The recent trial and conviction, in a national court, of former Guatemalan President General Efraín Ríos Montt on charges of genocide and crimes against humanity is only the latest blow against the impunity that previously protected high officials responsible for atrocities. Though the conviction has since been overturned by Guatemala’s Constitutional Court, Ríos Montt joins dozens of former heads of state and government leaders who have been prosecuted for gross abuses of human rights since the ICTY was established.