On December 10, as the International Court of Justice (ICJ) trial of Myanmar’s genocide against Rohingya Muslims got underway, de facto state leader Aung Sang Suu Kyi sat steely eyed, impassive. The Gambia, representing a coalition of 52 Muslim majority countries, called on the Court to invoke the 1948 Genocide Convention against Myanmar. Under the Convention, which was ratified by Myanmar in 1956, states can be held accountable for failing to prevent genocide, or failure to hold perpetrators of genocide accountable.