Chicago Journal of International Law legal standards regarding corporate liability limit culpability to natural persons. Having introduced the pertinent international criminal law (ICL), Section V applies the law to hypothetical cases at different levels of the corporate hierarchy. II. P ERTINENT I NTERNATIONAL C RIMES This Comment opens with a discussion of two international crimes: genocide and direct and public incitement to commit genocide. For the scope of this Comment, ICL refers to the body of international law, composed largely of treaty law and caselaw, which imposes criminal liability on individuals.27 As the most recent and comprehensive treaty on ICL, the Rome Statute of the International Criminal Court (Rome Statute) necessarily anchors discussion of ICL. Entered into force in 2002, the Rome Statute established the ICC as a permanent international court and empowered the court to examine ICL principles beyond the treaty’s plain terms.28 Article 21 of the Rome Statute authorizes the ICC to apply ICL from “applicable treaties and the principles and rules of international law.”29 Accordingly, a proper understanding of ICL today requires reference to older treaty law as well as caselaw more generally. This Comment ultimately focuses on direct and public incitement to commit genocide in the context of social media. However, a brief overview of genocide provides useful context to understanding incitement. A. Genocide Considered by some to be the “crime of crimes,” genocide carries unique weight in ICL.30 Genocide was criminalized in 1951, when the Convention on the Prevention and Punishment of Genocide (Genocide Convention) entered into force.31 The treaty’s ratification came as the world reeled from the horrors that World War II inflicted upon civilian populations. Mass atrocities committed 27 28 29 30 31 See William W. Burke-White, A Community of Courts: Toward a System of International Criminal Law Enforcement, 24 MICH. J. INT’L L. 1, 76 (2002) (“Unlike most fields of international law, the primary obligations imposed by international criminal law are on individuals, not on States.”). See Alexander Greenawalt, The Pluralism of International Criminal Law, 86 IND. L. J. 1063, 1080 (2011) (“In the first place, even the relatively detailed provisions of the Rome Statute will require judicial construction.”). See Rome Statute of the International Criminal Court, art. 21, July 17, 1998, 2187 U.N.T.S. 90 [hereinafter Rome Statute]. See, for example, William A. Schabas, National Courts Finally Begin to Prosecute Genocide, the ‘Crime of Crimes’, 1 J. INT’L CRIM. JUST. 39, 43 (2003) (referring to genocide as the “crime of crimes”). Convention on the Prevention and Punishment of the Crime of Genocide, Dec. 9, 1948, 102 Stat. 3045, 78 U.N.T.S. 277, 278 (“Came into force on 12 January 1951 . . . .”) [hereinafter Genocide Convention]. 88 Vol. 21 No. 1