The surrender of Albert Yekatom to the ICC: an infringement of the positive complementarity principl
1. The facts In the Central African Republic (CAR) II situation, Albert Yekatom alias ‘Rambo’, the former leader of the Anti-Balaka militia, was surrendered by CAR authorities to the International Criminal Court (ICC) on 17 November 2018, to answer for alleged war crimes and crimes against humanity committed in the western part of CAR between December 2013 and December 2014. This surrender was carried out following a warrant of arrest issued, under seal, by the ICC Pre-Trial