The trials for the Japanese war criminals were established in Tokyo, Japan, to implement the Cairo Declaration, the Potsdam Declaration, the Instrument of Surrender, and the Moscow Conference. The Potsdam Declaration (July 1945) had stated, "stern justice shall be meted out to all war criminals, including those who have visited cruelties upon our prisoners," though it did not specifically foreshadow trials.[7] The terms of reference for the Tribunal were set out in the IMTFE Charter, issued on January 19, 1946.[8] There was major disagreement, both among the Allies and within their administrations, about whom to try and how to try them. Despite the lack of consensus, General Douglas MacArthur, the Supreme Commander of the Allied Powers, decided to initiate arrests.