The BIAs were only granted following bully tactics from the United States  The United States has been accused of using bullying tactics in the pursuit of gaining Article 98 Agreements by, amongst others, Human Rights Watch [1] .  This has included significant reductions in non-military, development aid, including to countries such as South Africa, the Bahamas [2] and Peru [3] , as well as making threats to accession to NATO in the case of Croatia. [4]  By signing up to Article 98 Agreements, European nations help contribute to a climate where smaller nations can also be strong-armed in to harming the International Criminal Court by signing them, even if they were not subject to blackmailed in to it themselves.  [1] Roth, Kenneth, “Letter to the US Secretary of State Colin Powell on Bully Tactics against the International Criminal Court”, Human Rights Watch, 2003   [2] Roth, Letter to Colin Powell, 2003  [3] Keppler, Elise, “The United States and the International Criminal Court: The Bush Administration’s Approach and a Way Forward Under the Obama Administration”, Berkeley Journal of International Law, 2009, 2, p12,   [4] Roth, Letter to Colin Powell, 2003