR 2025 (PDF)
The UJAR 2025 was researched and written by UpRights. It has been produced with the financial support of the City of Geneva, the European Union, Oak Foundation, and the Taiwan Foundation for Democracy. The photograph shown on the publication’s cover was made by Bashar Taleb on 7 October 2023 in Gaza City. It was compiled in collaboration with Civitas Maxima, CJA, ECCHR, FIDH, REDRESS, and TRIAL International.
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