Earlier this month, the Appeals Chamber of the International Criminal Court (ICC) determined that the standards used to evaluate the ICC Prosecutor’s genocide charge against Sudanese President Omar al-Bashir in the Pre-Trial Chamber were insufficient. According to the Appeals Chamber, the ICC’s Pre-Trial Chamber erred in “…requiring that the existence of genocidal intent must be the only reasonable conclusion” (via Bec Hamilton). The Pre-Trial Chamber must now review its initial decision rejecting the Prosecutor’s genocide charge. As Bec Hamilton notes, this does not necessarily mean that the arrest warrant for Bashir will include a genocide charge. However, the Pre-Trial Chamber, in its review of its initial decision, may determine that the Prosecutor’s re-presentation is sufficient to warrant a genocide charge.