Kendra Bengtson
Law Student, Mitchell Hamline School of Law, Fall 2022
Genocide happens in stages, with the final stage being denial to erase the memory of the genocide. Bosnia experienced a genocidal war from 1992 to 1995 involving Bosniaks (Bosnian Muslims), Bosnian Serbs, and Bosnian Croats.[1] Several grave atrocities occurred during the war, including the Siege of Sarajevo, rape camps, and the Srebrenica genocide where 8,000 Bosniak men and boys were killed by Serb forces.[2] Approximately 200,000 people in total were killed during the war.[3] Individuals from all ethnic groups were criminally prosecuted and some countries were sued for their part in the genocide, war crimes, and crimes against humanity.[4] Bodies are still being found in mass graves and identified today.[5]
The territory of Bosnia-Herzegovina has long been subject to nationalist tensions and divisions between religious groups.[6] After World War II, Marshal Tito led the Socialist Federal Republic of Yugoslavia by bringing together several states in the Balkan region, including Serbia, Croatia, and Bosnia-Herzegovina. [7] The collapse of Socialism in 1989 led to nationalist pressures that resulted in the break-up of Yugoslavia, with individual republics seeking independent statehood.[8] Croatia and Slovenia proclaimed sovereignty and independence from Yugoslavia in 1991. The proclamation triggered the Yugoslav People’s Army (JNA) to attack the countries.[9] Meanwhile, Serbs wanted to establish Republika Srpska, a majority Bosnian Serb area within Bosnia and Herzegovina, as an independent Serb republic.[10]
On March 3, 1992, Bosnia and Herzegovina declared independence.[11] Bosnian Serbs opposed an independent
Bosnian nation with a Muslim Bosniak majority. The JNA and Bosnian Serb militias, backed by Serbia, attacked the Bosnian city of Sarajevo.[12] When the European Union recognized Bosnia as a sovereign state, the JNA occupied the Sarajevo airport to prevent people and goods from leaving or entering the country in a siege that lasted nearly four years.[13]
Serbs seized two-thirds of Bosnia’s territory and used “ethnic cleansing” to drive Bosniaks and Croats out while subjecting Bosniaks and Croats to violence.[14] Genocide occurred in the town of Srebrenica, an area that was geo-politically important to Serbs. The Serbs’ goal was to establish a Serb territory between Bosnia and Serbia.[15] Serbs eventually executed a plan to eliminate Bosniaks from Srebrenica by first forcibly removing women, children, and elderly men.[16] Despite the United Nations Protective Force (UNPROFOR) declaring Srebrenica a “safe area” and having a UN troop presence in the town, in July 1995 almost 8,000 Bosniak men and boys were killed by Serb forces.[17]
The Bosnian war ended in 1995 through a United States-brokered peace deal called the Dayton Accords, held in Dayton, Ohio. The country of Bosnia was divided into two entities—the Federation of Bosnia and Herzegovina (FBiH) and Republika Srpska (RS).[18] The Dayton Accords recognized Bosniaks, Croats, and Serbs as constituent peoples and established a governing body that shares power among these constituent groups.[19] This power-sharing government continues to this day.
Several legal proceedings were conducted to hold leaders accountable for the atrocities. On May 25, 1993, the United Nations Security Council established the International Criminal Tribunal for the Former Yugoslavia (ICTY) to prosecute individual perpetrators.[20] Perpetrators tried at the ICTY included members of all three constituent groups of Bosnia. The tribunal sentenced ninety war criminals to prison before it closed in 2017.[21] Serbian President Slobodan Milosevic (who died while incarcerated during the trial), Serb leader Radovan Karadzic, and Serb military commander Ratko Mladic were charged with the crime of genocide. Karadzic and Mladic were both convicted of genocide, crimes against humanity, and other war crimes. After the ICTY closed, the 250 remaining cases were transferred to Bosnia’s national courts.
In addition to the ICTY trials, Bosnia brought suit in the International Court of Justice (ICJ) against Serbia. Bosnia alleged Serbia was responsible for the acts of genocide when it provided political, military, and financial resources to Republika Srpska. The ICJ determined that the genocide had taken place in Srebrenica but failed to find Serbia responsible for the genocide. Nonetheless, the Court found that Serbia had violated its obligation to prevent the Srebrenica genocide. Thus, the ICJ set a precedent indicating that a state can be held accountable for genocide and has a duty to prevent genocide when it becomes aware of a significant risk of such an atrocity occurring.[22]
Genocide is carried out by perpetrators through a specific process.[23] Gregory Stanton identifies eight stages of genocide: (1) classification, (2) symbolization, (3) dehumanization, (4) organization, (5) polarization, (6) preparation, (7) extermination, and (8) denial.[24] Acts of denialism include hiding mass graves, burning or closing historical records, minimizing the number of people killed, or characterizing the deaths as the result of a civil war.[25] The arguments that perpetrators or others use to deny genocide include denying the facts of the crimes, denying responsibility, and denying that the events rise to the crime of genocide.[26] Deniers may also use trivialization arguments to minimize the number of deaths or trauma that occurred.[27] Relativization arguments are used to compare genocide to other forms of tragedy in an attempt to minimize the gravity of genocide.[28]
The purposes in naming the killing of a group of people who were targeted for their ethnicity, nationality, race, or religion as genocide is to hold perpetrators accountable, recognize the harm that occurred, and provide redress for wrongs.[29] Perpetrators deny genocide to avoid responsibility and reparations.[30] Without naming genocide as such, a perpetrator enjoys impunity for the most serious crimes committed.[31] Allowing impunity hinders the prevention of future genocides.[32] The act of denial dehumanizes the victims of genocide.[33] When both genocide denial and genocide acceptance coincide within a community, it undermines social cohesion and sustainable peace.[34] To move forward with sustainable peace, truth, and reconciliation must occur.
Denialism in Bosnia
Communities in Bosnia classify the Bosnian genocide according to their beliefs in the use of force during the war, their memories of the genocide, and post-war political revisionism.[35] The Srebrenica genocide is the only event during the war that has been legally classified as genocide through the ICTY and ICJ. Other massacres and atrocities during the war, such as the Siege of Sarajevo and rape camps in Foća and other locations, are not legally classified as genocide.[36]
For Bosniaks, classifying the crimes at Srebrenica as genocide recognizes the Bosniak community’s suffering.[37] The ICTY and ICJ judgments establish a factual record of the Srebrenica genocide and influence how Srebrenica is understood in the context of the Bosnian War.[38] The genocide played a significant role in shaping Bosniak national identity, and commemorating the tragedy serves as a symbol of the nation’s perseverance through adversity.[39]
On the other hand, many Bosnian Serbs and political leaders deny that genocide occurred. The denial created a new political community after the war where Bosniaks were removed from Serb territory and the violence perpetrated was seen as a legitimate use of armed forces in protecting the Serbs’ community.[40]
Denialism takes many forms in Bosnia. Some outwardly deny genocide occurred and spread systematic disinformation about genocide.[41] Others denied that Serbian forces were responsible for the bombing of Sarajevo, which resulted in the death of 26 people in May 1992 and nearly 14,000 deaths over the duration of the siege. Instead, they claimed that it was the Bosnian government that was responsible for the attack on its own citizens.[42] Milorad Dodik, the current leader of Republika Srpska, refers to the genocide as “a fabricated myth.”[43]
Another genocide denial example is the story of the hotel Vilina Vlas located in Republika Srpska.[44] During the war, the hotel was a detention camp run by Serb forces where hundreds of women were raped.[45] Now, the Republika Srpska tourist board has rebranded the hotel as a spa getaway, and hotel management claims the stories of the former detention camp are “unsubstantiated rumors.”[46] Competing narratives of fictitious claims and factual records of survivors’ testimonies and legal proceedings are the source of tension among the ethnic groups.
Criminalizing Genocide Denial
Genocide denial bans have been used in other countries to combat denialism. Several European countries, including Germany, France, and Austria, outlaw Holocaust denial.[47] Countries that outlawed genocide denial do so for cultural, historical, and philosophical reasons.[48] Outlawing Holocaust denial is more common in European countries that were complicit in the killing of Jews.[49] Supporters of Holocaust denial bans argue that Hitler came to power through hate speech, and allowing denialism to occur risks encouraging antisemitism.[50] The bans also serve to preserve the memory of the Holocaust by protecting victims and promoting a post-Holocaust belief system of awareness of previously unimaginable human suffering.[51]
Opponents of genocide denial bans argue that limiting freedom of speech inhibits democracy and dictates that there can only be one version of the truth in a complex history.[52] Attempts to suppress denialism may also have the opposite effect by giving deniers a platform to spread their views.[53] Critics of laws against genocide denial also contend that such laws frequently lack an element of intent.[54] They argue that incorporating an intent requirement into the legislation would more effectively serve the law’s purpose of prohibiting conduct that intends to cause harm to victims and glorify heinous crimes.[55]
Officials in Bosnia attempted the prevention of genocide denial through legislation. On July 23, 2021, the head of Bosnia’s Office of the High Representative (OHR) criminalized genocide denial in Bosnia.[56] Created by the Dayton Peace Accords, the OHR oversees the implementation of the peace agreement.[57] It has broad powers to amend constitutions, legislate, and dismiss public officials who undermine the peace agreement.[58] The criminal law prohibiting genocide denial stipulates a penalty of up to five years of imprisonment for individuals who glorify convicted war criminals or deny the occurrence of genocide, war crimes, or crimes against humanity committed during the Bosnian War.[59] When the High Representative announced the law, he stated that the “outright denial of genocide and war crimes prevent societies from dealing with their collective past, constitute renewed humiliation of the victims and their loved ones, while also perpetuating injustice and undermining interethnic relationships.”[60]
The reaction to the genocide denial ban was divided along ethnic lines. Bosniak politicians and relatives of victims welcomed the decision. Bosnian Serb leader Milorad Dodik condemned the law and threatened Republika Srpska’s secession from Bosnia.[61] Bosnian Serb leaders went so far as to reject the ban and claimed they would refuse to comply with prosecutions under the law.[62] On January 9, 2022, months after the genocide denial ban was in place, Bosnian Serbs in Republika Srpska held a parade to recognize an outlawed holiday that commemorates the day when Bosnian Serbs declared independence in 1992 at the start of the war.[63]
Whether Bosnia’s law outlawing genocide will serve its purpose of curbing denialism in the country and promoting unity remains to be seen. As of July 2022, reports of public acts of genocide denial decreased, especially in Republika Srpska, where genocide denial decreased by eighty percent.[64] Over fifty complaints were filed with Bosnian state prosecutors since the law was enacted; however, no charges have been filed as of July 2022.[65] Supporters of the denial ban argue that, without following through with prosecutions, acts of denialism and glorification of war criminals will continue.[66]
Critics of the genocide denial law argue that its implementation may have exacerbated the political crisis in Bosnia. European Union officials claim that the way the law was passed in Bosnia—through the High Representative imposing the legislation on his last day in office—did more harm by delegitimizing the High Representative’s office and stoking conflict.[67] Instead, they argue that the reconciliation process should be led by Bosnian locals and should genuinely confront the roots of hatred that led to genocide, rather than be led by the High Representative, who is an international appointee in Bosnia.[68] These differences in opinion on Bosnia’s denial law illustrate the difficulties in combating denialism in Bosnia.
Education About Genocide
Another path to combat genocide denial is through education.[69] Education works to prevent future genocide by providing a forum to address past violence.[70] The education system in Bosnia is structured by each individual canton (federal units within both administrative states of Republika Srpska and the Federation of Bosnia and Herzegovina).[71] The system is inefficient and results in segregated schools through a policy of “two schools under one roof.”[72] This policy requires ethnically divided students to be separated within the school, by using separate entrances and classrooms. The groups of students learn different lessons in language, religion, geography, and history.[73] The policy was originally enacted after the war as a temporary measure to encourage Bosnian citizens to return to the homes they were displaced from during the war and to prevent further ethnic violence.[74]
For instance, one elementary school in a Republika Srpska town (reportedly once used as military barracks for Bosnian Serb forces and later a temporary detention center for Srebrenica massacre victims) does not teach about the Srebrenica genocide.[75] Textbooks used in the Bosniak-Croat federation are banned in Republika Srpska if the books mentioned the siege of Sarajevo or the Srebrenica genocide. One parent and Srebrenica massacre survivor led a boycott by Bosniak parents who lived in a Republika Srpska town. The parents would not send their children to the Serb-administered school as a protest over the language and history curricula that did not teach about the Srebrenica genocide.[76] The parents set up an alternative school taught by a teacher from Sarajevo.[77] The parent says the international community “gave legitimacy to the genocide and ethnic cleansing with the creation of Republika Srpska under the Dayton accords.”[78] Advocacy groups attempt to end the ‘two schools under one roof’ model. The Federation of Bosnia and Herzegovina’s high court held that one of the cantons must end its segregated schooling, but the policy remains in place today.[79]
On an encouraging note, researchers conducted a study in Bosnian high schools that looked at how educational efforts can change stigmas and attitudes surrounding the use of sexual violence in conflict.[80] The studies generally found that after students participated in discussions of conflict-related sexual violence, the students’ attitudes surrounding stigmas of sexual assault positively changed.[81] The role of education in transitional justice is evidenced in this study, particularly by students having conversations about victims’ and survivors’ experiences.
Genocide denial is one element in the political crisis occurring in Bosnia today. Recent elections on October 2, 2022, were characterized by nationalism.[82] Serb leader Milorad Dodik was elected President of Republika Srpska and called for Republika Srpska to separate from Bosnia and Herzegovina, claiming that Christians and Muslims “cannot live together.”[83] Dodik blames Western countries for acting against Serb interests and aligns himself with Russian President Vladimir Putin.[84] Dodik’s friendship with Putin causes fears of seeing Republika Srpska’s secession come to fruition.[85]
In addition to the Republika Srpska feud with the Federation of Bosnia and Herzegovina, political parties between Bosniaks and Croats within the Federation of Bosnia and Herzegovina are now in conflict with each other after once being aligned.[86] Croats accuse Bosniaks of electing Croats who do not represent Croat interests. Croats threaten to reorganize the territory to ensure that Croats can elect their preferred candidates.[87] Further complications arose during the elections when the High Representative made a last-minute change to election laws after voting polls closed on election night.[88] The law increased the number of representatives elected in the Federation of Bosnia and Herzegovina and changed the way officials are elected.[89] The proposed change sparked protests, with some critics claiming the law change was “legislating apartheid.”[90]
International Response
The international community is monitoring and responding to the political divides in Bosnia. Ever since the war broke out, various peacekeeping missions have been deployed to Bosnia, beginning with the United Nations peacekeeping force that was unable to stop the fighting that began in 1992.[91] Since 2004, the European Union has stationed its troops (EUFOR troops) in Bosnia with the objective to contribute to a safe and secure environment in Bosnia and supporting and training the Federation of Bosnia and Herzegovina’s army.[92] As of August 2022, 1,100 EUFOR troops are stationed in Bosnia.[93]
The United States imposed various sanctions on Bosnian officials and businessmen. On January 5, 2022, the Biden administration sanctioned Republika Srpska President Milorad Dodik for corruption and for undermining the Dayton Peace Accords by moving to withdraw from Bosnia’s state-level institutions and create Republika Srpska’s own army.[94] The move came months after Dodik threatened Republika Srpska’s secession from Bosnia after the genocide denial ban was implemented.
On June 6, 2022, the Biden administration sanctioned the Federation of Bosnia and Herzegovina President Marinko Čavara for undermining democratic and peace efforts by refusing to nominate judges to the country’s top court since 2019. Alen Šeranić, Republika Srpska minister of health and social welfare, was also sanctioned for supporting a law that would establish a parallel health agency and undermine Bosnia’s state-level government health agency.[95] It is unclear how these attempts to sanction Bosnian political leaders, businesses, and private individuals for undermining democracy and peace in the country have affected the trajectory of the political crisis.
Genocide denial continues to stoke division and hate incidents between ethnic groups in Bosnia. In a country already geographically and politically divided along ethnic lines drawn from genocide and war,[96] peace will not occur without reconciliation. In the context of Bosnian leaders’ calls for unity, while also promoting ethnic interests, reconciliation between the groups is unlikely to occur without a shared understanding and recognition that genocide happened in Bosnia.[97]
The international community must continue to monitor, lend support, and call out leaders who stoke division in Bosnia. The international community should recognize the Bosnian genocide and human rights violations committed by all sides during the Bosnian war to lend support to Bosnia and remember the victims of the Bosnia war.[98] “Never again” was a promise made to prevent future human suffering on the scale of the Holocaust.[99] We broke that promise when the genocide happened in Bosnia and now we must not stand idly by while the final stage of genocide occurs—denialism.
[1] Bosnian War, John R. Lampe, Britannica, 6 Oct. 2022, https://www.britannica.com/event/Bosnian-War
[2] Court Declares Bosnia Killings Were Genocide, Marlise Simons, The New York Times, 27 Feb. 2007, https://www.nytimes.com/2007/02/27/world/europe/27hague.html
[3] The Bosnian Genocide, Montreal Holocaust Museum, accessed 1 Nov. 2022, https://museeholocauste.ca/en/resources-training/the-bosnian-genocide/
[4] Prosecuting the Crime of Genocide, United States Holocaust Memorial Museum, accessed 20 Nov. 2022, https://www.ushmm.org/genocide-prevention/countries/bosnia-herzegovina/case-study/aftermath/prosecuting-the-crime-of-genocide
[5] Bosnia is still finding bodies from a genocide some leaders claim never happened, Chico Harlan, The Washington Post, 21 Feb. 2022, https://www.washingtonpost.com/world/2022/02/21/bosnia-genocide-denial-crisis/
[6] European Human Rights and Constitution-building in a Post-conflict Society: the Case of Bosnia and Herzegovina, David Feldman, Cambridge Yearbook of European Legal Studies, 101-102, Vol. 7, 2004-2005.
[7] Ibid. at 102.
[8] Ibid. at 102-103.
[9] Ibid. at 103.
[10] Ibid. at 103.
[11] Ibid. at 103.
[12] Holocaust Encyclopedia: Bosnia, United States Holocaust Memorial Museum, accessed 26 Oct. 2022, https://encyclopedia.ushmm.org/content/en/article/bosnia
[13] Ibid. at 104.
[14] Holocaust Encyclopedia: Bosnia, United States Holocaust Memorial Museum, https://encyclopedia.ushmm.org/content/en/article/bosnia
[15] Genocide and the ending of war: Meaning, remembrance and denial in Srebrenica, Bosnia, Klejda Mulaj, Crime, Law, and Social Change, 130, Vol. 68, Iss. 1-2, September 2017.
[16] Ibid. at 131.
[17] Ibid. at 131.
[18] European Human Rights and Constitution-building in a Post-conflict Society, Feldman, 112.
[19] Ibid.
[20] Holocaust Encyclopedia: Bosnia, United States Holocaust Memorial Museum, https://encyclopedia.ushmm.org/content/en/article/bosnia
[21] Hague Tribunal History: Decades of Atrocities, Anguish, and Justice for Ex-Yugoslavia, Any Heil, RadioFreeEurope, 30 June 2021, https://www.rferl.org/a/yugoslavia-hague-tribunal-major-moments/31334488.html#:~:text=The%20ICTY%20convicted%20three%20junior,Serb%20region%20of%20Bosnia%2DHerzegovina
[22] Reflections on the Judgment of the International Court of Justice in Bosnia’s Genocide Case against Serbia and Montenegro, Susana SáCouto, Human Rights Brief, 3, 2007, Vol. 15, Iss. 1.
[23] The 8 Stages of Genocide, Gregory H. Stanton, Genocide Watch, 2, 1996, http://genocide-watch.com/genocide/8stagesofgenocide.html
[24] Ibid.
[25] Ibid. at 4.
[26] Legislating against Genocide Denial: Criminalizing Denial or Preventing Free Speech?, Roger W. Smith, University of St. Thomas Journal of Law and Public Policy, 129, 2010, Vol. 4, Iss. 2.
[27] Ibid. at 129-30.
[28] Ibid. at 129.
[29] Genocide and the ending of war, Mulaj. 129.
[30] Ibid.
[31] Defining or Diverting Genocide: Changing the Comportment of Genocide, Freda Kabatsi, International Criminal Law Review, 388, 2005, Vol. 5, Iss. 3.
[32] Ibid.
[33] Reconciliation: Part Two: No Way Home, NPR Ideas Podcast, https://www.cbc.ca/radio/ideas/genocide-denial-leave-bosniaks-stuck-in-a-violent-past-1.5851833
[34] Genocide and the ending of war, Mulaj, 129.
[35] Genocide and the ending of war, Mulaj 139.
[36] Why Bosnia’s ban on genocide denial was a necessity, Ehlimana Memišević, AlJazeera, 13 Aug 2021. https://www.aljazeera.com/opinions/2021/8/13/why-bosnias-ban-on-genocide-denial-was-a-necessity
[37] Genocide and the ending of war, Mulaj, 134.
[38] Ibid. at 135.
[39] Ibid. at 135.
[40] Ibid. at 139.
[41] Genocide denial leave Bosniaks stuck in a violent past, CBC Radio, 18 Apr 2022. https://www.cbc.ca/radio/ideas/genocide-denial-leave-bosniaks-stuck-in-a-violent-past-1.5851833
[42] Why Bosnia’s ban on genocide denial was a necessity, Ehlimana Memišević, AlJazeera, 13 Aug 2021. https://www.aljazeera.com/opinions/2021/8/13/why-bosnias-ban-on-genocide-denial-was-a-necessity
[43] Genocide Denial, Rising Tensions, and Political Crisis in Bosnia, Tallan Donine, United States Holocaust Memorial Museum, 18 Feb 2022. https://www.ushmm.org/genocide-prevention/blog/genocide-denial-rising-tensions-and-political-crisis-in-bosnia; How Bosnia’s Dodik went from a moderate reformist to genocide-denying secessionist, The Associated Press, NPR, 8 Jan 2022. https://www.npr.org/2022/01/08/1071537135/how-bosnias-dodik-went-from-a-moderate-reformist-to-genocide-denying-secessionis
[44] Genocide denial leave Bosniaks stuck in a violent past, CBC Radio, 18 Apr 2022. https://www.cbc.ca/radio/ideas/genocide-denial-leave-bosniaks-stuck-in-a-violent-past-1.5851833
[45] Ibid.
[46] Ibid.
[47] Legislating against Genocide Denial, Smith, 131.
[48] Ibid. at 128.
[49] Ibid. at 134.
[50] Holocaust Denial and the Law, Michael Bazyler, 197, 2016, Oxford University Press.
[51] Ibid. at 198.
[52] Holocaust Denial and the Law, Bazyler, 202; Legislating against Genocide Denial, Smith, 136.
[53] Holocaust Denial and the Law, Bazyler, 200.
[54] Evisceration of the Right to Appeal: Denial of Individual Responsibility as Actionable Genocide Denial, Jennifer E. King, Vanderbilt Law Review, p. 250, Jan 2021, vol. 74, no. 1.
[55] Ibid.
[56] “It’s getting out of hand”: genocide denial outlawed in Bosnia, Associated Press, The Guardian, 24 Jul 2021, https://www.theguardian.com/world/2021/jul/24/genocide-denial-outlawed-bosnia-srebrenica-office-high-representative
[57] General Information, Office of the High Representative, visited on 11 Nov 2022, http://www.ohr.int/about-ohr/general-information/; Feldman, 114.
[58] General Information, Office of the High Representative, visited on 11 Nov 2022, http://www.ohr.int/about-ohr/general-information/; Feldman, 114.
[59] Bosnia’s peace envoy imposes jail terms for genocide denial, Reuters, 23 July 2021, https://www.reuters.com/world/europe/bosnias-peace-envoy-imposes-jail-terms-genocide-denial-2021-07-23/.
[60] “It’s getting out of hand”: genocide denial outlawed in Bosnia, Associated Press, The Guardian, 24 Jul 2021, https://www.theguardian.com/world/2021/jul/24/genocide-denial-outlawed-bosnia-srebrenica-office-high-representative
[61] Ibid.
[62] Bosnian Serb Decree Rejecting Genocide Denial Law Sparks Uncertainty, Lamija Grebo, Balkan Transitional Justice, 13 Oct 2021, https://balkaninsight.com/2021/10/13/bosnian-serb-decree-rejecting-genocide-denial-law-sparks-uncertainty/
[63] OSCE Warns Against Hate Incidents Destabilising Bosnia, Reuters, U.S. News, 12 Jan. 2022, https://www.usnews.com/news/world/articles/2022-01-12/osce-warns-against-hate-incidents-destabilising-bosnia
[64] Bosnia’s Genocide Denial Ban Curbs Violations, But No Prosecutions Yet, Emina Dizdarevic and Lamija Grebo, Balkan Insight, July 6, 2022, https://balkaninsight.com/2022/07/06/bosnias-genocide-denial-ban-curbs-violations-but-no-prosecutions-yet/
[65] Ibid.
[66] Ibid.
[67] EU working to amend genocide denial law that is blamed for Bosnia crisis, Julian Borger, The Guardian, 22 Dec 2021, https://www.theguardian.com/world/2021/dec/22/eu-working-to-amend-law-on-srebrenica-genocide-denial-to-blame-for-bosnia-crisis
[68] Ibid.
[69] Legislating against Genocide Denial, Smith, 137.
[70] Education about the Holocaust and genocide, UNESCO, accessed 19 Nov. 2022, https://en.unesco.org/themes/holocaust-genocide-education
[71] Two schools under one roof: a lesson in ethnic unmixing from Bosnia’s segregated school system, Tea Hadziristic, openDemocracy, 3 March 2017, https://www.opendemocracy.net/en/can-europe-make-it/two-schools-under-one-roof-lesson-in-ethnic-unmixing-from-bosnia-/
[72] Ibid.
[73] Ibid.
[74] Bosnia and Herzegovina: Teaching Intolerance, Anes Alic, Open Society Foundations, 2 June 2008, https://www.opensocietyfoundations.org/voices/bosnia-and-herzegovina-teaching-intolerance
[75] On Srebrenica Massacre Road, School Won’t Teach Of Tragedy, Ron Synovitz & Ajla Obradovic, RadioFreeEurope, 31 Aug 2019, https://www.rferl.org/a/on-srebrenica-massacre-road-school-won-t-teach-of-tragedy/30139243.html
[76] Ibid.
[77] Ibid.
[78] Ibid.
[79] Education about the Holocaust and genocide, UNESCO, accessed 19 Nov. 2022, https://en.unesco.org/themes/holocaust-genocide-education
[80] Transitional Justice, Education, and Sexual Violence Stigma: The Results of a Schools-based Study in Bosnia-Herzegovina, Janine Natalya Clerk, Journal of Law and Society, p. 28, 2018, volume 45, issue 4.
[81] Ibid.
[82] Nationalist Divisions Dim Hopes for Change After Bosnia’s Election, Dado Ruvic Daria Sito-Sucic, U.S. News, 29 Sept. 2022, https://www.usnews.com/news/world/articles/2022-09-29/nationalist-divisions-dim-hopes-for-change-after-bosnias-election
[83] Ibid.; Separatist leader sworn in as Bosnian Serb president, The Associated Press, The Seattle Times, 15 Nov. 2022, https://www.seattletimes.com/business/separatist-leader-sworn-in-as-bosnian-serb-president/
[84] Genocide denial leave Bosniaks stuck in a violent past, CBC Radio, 18 Apr 2022, https://www.cbc.ca/radio/ideas/genocide-denial-leave-bosniaks-stuck-in-a-violent-past-1.5851833
[85] See Bosnian Serb leader Dodik says Ukraine war has delayed secession plan, Daria Sito-Sucic, Reuters, 6 June 2022, https://www.reuters.com/world/europe/bosnian-serb-leader-dodik-says-ukraine-war-has-delayed-secession-plan-2022-06-06/; Separatist leader sworn in as Bosnian Serb president, The Associated Press, The Seattle Times, 15 Nov. 2022, https://www.seattletimes.com/business/separatist-leader-sworn-in-as-bosnian-serb-president/
[86] Genocide denial leave Bosniaks stuck in a violent past, CBC Radio, 18 Apr 2022, https://www.cbc.ca/radio/ideas/genocide-denial-leave-bosniaks-stuck-in-a-violent-past-1.5851833
[87] Grappling with Bosnia’s dual crises, OCHA Services, 9 Nov. 2021, https://reliefweb.int/report/bosnia-and-herzegovina/grappling-bosnia-s-dual-crises
[88] Last-minute legal changes to Bosnian election law stir controversy, Eszter Zalan, EUobserver, 3 Oct. 2022, https://euobserver.com/world/156204
[89] Ibid.
[90] Legislating “apartheid”: Critics slam Bosnia’s election law plan, Mersiha Gadso, Aljazeera, 24 July 2022, https://www.aljazeera.com/news/2022/7/24/legislating-apartheid-critics-slam
[91] NATO assumes peacekeeping duties in Bosnia, History.com Editors, 9 Feb. 2010, https://www.history.com/this-day-in-history/nato-assumes-peacekeeping-duties-in-bosnia
[92] About EUFOR, European Union Force in BiH Operation Althea, 16 Aug 2022, https://www.euforbih.org/index.php/about-eufor
[93] Ibid.
[94] Treasury Sanctions Milorad Dodik and Associated Media Platform for Destabilizing and Corrupt Activity, U.S. Department of Treasure Press Releases, 5 Jan. 2022, https://home.treasury.gov/news/press-releases/jy0549; US Sanctions Bosnian Serb leader Milorad Dodik for ‘destabilizing activities,’ Julian Borger, The Guardian, 5 Jan. 2022, https://www.theguardian.com/world/2022/jan/05/us-sanctions-bosnian-serb-leader-milorad-dodik
[95] US sanctions Bosnian leader, official for threatening peace accords, Laura Kelly, The Hill, 6 June 2022, https://thehill.com/homenews/administration/3513166-u-s-sanctions-bosnian-president-official-for-threatening-peace-accords/.
[96] Genocide and the ending of war, Mulaj. 129.
[97] Ibid.
[98] European Human Rights and Constitution-building in a Post-conflict Society, Feldman, 101-102.
[99] Genocide and Crimes Against Humanity, World Without Genocide, last accessed 19 Nov 2022, https://worldwithoutgenocide.org/genocides-and-conflicts/background-and-overview-information/icc/genocide-and-crimes-against-humanity.