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University of Baltimore School of Law's Center for International and Comparative Law Fellows discuss international and comparative legal issues


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The Double-Edged Sword in the Stone: London’s Fate as a Seat of International Arbitration Post-Brexit

Esther-Jane Grenness

Her chest tightened and her palms began to sweat when an email popped up in her inbox with the subject line, “Attention HSBC London Employees.” Her worst fears were confirmed. Her job was moving to Paris as “preemptive action” in response to Brexit uncertainties.[1] She picked up her phone and dialed her father’s number. A Welsh collier who eagerly voted “Yes!” to leave the EU, he picked up the phone, happy to see his daughter calling. Without even saying hello, she blurted, “Thanks a lot, Da! My job’s to move to France because you an’ all voted to give them the boot.” Tears welled up in her eyes. After a moment’s pause, her father exclaimed, “Bloody foreign loving bastards! Shame on them. They’re a British bank.” Dejected, she mumbled, “It’s all because of Brexit.”

Brexit is the term used to describe the United Kingdom’s June 2016 referendum in which 51.9% of the eligible electorate voted to leave the European Union.[2] Not expecting it to actually happen, the United Kingdom must now decide how, and when, to trigger Article 50 of the Treaty on the Functioning of the European Union (TFEU – or Lisbon Treaty). Article 50 gives the U.K. two years in which to negotiate its exit, but the legislation that links the U.K. and EU is exceedingly complex. Not surprisingly, experts argue it could take ten years to unravel legal ties going back 45 years to the enactment of the European Communities Act of 1972.[3]

The Razor Edge

There is no doubt that Brexit has the British financial markets in turmoil. In addition to HSBC’s dash for the door, VTB Bank, a Russian bank, announced recently that it will also relocate due to Brexit.[4] Moves like this highlight the depth of the Brexit sword’s cut. London is a major player in the financial clearing sector, which is where banks act as intermediaries in business transactions.[5] As a member of the EU, the U.K. enjoys what is known as passporting, which allows the free flow of funds between countries in the European Economic Area (EEA).[6] Without such a free flow, additional regulatory authorizations would be necessary.[7] Brexit strips the U.K. of these EU benefits and leaves the U.K.’s financial market clout teetering on the edge of a sea of quicksand. And it’s not just the free flow of money that’s implicated in Brexit. The heretofore mobile workforce with expertise in “complex and multi-jurisdictional matters”[8] will be curtailed. British lawyers who are currently allowed to “provide interstate services on a temporary basis” in EU member states could lose that right if Brexit goes through.[9] Indeed, experts argue London could lose as many as 18,000 jobs in the legal and accounting services sector, and 83,000 total jobs over the next seven years as a direct result of Brexit.[10]

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The Blunt Edge

Where does this financial sector flight leave the international arbitration business in London? According to a 2015 survey, London is one of the most popular seats of international arbitration.[11] British law is also among the most widely chosen law to govern international commercial contracts—whether or not the contract was formed, performed, or even remotely related to Britain.[12] With such a top spot, the U.K. understandably doesn’t want to lose its primacy to competing international arbitration seats such as Paris, Dubai, Singapore, Hong Kong, Geneva, New York, Zurich, and Stockholm.”[13]

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Most writers on the subject believe London’s primacy as a seat for international arbitration will chug along “business as usual.”[14] There are two major reasons. First, EU law doesn’t govern arbitral awards. Rather, any awards granted in London are governed by the Convention on the Recognition and Enforcement of Foreign Arbitral Awards, also known as the New York Convention. This Convention allows parties to enforce arbitral awards in the domestic courts of any of its 156 member states. Second, the U.K.’s Arbitration Act of 1996 is very friendly to arbitration. Britain’s courts take a largely hands off approach but will step in to assist arbitral tribunals with such things as compelling witnesses to testify, preserving evidence, and ordering injunctive relief.[15]

Other arguments posed are that because the U.K. would no longer be bound by rulings from the Court of Justice of the European Union (CJEU), any precedent considered harmful to arbitration could be cast aside.[16] They argue further that in the field of investor-state arbitration, Brexit has its perks. After Brexit, the U.K. would not be bound by the EU’s recent move away from investor-state dispute settlement (ISDS) to an untested investment court system (ICS). Under the current ISDS model, investors are allowed a voice in choosing the arbitrators that will hear their case. Under the EU’s new ICS model, investors would no longer have a voice in arbitrator selection. Only member states would manage the names on a revolving roster of randomly appointed arbitrators. In a post-Brexit world, investors could continue to cherry pick from the various investment treaties to which the U.K. is a party in its own right. Investors could also happily anticipate the new investment treaties the U.K. would now be free to negotiate on its own behalf.

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Given these sunny predictions, one quickly nods one’s head in agreement with such common sense arguments. The sword is still in the stone, however. More recent studies have pointed out that the proponents of these arguments are largely U.K. centered practitioners, who are naturally biased in favor of keeping London at the top of the list.[17] In addition, optimists downplayed the significance of the financial sector’s flight. Even the most myopic commentators had to acknowledge London’s primacy as a seat of arbitration is “undeniably influenced by its role as an international business hub,” but they were quick to soften the potential “knock-on effect” as “expected to be minimal.”[18] A more realistic prediction for this blunt side of the sword is that an “exodus of businesses” would eviscerate London’s status as the financial hub in Europe.[19] Therefore, if London lost its status “and something else becomes the financial center of Europe, over time you may see arbitration gravitate that way.”[20]

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As a British national living abroad, I wasn’t eligible to participate in the U.K. referendum. I wish I could say I agree with the optimists, but the writing is on the wall. Most of the financial sector jobs are moving to Paris.[21] Because Paris is one of London’s competitors for international arbitration market share, it’s only a matter of time before the arbitration business bleeds out of London. The people of Britain have their hands on both edges of the Brexit sword, but as they pull it out of the stone, London’s international arbitration market is likely to wind up cut just as deeply as that of its financial sector.

­

Esther-Jane Grenness is an evening student in her fourth year of studies at the University of Baltimore School of Law. She graduated from the University of Baltimore in 2013 with a Bachelor of Arts in Jurisprudence and obtained her Associate of Arts from Howard Community College in 2001. Esther is a member of the International Arbitration Committee’s Investment Treaty Working Group of the American Bar Association’s Section of International Law. She also participated in the Mentorship program with the Women in International Law Interest Group of the American Society of International Law. In addition to her studies, Esther coordinates government procurement contracts in the mobility sales operations group for AT&T’s Global Business – Public Sector Solutions segment.

 

[1] Chris Johnson, HSBC Prepares to move 1,000 U.K. Jobs to Paris Due to Brexit Confusion, Law.com (Jan. 11, 2017), http://www.law.com/sites/almstaff/2017/01/11/hsbc-prepares-to-move-1000-u-k-jobs-to-paris-due-to-brexit-confusion/?et=editorial&bu=Law.com&cn=20170111&src=EMC-Email&pt=ALM%20Morning%20Minute&slreturn=20170021202538.

[2] King & Wood Mallesons, Brexit and Arbitration: Shaken but not Stirred, KWM News & Insights (Sept. 15, 2016), http://www.kwm.com/en/knowledge/insights/the-impact-of-brexit-on-international-arbitration-20160915.

[3] Caroline Simson, What Brexit Could Mean for International Arbitration, Law360 (Jun. 22, 2016, 5:22 PM EDT), https://www.law360.com/articles/808801/what-brexit-could-mean-for-international-arbitration.

[4] Chris Johnson, EY Report: Brexit Could Cost London 18,000 Legal, Accounting Jobs, The Am Law Daily (Nov. 14, 2016), http://www.americanlawyer.com/id=1202772254983/EY-Report-Brexit-Could-Cost-London-18000-Legal-Accounting-Jobs?mcode=1202617075486&curindex=0&curpage=ALL&slreturn=20170021203506.

[5] Clearing, Investopedia, http://www.investopedia.com/terms/c/clearing.asp (last visited Jan. 20, 2017).

[6] What is Passporting? Definition and Meaning, Market Business News, http:/marketbusinessnews.com/financial-glossary/passporting-definition-meaning/ (last visited Jan. 20, 2017).

[7] Id.

[8] James Rogers, Simon Goodall and Charles Golsong, How will Brexit impact arbitration in England and Wales? It’s Business As Usual, Norton Rose Fulbright, 16 (Sep. 25, 2016), http://www.nortonrosefulbright.com/files/international-arbitration-report-issue-7-142408.pdf.

[9] Caroline Simson, Post-Brexit Barriers Could Hurt London Arbitration: Study, Law360 (December 15, 2016, 5:18 PM EST), https://www.law360.com/articles/872676/post-brexit-barriers-could-hurt-london-arbitration-study.

[10] Chris Johnson, EY Report: Brexit Could Cost London 18,000 Legal, Accounting Jobs, The Am Law Daily (Nov. 14, 2016), http://www.americanlawyer.com/id=1202772254983/EY-Report-Brexit-Could-Cost-London-18000-Legal-Accounting-Jobs?mcode=1202617075486&curindex=0&curpage=ALL&slreturn=20170021203506.

[11] Caroline Simson, Post-Brexit Barriers Could Hurt London Arbitration: Study, Law360 (December 15, 2016, 5:18 PM EST), https://www.law360.com/articles/872676/post-brexit-barriers-could-hurt-london-arbitration-study.

[12] James Rogers, Simon Goodall and Charles Golsong, How will Brexit impact arbitration in England and Wales? It’s Business As Usual, Norton Rose Fulbright, 16 (Sep. 25, 2016), http://www.nortonrosefulbright.com/files/international-arbitration-report-issue-7-142408.pdf

[13] Caroline Simson, Post-Brexit Barriers Could Hurt London Arbitration: Study, Law360 (December 15, 2016, 5:18 PM EST), https://www.law360.com/articles/872676/post-brexit-barriers-could-hurt-london-arbitration-study.

[14] James Rogers, Simon Goodall and Charles Golsong, How will Brexit impact arbitration in England and Wales? It’s Business As Usual, Norton Rose Fulbright, 15 (Sep. 25, 2016), http://www.nortonrosefulbright.com/files/international-arbitration-report-issue-7-142408.pdf

[15] James Rogers, Simon Goodall and Charles Golsong, How will Brexit impact arbitration in England and Wales? It’s Business As Usual, Norton Rose Fulbright, 16 (Sep. 25, 2016), http://www.nortonrosefulbright.com/files/international-arbitration-report-issue-7-142408.pdf

[16] King & Wood Mallesons, Brexit and Arbitration: Shaken but not Stirred, KWM News & Insights (Sept. 15, 2016), http://www.kwm.com/en/knowledge/insights/the-impact-of-brexit-on-international-arbitration-20160915.

[17] Maxi Scherer and Johannes Koepp, Consequences of “Brexit” on International Dispute Resolution: Special Issue of Journal of International Arbitration, Kluwer Arbitration Blog, (Oct. 21, 2016), http://kluwerarbitrationblog.com/2016/10/21/consequences-brexit-international-dispute-resolution-special-issue-journal-international-arbitration/.

[18] James Rogers, Simon Goodall and Charles Golsong, How will Brexit impact arbitration in England and Wales? It’s Business As Usual, Norton Rose Fulbright, 18 (Sep. 25, 2016), http://www.nortonrosefulbright.com/files/international-arbitration-report-issue-7-142408.pdf

[19] Caroline Simson, What Brexit Could Mean for International Arbitration, Law360 (Jun. 22, 2016, 5:22 PM EDT), https://www.law360.com/articles/808801/what-brexit-could-mean-for-international-arbitration.

[20] Id.

[21] Chris Johnson, HSBC Prepares to move 1,000 U.K. Jobs to Paris Due to Brexit Confusion, Law.com (Jan. 11, 2017), http://www.law.com/sites/almstaff/2017/01/11/hsbc-prepares-to-move-1000-u-k-jobs-to-paris-due-to-brexit-confusion/?et=editorial&bu=Law.com&cn=20170111&src=EMC-Email&pt=ALM%20Morning%20Minute&slreturn=20170021202538.

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Further Brexit Complications: On Patents

John Rizos

Milan: home of fashion, of a historic soccer rivalry, and of… intellectual property protection? Well, of course! Milan is a center of life science innovators and international property expertise[1]. The Milanese Court manages most of Italy’s patent litigation and hosts the majority of Italy’s intellectual property practitioners[2].

In response to the Brexit vote,  the Italian Trade Body in Milan (L’Ordine dei Consulenti in Proprietà Industriale) wants to replace the Court of First Instance in London, which handles claims related to pharmaceutical patents, since the court would apply EU law and Court of Justice of European Union (CJEU) rulings.  The UK Intellectual Patent Office (UKIPO), however, stated that it will preserve and implement EU regulations and abide by them as signatory to the Unified Patent Court Agreement (UPCA)[3]. The UK was historically one of the main supporters of the unified patents, had lobbied extensively to host the court in London, and had worked in advance in preparation for the system[4].

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Intellectual property protection is a huge factor in the EU’s goal of harmonizing domestic laws, mainly achieved by removal of technical obstacles and implementation of directives[5]. Recently, the focus has been on harmonizing the intellectual property industry, especially patents[6]. The European Patent Convention (EPO) was signed in agreement in 1973[7], independent from the EU, comprised of EU and non-EU members. In 2013, 25 EPO States signed the Unified Patent Court Agreement (UPCA). It aims to establish the Unified Patent Court (UPC)[8] and a system of uniform patent protection throughout EPO States on new patents from any other EPO State[9]. Although it is independent from the EU, it comprises mostly EU law and can only be ratified by EU members[10]. The UPC will centralize disputes[11] through a main court in Paris with jurisdiction over legal disputes regarding patents, and two courts with jurisdiction over patents with specialized subject matter; one in Munich for engineering issues and one in London for disputes in pharmaceuticals and life sciences[12].

UK patent laws are formed by a mixture of domestic and EU laws, as many have been enacted in response to treaties and European cooperation. The UK’s ratification will not have an effect on its domestic laws, since it already includes EU law and is a signatory of the EPO. The organization will carry out the patent process as scheduled[13].The current UK patent system is governed by the Patents Act of 1977[14]. This act was framed to comply with the terms of international agreements, mainly the Cooperative Patent Classification (CPC), which although was never ratified by the EU, it was created by its predecessor, the EEC, pursuant to which the UK aligned its patent infringement provisions.[15] UK patent law is within the EU legislative framework in the areas of competition law defenses and relief for infringement for intellectual property[16]. UK supplemental protection certificates, a form of intellectual property protection which compensates for a period between filing and granting of a patent application for pharmaceuticals, is also governed by legislation implemented pursuant to EU regulation[17]. Additionally, the UK is expected to be an EU member until at least 2019[18]. During this period, the country will operate under a transitional framework pursuant to EU legislation. The government has stated that it will keep implementing EU directives and that the courts will continue to interpret EU law[19].

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In the case of an actual Brexit, the UK will likely ratify the court through the transitional framework of an EU exit or will lose its ratification vote and the UPC will be established through the very likely ratification of the rest of the EU. Even if the UK does not ratify the UPC, its patent law will be heavily influenced by EU law and it will remain an EPO member. If the UK does ratify the new court system, it would entwine UK law even closer to EU law by granting the court jurisdiction to resolve patent disputes covering EU members that have chosen to participate in the system[20]. In the case of Brexit, there would be no fundamental reason for the UK not to participate, but its participation would have to be secured by separate agreements with other countries. Since the agreements would have to be done with EU members, the UK government would have to implement laws to ensure compliance with EU laws[21]. The UK will likely consider three agreements: It remains a European Economic Area (EEA) member, it joins the European Free Trade Agreement (EFTA), or it maintains a trade partnership with the EU[22].

First, if it remains part of the EEA, court references will be made to EFTA courts and not the CJEU. However, EFTA functions to ensure uniform interpretation of EU law and the EEA has adopted EU intellectual property regulation regarding medicinal and plant protection products[23]. That may not seem important, but patent protection on medicinal products serve as “life blood” of the pharmaceutical industry, which generates 10% of the UK’s GDP, employs 100,000 people, and allows the UK to host clinical trial markets, foreign companies[24], and European medicinal organizations[25]. Second, if the UK joins EFTA, some of the remaining EU legislation could be expected to apply, especially through the transitional framework[26]. Third, if the UK decides to just trade with the EU, it would operate pursuant to a bilateral trade agreement, making it subject to CJEU jurisdiction and to EU law implementation to prevent gaps in legislation and in judicial opinions. Historically, UK judges have been influenced by decisions from other European judges, meaning they will keep referencing to CJEU rulings[27].

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In conclusion, in the field of patent protection, the EU has ostensibly achieved its goal of unity through embedded values, from which the UK will find it hard to separate. Europe does not have to worry as Brexit will not adversely affect European patent protection or UK patent law. The UK will still be guided by EU law regardless of whether it leaves the Union.

John Rizos is a 3L at the University of Baltimore School of Law with a concentration in International Law. He has an interest in human rights and international criminal law. In addition to being a CICL Fellow, John has served as the Secretary for Phi Alpha Delta Law Fraternity and is currently enrolled in HarvardX’s online course, “Humanitarian Response to Conflict and Disaster.” In June 2016, John was a member of the CICL Fellows team that, under the supervision of Professor Moore, assisted in drafting an amicus brief to the Extraordinary Chambers in the Courts of Cambodia, which was later approved and published. John graduated with honors from Towson University with a BA in International Studies (2013). He has interned at the Press Office of the Greek Embassy in Washington, D.C. and the International Civil Advocacy Network (ICAN), a non-profit organization advocating for women’s rights in the Middle East.

[1] https://www.thelawyer.com/issues/online-october-2016/brexit-mean-end-unified-patent-court/

[2] Id.

[3] http://www.lexology.com/library/detail.aspx?g=06cd3962-2c1d-4e8f-9618-c63b784b0875

[4] http://arstechnica.co.uk/tech-policy/2016/09/brexit-eu-unitary-patent-plans-legal-analysis/

[5] http://www.europedia.moussis.eu/books/Book_2/3/6/02/1/?all=1

[6] http://www.europedia.moussis.eu/books/Book_2/3/6/02/1/?all=1

[7] https://www.epo.org/about-us/office/timeline.html

[8] https://www.unified-patent-court.org/

[9] https://www.ft.com/content/9199ea86-80c8-11e6-8e50-8ec15fb462f4

[10] https://www.thelawyer.com/issues/online-october-2016/brexit-mean-end-unified-patent-court/

[11] http://www.lexology.com/library/detail.aspx?g=06cd3962-2c1d-4e8f-9618-c63b784b0875

[12] https://www.ft.com/content/9199ea86-80c8-11e6-8e50-8ec15fb462f4

[13] https://www.ft.com/content/9199ea86-80c8-11e6-8e50-8ec15fb462f4

[14] http://www.lexology.com/library/detail.aspx?g=dd074ec3-2c21-486f-b33e-5c0af5512ae8

[15] http://www.lexology.com/library/detail.aspx?g=dd074ec3-2c21-486f-b33e-5c0af5512ae8

[16] http://www.lexology.com/library/detail.aspx?g=dd074ec3-2c21-486f-b33e-5c0af5512ae8

[17] http://www.lexology.com/library/detail.aspx?g=dd074ec3-2c21-486f-b33e-5c0af5512ae8

[18] http://www.lexology.com/library/detail.aspx?g=dd074ec3-2c21-486f-b33e-5c0af5512ae8

[19] http://www.lexology.com/library/detail.aspx?g=dd074ec3-2c21-486f-b33e-5c0af5512ae8

[20] http://www.lexology.com/library/detail.aspx?g=dd074ec3-2c21-486f-b33e-5c0af5512ae8

[21] http://arstechnica.co.uk/tech-policy/2016/09/brexit-eu-unitary-patent-plans-legal-analysis/

[22] http://www.lexology.com/library/detail.aspx?g=dd074ec3-2c21-486f-b33e-5c0af5512ae8

[23] http://www.lexology.com/library/detail.aspx?g=dd074ec3-2c21-486f-b33e-5c0af5512ae8

[24] http://www.lexology.com/library/detail.aspx?g=06cd3962-2c1d-4e8f-9618-c63b784b0875

[25] http://www.lexology.com/library/detail.aspx?g=06cd3962-2c1d-4e8f-9618-c63b784b0875

[26] http://www.lexology.com/library/detail.aspx?g=dd074ec3-2c21-486f-b33e-5c0af5512ae8

[27]http://www.lexology.com/library/detail.aspx?g=dd074ec3-2c21-486f-b33e-5c0af5512ae8


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A Tale of Two Irelands; Is Unification Possible in the Wake of Brexit?

Alexander Ayer

On June 23, 2016 the U.K. shocked the world (and arguably themselves) by voting to leave the European Union.[1] The vote has left the U.K. and Europe as a whole wondering what will come next. However, in the wake of this event one group of people in the U.K. took an unprecedented action. Following Brexit so many people in Northern Ireland filed for Irish passports that the system came under significant strain and the Belfast Post Office ran out of application forms.[2] For the first time since the separation of the countries almost a century ago, Northern Irish citizens are discussing peacefully leaving the U.K. to join the Republic of Ireland.

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While England voted to leave the E.U., Northern Ireland voted 55.8% to 44.2% in favor of staying, which has caused some to question whether it might be in Northern Ireland’s best interests to split off from the U.K. as it splits off from the E.U.[3] This wouldn’t be the first time a part of the U.K. moved for independence. Just two summers ago Scotland moved to stay in the Union after a vote on independence. However, unlike the Scottish vote and for rather unique political reasons which will be discussed later, Northern Ireland might not need the approval of the current U.K. government to leave.

Historically there has been a lot of bad blood between the Irish and the British. The Irish had suffered political disenfranchisement, religious intolerance, racial prejudices, and other injuries under British rule. At the turn of the last century and in the middle of WWI, Ireland again erupted in rebellion. It has been remembered as the Easter Rising, and was organized by the Irish Republican Brotherhood. The rebellion was crushed, but the surviving members reformed, gathered support, and the rebellion soon turned into a revolution. This was the birth of the Irish Republican Army, the IRA.

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Eventually, the British government agreed to negotiate, and an autonomous Irish Free State was created which would soon thereafter become the fully independent Republic of Ireland. However, when the Free State was created, six counties in the North of Ireland were excluded and left as part of the U.K. These six counties became Northern Ireland. They were excluded at the time for several reasons, both practical and philosophical, but one major issue was that Northern Ireland was mostly Protestant while the rest of the island was Catholic. [4]

However, the situation deteriorated in the 1960s. Catholics in Northern Ireland faced discrimination in many aspects of life, including employment and housing, as well as violence from Protestants. The situation eventually boiled over, Catholics took up arms, and formed the Provisional IRA. What ensued was thirty plus years of fighting, with the IRA on one side and Unionist paramilitary units and the British government on the other. The level of violence tore the North apart. The fighting was eventually ended in 1998 with the Good Friday Agreement. As part of the agreement, the IRA agreed to renounce violence as a means of effecting change, Sinn Fien (which was the political wing of the IRA) would share power in the government with protestants, Catholics where guaranteed equality, Northern Ireland would stay in the U.K., but left the future possibility of unification on the table.[5]

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Which leaves us where we are now. Brexit may bring the U.K. into conflict with many facets of the Good Friday Agreement. For example, one major argument for the pro-Brexit camp was that leaving the E.U. would allow the U.K. to secure its boarders.[6] However the only land boarder the UK has with the E.U. is the border between the Republic of Ireland and North Ireland. As part of the Good Friday Agreement, the U.K. promised not to limit movement across the Irish boarder.[7]  If the U.K. is going to secure its border with Europe, then it will be brought into contention with the Good Friday Agreement. Further, Northern Ireland receives aid through the Agreement from the E.U. to help rebuild after the fighting and maintain peace.[8] Many argue that Brexit is inconsistent with the Agreement, and a constitutional argument is being made before the High Court in Belfast to challenge the legality of Brexit at least as it relates to North Ireland.[9]

There have been concerns over the threat Brexit might pose to peace. The peace isn’t even 20 years old, and while most of the Provisional IRA has laid down its arms and renounced violence, most does not mean all. New offshoots of the IRA remain somewhat active, even if they are smaller than the old IRA and lack most of its capabilities.[10]

As mentioned earlier, the U.K. government might not get a say in the matter. Under the Good Friday Agreement, the possibility of unification was left open. Specifically, the Agreement states that North Ireland was granted the right to have a vote in the future to join the Republic if they so desired.[11] It was done at a time when London believed that such a strong sentiment would not exist for decades.[12] However, with Brexit and the threat it could pose to Northern Ireland’s economic and social wellbeing this provision has suddenly become relevant. If North Ireland decides to have a vote, it votes to leave, and the Republic of Ireland agrees to accept them that might be the end of the discussion. Unlike the Scottish independence vote two summers ago, Northern Ireland doesn’t require the approval of Parliament to have a vote to leave – they already have it.

Furthermore, not only could the vote happen, Sinn Fien, now one of the major parties in both Northern Ireland and the Republic of Ireland, has already said they want to have the vote.[13] The Prime Minister of Northern Ireland went so far as to say that a vote for unification might happen in the wake of Brexit.[14]

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It would be inspiring to see Northern Ireland, a place which has experienced so much bloodshed and division to stand unified peacefully for the benefit of all their people. However, there is still a lot of tension, and Brexit may not be enough to create a successful unification effort. However, there are some things that could help push North Ireland towards unification.

  1. If Scotland leaves. Scotland also voted overwhelmingly to stay in the E.U., and after Brexit there was a surge of interest in another independence vote. If Scotland declares its independence, or at least has another vote for independence it could encourage North Ireland to take the plunge. Further, there seems to be a sense in both Northern Ireland and abroad that if Scotland attempts independence again, the possibility of Northern Ireland leaving the U.K. substantially increases.[15]
  1. The economy begins to suffer. The U.K. economy suffered noticeably in the immediate aftermath of the Brexit vote.[16] While it has stabilized somewhat since then, uncertainty remains. There have been justifiable concerns that if the U.K. actually cuts ties with the E.U., it could have significant negative economic impacts.[17] If Brexit actually happens and it begins to take a toll on the economy, while Ireland remains reasonably stable, it would provide the biggest help` in pushing for unification.
  1. A guarantee of equal rights for Protestants and/or a degree of autonomy for the region. The old wounds still ache from time to time. Fear of Catholic reprisals may keep hard-core unionists or even moderate Protestants from going along with unification. While the Republic has always had a distinctly Catholic tone. Divorce was not a legally recognized right until the 1990s.[18] If the Republic of Ireland can reassure the Protestants that they shall have equal rights and access to political participation, then unification may go more smoothly. Northern Ireland may even be granted a degree of regional autonomy, which when combined with the economic and social benefits of continued E.U. membership may be enough to overcome old suspicions.[19]

If these things happen, and the U.K. actually leaves the E.U., then I think the chances of Irish Unification increase noticeably and may happen in the coming years.

Alexander Ayer  is a third year (3L) law student at the University of Baltimore School of Law. His undergraduate studies were completed at Hood College, where he majored in history and graduated cum laude in 2014. Alexander is expected to graduate from the University of Baltimore School of Law in the Spring of 2017. As part of his international law background he took part in a study abroad program at the University of Aberdeen School of Law in Scotland. Alexander is drawn to international law by the comparative approach of seeing how different societies solve similar problems in different ways, as well observing how history has effected the laws and policies of various nations, and the behaviors demonstrated by counties interacting with each other on the world stage. In addition to international law, Alexander is also interested in disability law and copyright law.

[1] http://www.bbc.com/news/uk-politics-32810887

[2] https://www.washingtonpost.com/news/worldviews/wp/2016/06/28/a-stampede-for-irish-passports-in-the-wake-of-brexit-vote/

[3] http://time.com/4383916/brexit-vote-revived-calls-united-ireland/

[4] http://www.huffingtonpost.com/chris-weigant/will-ireland-reunify-afte_b_10745358.html

[5]http://peacemaker.un.org/sites/peacemaker.un.org/files/IE%20GB_980410_Northern%20Ireland%20Agreement.pdf

[6] https://www.theguardian.com/politics/2016/jun/08/brexit-threat-northern-ireland-border-communities

[7]http://peacemaker.un.org/sites/peacemaker.un.org/files/IE%20GB_980410_Northern%20Ireland%20Agreement.pdf

[8] http://www.independent.co.uk/news/uk/politics/northern-ireland-brexit-challenge-involve-attorney-general-john-larkin-a7326531.html

[9] http://www.independent.co.uk/news/uk/politics/northern-ireland-brexit-challenge-involve-attorney-general-john-larkin-a7326531.html

[10] http://www.bbc.com/news/uk-northern-ireland-10866072

[11]http://peacemaker.un.org/sites/peacemaker.un.org/files/IE%20GB_980410_Northern%20Ireland%20Agreement.pdf

[12] http://www.huffingtonpost.com/chris-weigant/will-ireland-reunify-afte_b_10745358.html

[13] http://www.independent.co.uk/news/uk/politics/brexit-northern-ireland-eu-referendum-result-latest-live-border-poll-united-martin-mcguinness-a7099276.html

[14] http://time.com/4412381/ireland-prime-minister-enda-kelly-referendum-northern-ireland/

[15] http://time.com/4383916/brexit-vote-revived-calls-united-ireland/ & http://www.huffingtonpost.com/chris-weigant/will-ireland-reunify-afte_b_10745358.html

[16] http://www.bbc.com/news/business-36956418

[17] http://www.bbc.com/news/business-36956418 & http://www.huffingtonpost.com/chris-weigant/will-ireland-reunify-afte_b_10745358.html

[18] http://www.taoiseach.gov.ie/eng/Historical_Information/The_Constitution/February_2015_-_Constitution_of_Ireland_.pdf

[19]http://peacemaker.un.org/sites/peacemaker.un.org/files/IE%20GB_980410_Northern%20Ireland%20Agreement.pdf


1 Comment

Lèse-majesté in 2016: Erdoğan’s New Ottoman Empire and the European Press

Shane Bagwell

On April 15, 2016, German Chancellor Angela Merkel authorized the prosecution of comedian Jan Böhmermann under Article 103 of the German Criminal Code, a lèse-majesté law prohibiting “defamation of organs and representatives of foreign states.”[1] The Article is so rarely used and outdated that many jurists were unaware of its very existence until recently. The case now heads to the German judiciary for potential prosecution, though the outcome is hardly certain to any of the parties involved. The Chancellor’s announcement represents the broader situation in Europe, which is facing a refugee crisis, culture clash resulting from thousands of migrants entering the EU, and dwindling influence outside of its borders.

Lèse-majesté is an ancient concept dating back to the Romans, who made it a criminal offense to injure the sovereign power of the Roman people. The concept has shifted in its use over the years, and now includes certain crimes against the government as well. The current German law dates back to 1871, when  Kaiser Wilhelm II expanded the definition to include non-royal heads of state in an effort to secure the country’s ability to conduct diplomatic relations more effectively.

Turkey has been an associate member of the European Union since 1963, has been waiting for membership since 1987. However, numerous concerns about issues ranging from human rights to free speech have blocked their accession in one way or another. Since the outbreak of the Syrian Civil War though, Turkish influence over Europe has increased dramatically. A recent agreement between the EU and Turkey provides for more asylum seekers to remain in Turkey in exchange for EU cash assistance and other concessions (including renewed talks of Turkish accession).

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As Europe has grown ever more reliant of Turkey and President Erdoğan for support during the refugee crisis, the Turkish government’s sway over Brussels (and Berlin) has grown drastically. Although Germany was previously one of the leading and most vocal critics of Turkish accession to the EU, Chancellor Merkel’s government has aggressively sought a warming of relations, some would say to the detriment of her own country’s power and prestige. And, with recent German municipal elections strongly favoring a fresh tide of right-wing, anti-immigrant sentiments, she has reason to worry. Not only does the crisis have the power to potentially bring down her government, it could well lead to a collapse of the Union itself. As countries within the Schengen area have closed their borders to prevent the flow of asylum seekers, the cracks within Europe are beginning to show.

Within the last several months, Turkey has arrested scores of journalists and academics critical of the regime. Two journalists from the Turkist newspaper Cumhuriyet were tried for espionage after publishing a video that allegedly showed Turkey’s intelligence agency funneling weapons into Syria.[2] In March, two cartoonists were sentenced to 11 months and 20 days in prison for insulting Erdoğan on the cover of Penguen magazine, on which a cartoon figure of Erdogan is welcomed to the presidential palace by a public servant. Erdoğan tells him, “But this is so dry. We could have at least slaughtered a journalist.”[3] (A prime example of the President’s penchant for irony) The crackdown on journalists and academics syncs up with the Turkish government’s crackdown on Kurds in the southeast of the country, which has been subject to a media blackout, and has been harshly criticized by the free press group Reporters without Borders, whose Turkey page provides a truly damming assessment of free speech within Turkey. [4]

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Unable to resist the temptation of lampooning Turkey’s President over his increasingly dictatorial approach to governance, German comedian Jan Böhmermann released a video entitled “Erdowie, Erdowo, Erdoğan.”[5] The video shows footage of Erdogan’s most absurd public moments, intercut with crackdowns on protesters. “Equal rights for women: beaten up equally,” the song goes, as police beat women with batons.[6] Shortly after the video was aired on German television, the German ambassador in Ankara was summoned before the Turkish government to answer for the affront.[7] Within days, Böhmermann was at it again, this time specifically to test the limits of the free speech laws in Germany. The German ambassador was summoned once again, but this time rather than a verbal lashing, it was to receive a formal complaint that was required for prosecution under Article 103. Chancellor Merkel was faced with a tough decision: support the free speech rights of the Germans (indeed all of Europe), but risk the deal that had been hard worked between the EU and Turkey, or bow to Turkish pressure and cede German prestige and power to assure the agreement’s future. Unfortunately, Chancellor Merkel failed to remember that petulant and brutish tyrants such as Erdoğan will only be emboldened by concessions, a lesson which the rest of the world learned dealing with Germany in the 1930’s.

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Erdoğan’s response to Böhmermann has been to say, “I’m not some sort of tyrannical leader that is hostile to a free press, and to show it, I’m going to request that a foreign government prosecute a comedian for making fun of me.” The inability to recognize the irony of the situation only stands to bolster the argument that Erdoğan might need a lesson in what a “sense of humor is.” Free speech advocates around the world have lined up behind Böhmermann, not because his crass and offensive poem itself was valuable to the public discourse, but because art sometimes requires a shock to the senses in order to stimulate the discussion which this affair has.[8] The authorization for prosecution by Chancellor Merkel represents Germany’s bowing to the power of the new Ottoman Empire, and an abandonment of the core values which Europe seeks to protect. Perhaps the greatest joke here is that concerns such as these have been the largest impediment to Turkey’s accession to the Union. Now we wait to see who has the last laugh.

Shane Bagwell is a 3L at the University of Baltimore School of Law, and a graduate of West Chester University with a Bachelor of Arts in Political Science. He currently serves as the President of the Military Law Association. His interests are Middle Eastern politics, international conflicts, and the law of land warfare. He is currently a law clerk for the Office of the State’s Attorney for Baltimore City, Economic Crimes Division.

[1]Strafgesetzbuch (StGB) (Penal Code) § 103

[2]‘I’m not at war with press,’ says Turkish President Recep Tayyip Erdogan, CNN, 31 March 2016, http://www.cnn.com/2016/03/31/middleeast/recep-tayyip-erdogan-amanpour-interview/ (last visited 17 April 2016)

[3]Cartoonists convicted for insulting Turkey’s President, Zeynep Bilginsoy and Ivan Watson, CNN, 26 March 2016, http://www.cnn.com/2015/03/26/world/turkey-cartoonists-conviction/ (last visited 17 April 2016)

[4]Reporers Without Borders, Turkey, https://rsf.org/en/turkey (last visited 17 April 2016)

[5]https://www.youtube.com/watch?v=R2e2yHjc_mc

[6]Erdowie Erdowo Erdogan The Video That Made Turkey Mad Enough to Summon the German Ambassador, Foreign Policy Watch, http://foreignpolicy.com/2016/03/29/watch-erdowie-erdowo-erdogan-the-video-that-made-turkey-mad-enough-to-summon-the-german-ambassador/ (last visited 4/15/2016).

[7]Turkey asks Germany to prosecute comedian over Erdoğan poem, The Guardian, 11 April 2016, http://www.theguardian.com/world/2016/apr/11/turkey-germany-prosecute-comedian-jan-bohmermann-erdogan-poem (last visited 17 April 2016)

[8]Künstler solidarisieren sich mit Böhmermann, Die Zeit, 13 April 2016, http://www.zeit.de/kultur/film/2016-04/jan-boehmermann-satire-solidaritaet-prominente-offener-brief (last accessed 17 April 2016) (auf Deutsch) (in German)

 


4 Comments

Turkey’s Breach of the Principle of Non-Refoulement

Yasmine Akkad

Non-refoulement is a fundamental principle in international law that was first laid out in the UN Convention relating to the Status of Refugees in 1954.[i] Article 33(1) of the convention provides that: “no Contracting State shall expel or return (‘refouler’) a refugee in any manner whatsoever to the frontiers of territories where his life or freedom would be threatened on account of his race, religion, nationality, membership of a particular social group or political opinion.”[ii] Recently, Turkey breached this principle of non-refoulement by illegally returning thousands of Syrian refugees to war-torn Syria.[iii]

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According to a report conducted by Amnesty International, about 100 Syrians have been sent back to their war-torn country every day since January.[iv] This news comes shortly after Turkey struck a deal with the European Union (aimed at stemming the flow of refugees arriving in Greece), agreeing to accept refugees in return for aid and political concessions.[v] Under the agreement, all “irregular migrants” arriving in Greece from Turkey on 20 March onwards will face being sent back.[vi] The agreement further stipulates that the EU will take in one Syrian (who has made a legitimate request) for each Syrian migrant returned to Turkey.[vii] The process, which is known as “one in, one out,” is meant to discourage illegal migration into Europe.[viii]

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Amnesty says this latest report exposes the flaws in the deal between Turkey and the EU.[ix] Critics of the deal say the EU is irresponsibly returning Syrian refugees to an unsafe country, in a desperate effort to seal its borders.[x] In the Amnesty report, John Dalhuisen remarked, “in their desperation to seal their borders, EU leaders have willfully ignored the simplest of facts: Turkey is not a safe country for Syrian refugees and is getting less safe by the day.”[xi]

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Turkey’s recent breach of international law is symptomatic of a larger issue. There is no end in sight for Syria’s civil war, and the number of people fleeing Syria will only increase. Since Syria’s civil war began more than five years ago, Turkey has taken in more refugees than any other country worldwide.[xii] Put simply, Turkey is overwhelmed. The country has struggled to accommodate the refugees, who are putting a strain on Turkey’s economy and healthcare system.[xiii] While it is not acceptable for Turkey to return refugees to war-torn Syria, it is also not acceptable for the world to sit idly by as thousands of Syrians flee the ongoing violence and hostility in Syria.

Yasmine Akkad is a third year law student at the University of Baltimore School of Law J.D. Candidate (’16). She holds a Bachelors of Science in Law and American Civilization and a minor in English from Towson University. Her primary interests include international law and international human rights law. In addition to being a CICL Fellow, she competed in the 2014-2015 Jessup International Moot Court Competition, Mid-Atlantic Region, and is an active member of the American Society of International Law.

[i] http://www.unesco.org/new/en/social-and-human-sciences/themes/international-migration/glossary/refoulement/

[ii] Id.

[iii] http://www.bbc.com/news/world-europe-35941947

[iv] Id.

[v] Id.

[vi] http://www.theguardian.com/world/2016/apr/04/eu-turkey-deal-syrian-refugees-germany-istanbul-hanover

[vii] http://www.bbc.com/news/world-europe-35956836

[viii] http://www.ibtimes.com/syrian-refugees-forced-back-war-zone-turkish-authorities-eu-turkey-agreement-goes-2348127

[ix] Id.

[x] Id.

[xi] Id.

[xii] https://www.mercycorps.org/articles/iraq-jordan-lebanon-syria-turkey/quick-facts-what-you-need-know-about-syria-crisis

[xiii] http://www.ibtimes.com/syrian-refugees-forced-back-war-zone-turkish-authorities-eu-turkey-agreement-goes-2348127


4 Comments

Restricting Schengen – Keeping out Refugees

Raiven Taylor 

Recently, European countries have come up with plans to keep migrants out. In June of 2015, the EU had an emergency meeting and came up with a “10-point plan” to “capture and destroy” boats used to smuggle in migrants.[i] Not long after this plan hatched, Hungary and other European countries erected wire fences to keep migrants out. [ii] Germany, Denmark, Austria and a few other countries suspended their willingness to adhere to the Schengen rules and reintroduce border controls.[iii] The Schengen treaty allows for open travel in the 26-nation bloc known as the Schengen area.[iv] This area, created in 1995 and originally consisting of 26 EU nations, abolished passport controls at common borders.[v] The recent suspension of this was thought to shock the rest of EU when it came to border controls to deal with the migration crisis. Because Germany borders nine other countries, without its participation, Schengen fails.[vi] This led other countries to begin closing their borders, criminalizing most new arrivals as illegal immigrants.[vii] With all of the changes, it has been difficult for migrants to find a country that will allow them to enter. This also makes it difficult for those countries that CAN take these immigrants into their territory because resources are tight. As of September 2015, 63,000 asylum seekers from Hungary and Austria entered Bavaria, which is more than the total of asylum seekers for the enter year of 2014.[viii]

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The EU proposed a deal with Turkey, promising $3.3 billion for it to close down its borders.[ix] Denmark has also passed a law allowing it to seize valuables from asylum seekers in order to pay for their upkeep.[x] All of this is leads to bigger problems because even though countries are locking down their borders, migrants are finding other, often very dangerous ways, to get in anyway. On February 12, 2016 the UN High Commission for Refugees (UNHCR) expressed its concern for the increasing restrictive measures on the part of EU states, stressing that something must be done to protect the fundamental human rights of the people trying to reach Europe.

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Spokesperson for the Office of the UN High Commissioner for Refugees (UNCHR) stated that more than 80,000 migrants arrived in Europe by boat in the first 6 weeks of 2016, with 400 dying in their attempt. Statistics show that 58 percent of migrants coming to Europe are women and children. One in 3 people arriving in Greece are children, compared to the 1 in 10 in September 2015.[xi] It has also been reported that two children drown every day, on average, since September 2015 as their families attempt to cross the Mediterranean Sea, totaling more than 340 children.[xii] UNCHR and the UN Children’s Fund (UNICEF) urge countries to cooperate and make dangerous journeys like this safer for children.[xiii]

A UN Special Rapporteur on Human Rights of Migrants, François Crépeau, stated that although “Europe has always been a strong advocate of human rights in Europe and elsewhere… its struggle to maintain control of its borders however…is being tested…[and by]stripping away the rights of asylum-seekers and migrants, Europe is creating a scary new ‘normal.’”[xiv] Over-reliance and securitization of borders will not work to keep migrants out because they will find another way in order to survive, allowing smugglers to continue to adapt, prosper, and exploit migrants.[xv] In order to combat smuggling, states must provide regular, safe and cheap mobility solutions, including both identity and security checks.[xvi]

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The European public, predominantly, has the view that Europe needs stricter controls, bigger fences, and more military control.[xvii] Although the public might favor these stricter policies, politicians view them as an immoral and an unworkable approach.[xviii] The question is how will European countries pursue this issue and in what ways will immigration be affected long term? Will countries continue keeping its borders open? Will countries continue with daily limits on migrants? I believe countries should find a less dangerous way for migrants to travel while also coming up with a way to stem the tide of migration. It is somewhat understandable for countries to not want to be overpopulated and have an extra burden on state-run agencies. However, risking the lives of migrants is not the way to overcome this problem. Many organizations are attempting to convince the politicians to work this issue out as peacefully as possible and in a way that lessens the dangers for migrants. Something needs to be done – sooner, rather than later!

[i] http://www.theguardian.com/commentisfree/2016/jan/31/europe-bind-act-morally-on-immigrants-heed-its-citizens

[ii] Id.

[iii] Id.

[iv] http://www.theguardian.com/world/2015/sep/13/germany-border-crackdown-deals-blow-to-schengen-system

[v] http://www.theguardian.com/commentisfree/2016/jan/31/europe-bind-act-morally-on-immigrants-heed-its-citizens

[vi] http://www.theguardian.com/world/2015/sep/13/germany-border-crackdown-deals-blow-to-schengen-system

[vii] Id.

[viii] Id.

[ix] http://www.theguardian.com/commentisfree/2016/jan/31/europe-bind-act-morally-on-immigrants-heed-its-citizens

[x] Id.

[xi] http://www.un.org/apps/news/story.asp?NewsID=53217#.VsxxWMfiQtg

[xii] http://www.un.org/apps/news/story.asp?NewsID=53272#.VsxxYsfiQtg

[xiii] Id.

[xiv] http://www.un.org/apps/news/story.asp?NewsID=53217#.VsxxWMfiQtg

[xv] id.

[xvi] Id.

[xvii] http://www.theguardian.com/commentisfree/2016/jan/31/europe-bind-act-morally-on-immigrants-heed-its-citizens

[xviii] Id.


4 Comments

Nigeria’s Economy – Help is on the Way!

Carolyn Mills

The economy of Nigeria is the largest economy in West Africa, experiencing massive growth in the last 24 years. While the African continent, as a whole, has experienced rapid growth and development, there is concern amongst the international community regarding the threat of terror organizations, such as Boko Haram and the internal rampant corruption. The economy of Nigeria has recently faced difficulty and has made several appeals to the international community for support. Without this crucial intervention international organizations the threat of collapse could be imminent.

Boko Haram

Currently Boko Haram has taken a large foothold in the northern Nigeria, and is notably known for the kidnapping of 300 school girls in 2014, which sparked the #BringBackOurGirls movement. Boko Haram’s terror is indiscriminate as the organization is known for attacking both Christians and Muslims. Boko Haram began as a peaceful organization until 2009 when the government of Nigeria launched investigations into their activities. [1] The terror group has been credited with the death of nearly 17,000 Nigerians since its reign of terror began in 2010. [2] Corruption has been a further impediment to the growth of Nigeria’s economy. A recently published article, one of the most notable and egregious cases of corruption occurred when $195 billion naira (nearly 10 billion dollars) was pilfered from a pension fund that was intended for retired workers.[3]

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2014 was a year of great exploits for Nigeria, as it was named the largest economy in Africa (as well as most populous)[4].  Its largest industries are its growing entertainment sector known as ‘Nollywood’, followed by its large agricultural sector.[5] In the past 2 years, however, Nigeria has experienced a fall in the valuation of their currency (the naira) as oil prices have fallen below $30 per barrel. Initially following the election of President Muhammadu Buhari the stock market peaked at the hope of a new president with a new economic policy, however hopes were quickly dashed. [6] The falling price of crude oil in the country coupled with their need to import refined fuel has put much pressure on the economy and President Buhari. [7]

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In an effort to assist the country in its efforts to fight Boko Haram, the European Union has pledged more than $50 million dollars to aide in the fighting against Boko Haram[8]. The European Union has also recently pledged to assist in diversifying its nearly exclusive oil dependent economy[9]. The attractive package comes with many caveats (read strings). The EU Ambassador to Nigeria, based in Lagos, stressed the importance of business owners and investors having protection under Nigerian laws stating.[10] Although how Nigeria will ensure the protection of potential investors is still in flux, Foreign Minister Geoffrey Onyeama remains hopeful that any future agreements with other countries will provide Nigeria with technical assistance to make the transition from a primarily agrarian economy to a fully industrialized economy.[11] The more pronounced role of other states and organizations is necessary to help usher in Africa’s largest economy and assist in sustained growth—rather than a mere suggestion from the EU.

German President Guack

Despite the recent call for help from President Buhari, Germany has been the only state to show interest in contributing to the development and investment in Nigeria’s now lackluster economy. Among other things, German President Joachim Guack has pledged support in the move to eliminate corruption, which is seen as the country’s number one enemy to progress. [12]

The threat of global terrorism should not deter international development. With increased investment comes increased infrastructure—infrastructure that is undoubtedly linked to the safety of the country’s border. Without such investment, the economy will stagnate and most of its resources will be sunk into their safety and defense forces, rather than development.  It is a harrowing catch-22 for government of Nigeria, as they attempt to advance their economic and social strength, while combating terrorism and corruption that seeks to slow progress. Germany’s advanced (and seemingly sole) role in the elimination of terror and the diversification of the economy will hopefully prove to be altruistic and non-imperialistic in nature as Nigeria fights to remain a forerunner on the African Continent.

Carolyn Mills is a graduate from of Bowie State University  and holds a Bachelor of Arts in Political Science. Carolyn is a 2L at the University of Baltimore School of Law. She serves as 2L Representative for the International Law Society.  Her interests and focus areas are on Central America and West Africa; she has traveled to both Guatemala and Honduras and hopes to visit Ghana this summer. She is currently a law clerk for the Department of Homeland Security’s Human Rights Law Section.  

[1] http://m.nzherald.co.nz/world/news/article.cfm?c_id=2&objectid=11250530

[2] http://www.globalresearch.ca/boko-haram-in-nigeria-the-destabilization-of-the-world-through-the-war-on-terror/5504014

[3] https://www.naij.com/402850-top-12-corruption-cases.html

[4] http://leadership.ng/features/502916/nigerian-economy-global-appeal-nwanze

[5] http://www.theatlantic.com/international/archive/2014/04/how-nigeria-became-africas-largest-economy-overnight/360288/

[6] http://qz.com/595453/the-precarious-state-of-nigerias-economy-right-now-captured-in-two-charts/).

[7] Id.

[8] Id.

[9] ( http://www.thisdaylive.com/articles/eu-pledges-to-assist-nigeria-diversify-economy/232283/)

[10] http://www.thisdaylive.com/articles/eu-pledges-to-assist-nigeria-diversify-economy/232283/.

[11] (http://allafrica.com/stories/201602100215.html).

[12] http://www.vanguardngr.com/2016/02/we-have-lost-lives-economy-because-of-corruption/