The U.S. Department of State has described Ethiopia as “a strategic partner in the Global War on Terrorism”1 and welcomed “Ethiopia’s dedication to maintaining security in the region.”2 The country has received high-level visits from U.S. President Barack Obama and Secretary of State John Kerry, both of whom lauded the partnership between the two countries in addressing governance issues, economic growth, and regional security concerns. The encomia are more than merited, both for the Ethiopian government’s actions abroad and for the challenges it faces at home, which the most recent edition of the Department’s Country Reports on Terrorism summarized as follows: “The continuing threat of al-Shabaab emanating from Somalia dominated the Government of Ethiopia’s security posture and the Ethiopia National Defense Forces’s (ENDF’s) counterterrorism efforts in Somalia. Therefore, the Government of Ethiopia’s counterterrorism efforts focused on fighting al-Shabaab in Somalia and pursuing potential threats in Ethiopia.”3
As of late 2016, Islamist threats to Ethiopia’s security are primarily external and emanate from Somalia.
While a certain amount of controversy surrounds the precise details of Islamism’s introduction into Ethiopia, a bridgehead seems to have been established in and around the town of Harar fairly early on in the 20th century, perhaps during the Italian occupation (1936-1942), by pilgrims returning from the hajj. Later, in the 1960s and 1970s, a number of Oromo students returning from religious studies in Saudi Arabia further propagated political Islam, not only in their native regions but also in Addis Ababa and Wollo. The May 1991 fall of the Derg dictatorship gave new impetus to these trends, as many returning Oromo exiles had been influenced by Wahhabi doctrines during their time abroad and the new government’s policies facilitated the contact with coreligionists in other countries, who supported the establishment of mosques, schools, and associations.4 Among the latter were two entities in Addis Ababa: the Ethiopian Muslim Youth Association, founded in the 1990s and linked to the Riyadh-based World Association of Muslim Youth (WAMY), and the Alawiyah School and Mission Center, owned since 1993 by the Saudi-controlled World Muslim League’s International Islamic Relief Organization (IIRO).5 IIRO has also donated food and medical relief to Ethiopia following natural disasters.6 (In August 2006, the U.S. Treasury Department formally designated the Philippine and Indonesian branches of the IIRO for facilitating terrorism.7 )
Like their Wahhabi confrères elsewhere, Ethiopian Islamists have attacked what they regard as syncretism among other Muslims, as exemplified by certain Sufi-inspired practices like pilgrimages to various shrines and the celebration of Mawlid (the birthday of the prophet Muhammad). More recently, some zealots have pushed for a stricter observance of what they regard as compulsory practices such as the wearing of pants above the ankles and the use of face coverings by women. The tensions within the Muslim community were further aggravated when a branch of Takfir wal-Hijrah (“Excommunication and Exodus”), a radical group which originated in Egypt in the 1970s, was driven from Sudan and decamped first to Gondar and, subsequently, to a northern suburb of Addis Ababa.8 The group labels most fellow Muslims, including other Wahhabis, as kuffar (“non-believers”). Although it has caused less of a sensation since the death, in 2004, of its leader in Ethiopia, Sheikh Muhammad Amin, the group continues to exist.9 Details of the group’s activities, capabilities and resources within Ethiopia, however, remain sketchy at best, although one well-respected researcher with extensive fieldwork on the Muslim community in the country has noted that Ethiopian adherents of Takfir wal-Hijrah refuse to recognize the national constitution, pay taxes, or carry identification cards.10
Al-Qaeda is also active in Ethiopia. The organization has long viewed East Africa as a priority within its overall strategy. According to the Combating Terrorism Center at West Point, the nascent al-Qaeda, then based in Sudan, sought both to establish working relations with Islamist extremists in Somalia and create training camps in ethnic Somali areas of Ethiopia in the early 1990s.11 When Ethiopia intervened in Somalia in 2006 and again in 2014, for example, al-Qaeda renewed its interest in targeting both the Horn of Africa in general and Ethiopia in particular. However, like with Takfir wal-Hijrah (above), accurate information on al-Qaeda’s organizational make-up and capabilities in Ethiopia is far from complete, at least at the open-source level. Moreover, there are indications that the foothold al-Qaeda once held in East Africa through links to al-Shabaab has eroded, particularly as the Islamic State in Iraq and Syria (ISIS) has gained ground.
Another Islamist group active in Ethiopia is the world’s largest dawa (proselytizing) movement, Tablighi Jamaat. Founded in India in 1929, the group first came to Ethiopia from South Africa in the 1970s. Its activities, however, were very limited until after the fall of the Derg, the Marxist junta led by Mengistu Haile Mariam that seized control of Ethiopia after deposing the Emperor Haile Selassie in 1974 and ruled the country until its own overthrow in 1991. Little is known about the group’s activities other than that its center of operations seems to be the Kolfe district of Addis Ababa, where it is especially active within the Gurage community that has migrated to the city from their mountainous homeland southwest of there.
The principal Islamist threat to Ethiopia, however, comes from neighboring Somalia. Following the January 1991 collapse of the Muhammad Siyad Barre regime, the last effective central government of Somalia, the rise of al-Itihaad al-Islamiya (AIAI, “Islamic Union”) posed serious challenges to Ethiopian security—a situation that would persist throughout the 1990s. While the AIAI’s primary focus was on the establishment of an Islamist state in Somalia, it also encouraged subversive activities among ethnic Somalis in the Somali region of Ethiopia and carried out a series of terrorist attacks, including the bombing of two hotels in 1996 and the attempted assassination, in 1995 that same year, of cabinet minister Abdul Majeed Hussein, an ethnic Somali Ethiopian whom the AIAI accused of being a traitor. AIAI’s hostility to Ethiopia arose from its toxic mix of Islamism with Somali irredentist designs on Ethiopian territory. The exasperated Ethiopian regime finally intervened in Somalia in August 1996, wiping out al-Itihaad bases in the Somali towns of Luuq and Buulo Haawa and killing hundreds of Somali extremists, as well as scores of non-Somali Islamists who had flocked to the Horn under the banner of jihad.12
As it turns out, the defeat was only a temporary setback for Somali Islamists, who regrouped under the banner of the Islamic Courts Union (ICU) with many of the same leaders as AIAI. One such leader was Sheikh Hassan Dahir Aweys, who had served as number two in AIAI and went on to chair the ICU’s shura and later head the Eritrea-based Alliance for the Re-Liberation of Somalia (ARS), after Ethiopian forces intervened in Somalia in December 2006 in support of the country’s internationally-recognized, but weak “Transitional Federal Government.” The presence of Ethiopian troops in Somalia, which lasted until early 2009, occasioned an Islamist insurgency spearheaded by the radical Harakat al-Shabaab al-Mujahideen (“Movement of Warrior Youth,” more commonly known as al-Shabaab), a group that was labeled a “specially designated global terrorist” by the U.S. Department of State in 2008.13 Subsequently, in 2012, the U.S. Department of State added seven al-Shabaab leaders to its Rewards for Justice program, offering large rewards for information leading to their locations.14 In 2014, Ethiopian forces returned to Somalia as official contributors to the African Union Mission in Somalia (AMISOM), prompting renewed calls from al-Shabaab to attack Ethiopian forces in Somalia and at home. “We defeated Ethiopia before and we know how to battle them now,” al-Shabaab spokesman Ali Mohamud Rage said.15
Fortunately, much of the pressure from this quarter has been relieved with the military and political setbacks suffered by al-Shabaab since it was forced to withdraw from Mogadishu in August 2011.16 That said, the absence of a major al-Shabaab attack in Ethiopia is not due to a lack of effort on the part of the group; in 2013, two suspected al-Shabaab operatives were killed when the bomb they were working on exploded in a home in an affluent Addis Ababa neighborhood. No one else was injured, though authorities arrested five people for their involvement and reported that al-Shabaab planned to target an upcoming football match.17 Thus, the resurgence in al-Shabaab activities in Somalia in 2016 will, undoubtedly, be closely watched by authorities in Ethiopia.
While the threat from Somalia is external, it cannot be entirely separated from the internal threat to Ethiopian national security posed by dissidents who align themselves with the country’s foreign enemies.
Among the latter, Eritrea falls into a category all of its own, given the bitter two-year war which the tiny state precipitated in May 1998 when it occupied a small sliver of territory that had up to then been peaceably administered by Ethiopia. While the regime of Eritrean President Isaias Afewerki is not known for its religiosity, that has not prevented it from supporting Islamist movements that serve its overall strategic objective of undermining the Ethiopian government. To this end, it has at times in the twenty-first century lent support to the Islamist insurgency in Somalia,18 as well as to the secessionist Ogaden National Liberation Front (ONLF) in Ethiopia, which has frequently partnered with its extremist ethnic kin in Somalia.19
Traditionally, the dominant ethnic group in Ethiopia has been the Amhara, who, together with the Tigray, currently make up about 33 percent of the population, according to the last national census (conducted in 2007).20 The Oromo, who live largely in the southern part of the country, constitute another 34 percent. Other important ethnic groups include the Somali (6.2 percent), Gurage (2.5 percent), Sidama (4 percent), and Welayta (2.3 percent). Religiously, more than half of the population is Christian, mainly adherents of the Ethiopian Orthodox Tewahedo Church, an Oriental (Monophysite) Orthodox Christian body in communion with the Armenian, Coptic, and Syrian Churches. Evangelical Christianity is the fastest growing denomination in Ethiopia, with some 14 million Protestants counted in the country’s last census.21 Another 34 percent or so is Muslim, drawn primarily from the Oromo and other southern peoples, as well as the ethnic Somali and the Afar. Given that the population of Ethiopia is estimated to number at least 100 million, the country has more Muslims than many Muslim states, including Afghanistan and Saudi Arabia.22
Almost all Muslims in Ethiopia are Sunni, with a plurality, if not a majority, adhering to one or another Sufi tarīqa (order). The most widely followed of these is the Qadiriyya, although the Tijaniyya, Shaziriyya, and Semaniyya orders also have significant followings. Islam is most prevalent in eastern Ethiopia, particularly in the Somali and Afar regions, as well as in many parts of the Oromo region. While institutional Islam in Ethiopia tends to be decentralized, the Ethiopian Supreme Council for Islamic Affairs, formally established (although not accorded de jure recognition) in 1976, is treated by the government as “representative of the Ethiopian Muslim community” and accorded the same courtesies as the heads of the Orthodox, Catholic, and Protestant Churches in state ceremonial matters.23
Overall, especially in contrast to the rough times experienced under the Derg dictatorship, the Muslim community in Ethiopia has fared better under the Ethiopian Peoples’ Revolutionary Democratic Front (EPRDF) government, which lifted its predecessor’s restrictions on the hajj, ban on the importation of religious literature, and obstacles to the construction of mosques and religious schools.24 The opening “produced a new consciousness among the Muslim population, generated new religious affiliations and paved the way for Islam in Ethiopia to become more visible.” 25
By and large, Ethiopian Muslims have resisted the attempts of radical co-religionists to promote political Islam. The main reasons for this failure of Islamism to gain traction include not only the deep roots of more traditional forms of Islam, especially those represented by the Sufi orders, and the strength of social ties that cross religious boundaries, but also the fact that the extremists have failed to offer concrete solutions to many of the problems faced by ordinary Ethiopians. By contrast, the government despite its limitations, has managed to deliver impressive rates of economic growth.26 Nonetheless, the potential does exist for religion to be exploited to mobilize greater support by various separatist or extremist movements.
Beginning in 2011, tensions escalated between some parts of the Muslim community and the Ethiopian government, with the former accusing the latter of interfering in religious matters by allegedly trying to impose the quietist Al-Ahbash sect on the country’s Supreme Islamic Council.27 Protests over more than a year drew thousands, and grievances widened to include perceived government interference in Islam and in the selection of the Supreme Islamic Council. In 2015, a court convicted eighteen Muslims who had been arrested during the protests under the country’s anti-terrorism law.28 Activists and some human rights organizations suggested that the trial of these Muslim activists—in addition to other, lower-profile cases—was politicized and not held in accordance with the law.29
Following the 1974 overthrow of the Emperor Haile Selassie, the communist Derg regime of Mengistu Hailemariam persecuted religious leaders and discouraged the practice of religion by Christians and Muslims alike. Since the defeat of the dictatorship, and the subsequent assumption of power of the current government led by the Ethiopian Peoples’ Revolutionary Democratic Front (EPRDF) in 1991, the policy has shifted to one of religious tolerance, although the formation of political groups on the basis of religion is forbidden. According to the State Department’s 2015 annual report on religious freedom, the Ethiopian constitution “requires the separation of state and religion, establishes freedom of religious choice and practice, prohibits religious discrimination, and stipulates the government shall not interfere in the practice of any religion.”30 Also in 2015, “some religious leaders reported interreligious tensions were at a five-year low.”31
Despite—or perhaps because of—this lack of domestic tension, the Ethiopian government has taken a significant role in regional and international counterterrorism efforts. It served as host for the African Union’s Center for Study and Research on Terrorism and in 2008 ratified the Protocol to the OAU Convention on the Prevention and Combating of Terrorism.32 From 2006 through late 2008, Ethiopia led the efforts in Somalia against extremists connected with the ICU, and provided “critical support” to AMISOM in their efforts against extremist groups.33 In 2014, Ethiopia intervened again in Somalia in support of AMISOM’s effort to fight al-Shabaab. The U.S. State Department has generally considered Ethiopia to be an “important regional security partner,”34 although funds for military assistance “are explicitly limited to nonlethal assistance, training, and peacekeeping support at present.”35
However, Ethiopia’s counterterrorism efforts have drawn mixed reviews. In 2009, Ethiopia passed an anti-terrorism law designed to discourage the formation and activities of radical groups within its borders, carrying penalties ranging up to life imprisonment and even the death penalty. Expressing support for terrorism was likewise criminalized: “Whosoever writes, edits, prints, publishes, publicises, disseminates, shows, makes to be heard any promotional statements encouraging... terrorist acts is punishable with rigorous imprisonment from 10 to 20 years.”36 The legislation, while recognized as an attempt to combat extremism, has drawn criticism from Ethiopia’s international partners and from human rights organizations who claim that the law’s ambiguous language, as well as its uneven implementation, is an attempt by the EPRDF to cement its power and justify oppression of opposition groups and independent media.36
Others have pointed to the country’s recent elections as further reason for concern. In May 2010, the EPRDF and its allies won 545 out of 547 seats in the country’s parliament. While the lopsided results were partially attributable to divisions within the opposition, they nonetheless raised questions among some analysts about the future of democracy in the Ethiopia.38 In May 2015, the ruling party’s victory in parliament was further cemented when the opposition did not win a single seat.39
As of late 2016, widespread demonstrations throughout the country’s two largest regions—Amhara and Oromia—were ongoing. Protests began in late 2014 over the government’s announcement of a controversial land reallocation scheme; they have continued and expanded in scope to be broadly anti-government. While primarily peaceful, some protesters have engaged in serious property damage—especially affecting foreign-owned businesses. Scores have been arrested, and hundreds have been killed in clashes with security forces.40 As a result of the ongoing unrest, Ethiopian authorities announced a six-month state of emergency to begin in October 2016, which allows expanded powers to the security services; the government has thus far blamed the unrest on “anti-peace” elements from Eritrea and Egypt.41 While there is no overt religious element to the current demonstrations, the Ethiopian government’s claims of foreign meddling, as well as its restrictions on ordinary citizens as a result of the unrest, bear watching.
Not all experts see cause for concern, however. Rather, they emphasize the progress Ethiopia has made since ousting the Soviet regime in 1991—especially when placed in the context of its neighbors Eritrea, Somalia, and Kenya, all of whom have struggled with instability.42
Nevertheless, the potential for conflict remains. After the fall of the communist Derg dictatorship, a constituent assembly convened by the EPRDF government adopted a constitution in 1994 that carried “a radical recognition of diversity and of a new kind of equality.”43 Each ethnic community is accorded the right and duty to manage its own affairs under the aegis of a federal government that serves as the center for state unity. While it is too early to declare the success or failure of this system of ethnic federalism, it does raise the specter of struggles for allegiance between religion and ethnicity. It also creates the distinct possibility that Islam in particular may be used by groups seeking to mobilize their ethnic kin to exercise the secession that the constitution affirms is an inherent part of the “unconditional right of self-determination” accorded to every “group of people who have or share a large measure of common culture or similar customs, mutual intelligibility of language, belief in a common or related identities, a common psychological make-up, and who inhabit an identifiable, predominantly contiguous territory.”44 Against this potential vulnerability—which external foes, both state and non-state will be eager to seize upon—the Ethiopian government will need to maintain constant vigilance, especially as the country enters a new political era and its leaders try to maintain its much-valued stability and economic growth amid rapidly changing societal expectations.
 U.S. Department of State, Bureau of African Affairs, “Background Note: Ethiopia,” June 2009, http://www.state.gov/outofdate/bgn/ethiopia/82233.htm.
 U.S. Department of State, Bureau of African Affairs, “Fact Sheet: U.S. Relations with Ethiopia,” June 2016, http://www.state.gov/r/pa/ei/bgn/2859.htm.
 U.S. Department of State, Office of the Coordinator for Counterterrorism, “Country Reports: Africa Overview,” in Country Reports on Terrorism 2015, October 21, 2016, http://www.state.gov/j/ct/rls/crt/2015/257514.htm.
 See generally Haggai Erlich, Saudi Arabia and Ethiopia: Islam, Christianity, and Politics Entwined (Boulder, CO: Lynne Rienner, 2007).
 Terje Østebø, “The Question of Becoming: Islamic Reform Movements in Contemporary Ethiopia,” Journal of Religion in Africa 38, no. 4 (2008), 421.
 David H. Shinn, “Ethiopia: Governance and Terrorism,” in Robert I. Rotberg, ed., Battling Terrorism in the Horn of Africa (Cambridge, MA and Washington, DC: World Peace Foundation/Brookings Institution, 2005), 98.
 Press Release, “Treasury Designates Director, Branches of Charity Bankrolling Al Qaeda Network,” U.S. Department of the Treasury, August 2, 2006, http://www.treas.gov/press/releases/hp45.htm.
 Timothy Carney, “The Sudan: Political Islam and Terrorism,” in ibid., 122.
 Østebø, “The Question of Becoming,” 422-423.
 See Éloi Ficquet, “The Ethiopian Muslims: Historical Processes and Ongoing Controversies,” in Gérard Prunier and Éloi Ficquet, eds., Understanding Contemporary Ethiopia (London: Hurst and Company, 2015), 107.
 Combating Terrorism Center at West Point, Al –Qa’ida’s (mis)Adventures in the Horn of Africa (West Point, NY: U.S. Military Academy, Harmony Project, 2007), 38-40.
 Medhane Tadesse, Al-Ittihad: Political Islam and Black Economy in Somalia. Religion, Money, Clan and the Struggle for Supremacy over Somalia (Addis Ababa: Meag printing enterprise, 2002), 156-168.
 U.S. Department of State, Office of the Coordinator for Counterterrorism, “Designation of al-Shabaab as a Specially Designated Global Terrorist” (Public Notice 6137), February 26, 2008, http://www.state.gov/s/ct/rls/other/des/102448.htm.
 U.S. Department of State, Office of the Spokesperson, “Rewards for Justice – al-Shabaab Leader Rewards Offers” June 7, 2012, http://www.state.gov/r/pa/prs/ps/2012/06/191914.htm.
 “Somalia Islamists Vow to Boost Attacks as Ethiopia Joins AU Force,” Ahram Online, January 25, 2014, http://english.ahram.org.eg/NewsContent/2/9/92471/World/International/Somali-Islamists-vow-to-boost-attacks-as-Ethiopia-.aspx.
 Bronwyn Bruton and J. Peter Pham, “The Splintering of Al Shabaab,” Foreign Affairs, February 2, 2012, http://www.foreignaffairs.com/articles/137068/bronwyn-bruton-and-j-peter....
 Aaron Maasho, “Ethiopia Says Arrests Five Suspects in Soccer Match Bomb Plot,” Reuters, December 19, 2013, http://www.reuters.com/article/us-ethiopia-bombers-idUSBRE9BI14F20131219.
 J. Peter Pham, “Eritrea: Regional Spoiler Exacerbates Crisis in the Horn of Africa and Beyond,” World Defense Review, October 15, 2009, http://worlddefensereview.com/pham101509.shtml; See also Ahmed Mohamed Egal, “Eritrea’s Repayment of its Fraternal Debt to the Somali People,” American Chronicle, November 4, 2009, http://www.americanchronicle.com/articles/view/126773.
 J. Peter Pham, Testimony before the U.S. House of Representatives Committee on Foreign Affairs, Subcommittee on Africa and Global Health, October 2, 2007, http://foreignaffairs.house.gov/110/pha100207.htm.
 “Ethiopia,” CIA World Factbook, October 21, 2016, https://www.cia.gov/library/publications/the-world-factbook/geos/et.html.
 Emanuele Fantini, “Go Pente! The Charismatic Renewal of the Evagelical Movement in Ethiopia,” in Gérard Prunier and Éloi Ficquet, eds., Understanding Contemporary Ethiopia.
 “Ethiopia,” CIA World Factbook.
 Hussein Ahmed, “Coexistence and/or Confrontation?: Towards a Reappraisal of Christian-Muslim Encounter in Contemporary Ethiopia,” Journal of Religion in Africa 36, no. 1 (2006), 11-12.
 Hussein Ahmed, “Islam and Islamic Discourse in Ethiopia (1973-1993),” in Harold G. Marcus, ed., New Trends in Ethiopian Studies: Social Sciences (Papers of the 12th International Conference of Ethiopian Studies, vol. 1) (Lawrenceville, NJ: Red Sea Press, 1995), 775-801.
 Østebø, “The Question of Becoming,” 417.
 See Alex de Waal, ed., Islamism and its Enemies in the Horn of Africa (Addis Ababa: Shama Books, 2004); See also World Bank, “With Continued Rapid Growth, Ethiopia is Poised to Become a Middle Income Country by 2025,” November 23, 2015, http://www.worldbank.org/en/country/ethiopia/publication/ethiopia-great-....
 Ficquet, “The Ethiopian Muslims,” 117-18.
 U.S. Department of State, Bureau of Democracy, Human Rights, and Labor, “Country Report: Ethiopia,” in International Religious Freedom Report 2015, 2016, http://www.state.gov/j/drl/rls/irf/religiousfreedom/index.htm?year=2015&....
 Morgan Winsor, “Ethiopian Muslims Accused of Terrorism, Jailed for 22 Years After Obama’s Visit,” International Business Times, August 4, 2015, http://www.ibtimes.com/ethiopian-muslims-accused-terrorism-jailed-22-yea....
 U.S. Department of State, “Country Report: Ethiopia.”
 U.S. Department of State, “Background Note: Ethiopia.”
 U.S. Department of State, “Country Reports: Africa Overview.”
 U.S. Department of State, Bureau of African Affairs, “Background Note: Ethiopia,” November 5, 2010, http://www.state.gov/outofdate/bgn/ethiopia/158887.htm.
 U.S. Department of State, “Fact Sheet: U.S. Relations with Ethiopia.”
 “Ethiopia Adopts Strict Anti-Terrorism Bill,” Agence France Presse, July 7, 2009, http://www.google.com/hostednews/afp/article/ALeqM5hMqgOlskPvo1m_dSE35D1....
 Leslie Lefkow, Testimony before the House of Representatives Committee on Foreign Affairs, Subcommittee on Africa and Global Health, June 17, 2010; Human Rights Watch, “Ethiopia: Terrorism Law Decimates Media,” May 3, 2013, https://www.hrw.org/news/2013/05/03/ethiopia-terrorism-law-decimates-media.
 Barry Malone, “Ethiopia Court Rejects Final Poll Result Challenge,” Reuters, July 20, 2010, http://af.reuters.com/article/topNews/idAFJOE66J0RW20100720.
 Morgan Winsor, “Ethiopia Election 2015: Ruling Party Declares Historic 100 Percent Victory in Parliamentary Polls,” International Business Times, June 23, 2015, http://www.ibtimes.com/ethiopia-elections-2015-ruling-party-declares-his....
 “What is Behind Ethiopia’s Wave of Protests?” BBC, August 22, 2016, http://www.bbc.com/news/world-africa-36940906.
 “Ethiopia Blames Egypt and Eritrea Over Unrest,” BBC, October 10, 2016, http://www.bbc.com/news/world-africa-37607751.
 “Ethiopia’s Ruling Party Set For Landslide Win,” Reuters, May 24, 2010, http://af.reuters.com/article/ethiopiaNews/idAFLDE64N1C220100524.
 Jon Abbink, “An Historical-Anthropological Approach to Islam in Ethiopia: Issues of Identity and Politics,” Journal of African Cultural Studies 11, no. 2 (1998), 121-123.
 J. Peter Pham, “African Constitutionalism: Forging New Models for Multi-ethnic Governance and Self-Determination,” in Jeremy I. Levitt, ed., Africa: Mapping New Boundaries in International Law (Oxford: Hart Publishing 2008), 188-190.