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More recently, hybrid tribunals have been established in Sierra Leone, Cambodia, andLebanon. The Special Court for Sierra Leone was established by a treaty between Sierra Leoneand the United Nations. 286 The Special Court applies both international and Sierra Leoneanlaw. 287 Similarly, in Cambodia, the Extraordinary Chambers in the Courts of Cambodia (ECCC)was established under Cambodian domestic law, but regulated by an agreement betweenCambodia and the United Nations. 288 The Special Tribunal for Lebanon was establishedfollowing an agreement between the United Nations and Lebanon to prosecute, inter alia,persons responsible for the February 2005 attack resulting in the death of former Lebanese PrimeMinister Rafiq Hariri. 28918.21 LIMITS ON THE PUNISHMENT OF INDIVIDUALS UNDER THE LAW OF WARInternational law places certain limits on the authority of States, whether actingindividually, or together with other States, to punish individuals for violations committed duringarmed conflict.286 See Agreement between the United Nations and the Government of Sierra Leone on the Establishment of aSpecial Court for Sierra Leone, in Appendix II to Letter dated 6 March 2002 from the Secretary-General addressedto the President of the Security Council, U.N. Doc S/2002/246, 17 (Mar. 8, 2002). See also U.N. SECURITYCOUNCIL RESOLUTION 1315, U.N. Doc S/RES/1315 (Aug. 14, 2000) (“Requests the Secretary-General to negotiatean agreement with the Government of Sierra Leone to create an independent special court consistent with thisresolution,”).287 Statute of the Special Court for Sierra Leone, art. 1(1) Attachment to Agreement between the United Nations andthe Government of Sierra Leone on the Establishment of a Special Court for Sierra Leone, in Appendix II to Letterdated 6 March 2002 from the Secretary-General addressed to the President of the Security Council, U.N. DocS/2002/246, 17 (Mar. 8, 2002) (“There is hereby established a Special Court for Sierra Leone to prosecute personswho bear the greatest responsibility for serious violations of international humanitarian law and Sierra Leonean lawcommitted in the territory of Sierra Leone since 30 November 1996.”).288 See Harold Hongju Koh, Legal Adviser, Department of State, Remarks on international criminal justice at theVera Institute of Justice in New York and at Leiden University, Campus The Hague, 2012 DIGEST OF UNITEDSTATES PRACTICE IN INTERNATIONAL LAW 61, 66 (“Similarly, in Cambodia, the international community workedlong and hard with domestic authorities to pursue accountability for atrocity crimes that took place decades ago.The Khmer Rouge Tribunal – formally, the Extraordinary Chambers in the Courts of Cambodia (ECCC) – was adifferent type of hybrid, established under domestic law but regulated by a UN-Cambodia agreement.”). See alsoU.N. GENERAL ASSEMBLY, Report of the Secretary-General on Khmer Rouge trials, U.N. Doc A/60/565 (Nov. 25,2005) (“On 28 April 2005 a notification was sent to the Government of Cambodia indicating that the legalrequirements on the United Nations side for the entry into force of the Agreement between the United Nations andthe Royal Government of Cambodia concerning the Prosecution under Cambodian Law of Crimes Committedduring the Period of Democratic Kampuchea, done at Phnom Penh on 6 June 2003, had been complied with. TheAgreement accordingly entered into force on 29 April 2005, the day after the notification, in accordance with itsarticle 32. The Government of Cambodia had previously provided its notification under that article, on 16November 2004.”).289 Agreement between the United Nations and the Lebanese Republic on the establishment of a Special Tribunal forLebanon, art. 1, Annex to U.N. SECURITY COUNCIL RESOLUTION 1757, U.N. Doc S/RES/1757 (2007) (“There ishereby established a Special Tribunal for Lebanon to prosecute persons responsible for the attack of 14 February2005 resulting in the death of former Lebanese Prime Minister Rafiq Hariri and in the death or injury of otherpersons.”).1113