Two very different courts, both based at The Hague, have once again shown how difficult it is to prosecute individuals for genocide. On May 9, 2007 the Appeals Chamber of the International Criminal Tribunal for the former Yugoslavia (ICTY) overturned the conviction for complicity in genocide handed down against former Bosnian Serb commander Vidoje Blagojevic, while affirming his conviction for complicity in crimes against humanity committed in Srebrenica (Bosnia) in 1995. The ICTY ruled that the Srebrenica massacre of nearly 8,000 Bosnian Muslim men constituted genocide, but held that complicity required that Blagojevic knew of the primary actors' intention to commit genocide. The Appeals Chamber found that Blagojevic knew about the attack, the forced displacement of civilians, and the execution of approximately 50 Bosnian Muslims in Bratunac, but that he was not aware of the mass killings. His sentence was reduced to 15 years in prison. The same day, a Dutch appeals court acquitted Frans van Anraat for complicity in genocide, but raised his sentence with two years to 17 years for complicity in war crimes. The former businessman had been found guilty of delivering chemicals to former Iraqi president Saddam Hussein, who used them in chemical weapons against civilian populations in the 1980s. The appeals court found no evidence that Van Anraat knew, or could have known, about Hussein's intention to commmit genocide. The Dutch judges explained that the international law on liablity as accomplice in genocide has not been unequivocally established.