2026 Amnesty International Report Architects of Atrocities

Amnesty International’s recent report, “The Architects of Atrocities,” submitted to the United Nations Security Council, argues that Iranian authorities have repeatedly committed crimes against humanity over several decades. The report presents a systematic account of these violations, with particular attention to the 2022 “Woman, Life, Freedom” uprising. It documents widespread and coordinated abuses during and after the protests, including arbitrary detention, torture, enforced disappearance, and unlawful killings.

The report also situates the 2022 crackdown within a longer history of state violence. It revisits earlier atrocities, including the 1988 prison massacres, and presents evidence and testimony that suggest a persistent pattern of grave human rights violations from the late 1980s to the present. Amnesty International argues that Iranian authorities have not only failed to address past abuses but have continued to commit similar acts with impunity. It therefore calls on the international community, particularly the United Nations Security Council, to take urgent action to ensure accountability and justice for victims and their families.

This report proceeds in four parts. First, it summarizes Amnesty International’s findings on alleged crimes against humanity connected to the 2022 “Woman, Life, Freedom” uprising and earlier abuses, including the 1988 prison massacres. Second, it explains why Iran’s status outside the Rome Statute limits the International Criminal Court’s automatic jurisdiction. Third, it examines documented assassinations and plots in Europe as possible evidence of a broader state policy. Finally, it assesses the realistic accountability pathways available through national prosecutions, a Security Council referral, and a separate international mechanism.

Amnesty International’s investigation, spanning more than 1,000 pages, concluded that Iranian authorities orchestrated a widespread and systematic assault on the civilian population. According to the report, this assault followed a deliberate state policy of using lethal force to suppress nationwide protests after Mahsa Amini died in custody. The report identifies several crimes against humanity, including:

• Murder
• Torture
• Enforced disappearance
• Arbitrary imprisonment
• Rape and other forms of sexual violence
• Persecution based on political opinion, gender, ethnicity, and religion

Amnesty documented the deaths of at least 377 protesters and bystanders, including 56 children, and reported that Baluchi and Kurdish communities suffered a disproportionate share of the violence. Thousands more were subjected to arbitrary detention, enforced disappearance, or torture. The report states that security forces, primarily the Islamic Revolutionary Guard Corps (IRGC) and FARAJA police, implemented these policies through coordinated chains of command involving the Supreme National Security Council and provincial and county-level security authorities. Amnesty named 87 officials, mostly IRGC and police commanders as well as senior Interior Ministry officials, whom it says should be subject to criminal investigation for their roles in these abuses.

According to Amnesty, the entrenched culture of impunity within Iran has enabled the recurrence and escalation of such atrocities. The organization argues that, without meaningful international accountability, patterns of unlawful killings, torture, enforced disappearances, and violent repression are likely to continue. It is urging the United Nations Security Council to refer the situation in Iran to the International Criminal Court and is calling on the UN General Assembly to establish a dedicated international criminal justice mechanism to address these grave crimes.

1988 Prison Massacres

Amnesty International has consistently characterized the mass extrajudicial executions and enforced disappearances of at least 5,000 political prisoners in 1988 as crimes against humanity. The organization asserts that these crimes are ongoing, as Iranian authorities continue to conceal the fate and whereabouts of the victims, deny or distort the historical record, and persecute the families who seek truth and justice. Amnesty has repeatedly called for an independent United Nations investigation into these events.

In its broader annual reporting on Iran, Amnesty highlights a persistent pattern of systemic impunity for both past and present violations of international law. These include unlawful killings during protests, torture, enforced disappearances, and the use of the death penalty as a tool of political repression. The organization warns that, in the absence of meaningful international accountability, the cycle of protest massacres and other grave abuses is likely to persist.

Iran’s status outside the International Criminal Court (ICC) is central to the accountability question. Although Iran signed the Rome Statute—the treaty establishing the ICC—on 31 December 2000, it has never ratified it. Signature alone does not make a state legally bound by the Statute; only ratification or accession does. As of 2026, there are 125 States Parties to the ICC, while Iran remains among the countries that have signed but not ratified the Rome Statute and is therefore not subject to the Court’s jurisdiction by default.

Because Iran is not a State Party, the ICC does not have automatic jurisdiction over crimes committed on Iranian territory or by Iranian nationals. However, the Court could exercise jurisdiction in limited circumstances:

• If an Iranian national commits a crime on the territory of a State Party, the ICC could have jurisdiction based on the location of the crime.
• If Iran were to make an ad hoc declaration under Article 12(3) of the Rome Statute, it could accept the Court’s jurisdiction for a specific situation or period of time.
• If the United Nations Security Council refers a situation in Iran to the ICC under Article 13(b) of the Statute, the Court could investigate and prosecute crimes, provided none of the five permanent members of the Security Council (China, France, Russia, the United Kingdom, and the United States) exercise their veto power to block the referral.

Iran participates in meetings of the Assembly of States Parties to the ICC only as an observer. This status allows it to attend sessions and make statements, but it does not give Iran membership, voting rights, or make it subject to the Court’s jurisdiction.

For these reasons, when organizations such as Amnesty International and other human rights advocates call for accountability for alleged crimes against humanity in Iran, they typically urge the United Nations Security Council to refer the situation to the ICC or call for the creation of a separate, UN-mandated accountability mechanism. They do not expect the ICC to act independently in the absence of such a referral or declaration, given the current legal limitations on the Court’s jurisdiction over Iran.

There is a substantial body of evidence documenting a long history of killings, assassinations, and other violent acts attributed to Iranian state actors and affiliated networks, both within and beyond the Middle East. These include high-profile attacks, such as the bombing of the Jewish community center in Argentina, as well as numerous assassination plots and operations across Europe.

The Mykonos restaurant assassinations in Berlin on September 17, 1992, remain among the most legally significant European cases attributed to Iranian state involvement. Four people were murdered: Sadegh Sharafkandi, leader of the Democratic Party of Iranian Kurdistan (PDKI), along with Fattah Abdoli, Homayoun Ardalan, and Nouri Dehkordi. After a lengthy trial, a German court convicted the gunmen and concluded that the operation had been ordered by Iran’s “Committee for Special Affairs,” with the knowledge and approval of senior Iranian leaders, including then-Intelligence Minister Ali Fallahian. The verdict led to an international arrest warrant for Fallahian and remains a rare example of a European court directly attributing a state-sponsored assassination to high-level Iranian officials.

Other well-documented assassinations in Europe attributed to Iranian operatives or their agents include:

• Shahriar Shafiq, nephew of the last Shah of Iran, shot dead in Paris in December 1979.
• General Gholam-Ali Oveissi, a former Iranian military commander, assassinated in Paris in 1984.
• Abdul Rahman Ghassemlou, leader of the Kurdish Democratic Party of Iran (KDPI), and two associates, killed during negotiations in Vienna in July 1989.
• Shapour Bakhtiar, the last prime minister before the 1979 revolution, stabbed to death in his Paris home in August 1991.
• Fereydoun Farrokhzad, a prominent dissident singer and entertainer, murdered in Bonn, Germany, in 1992.

In March 2025, former IRGC minister Mohsen Rafiqdoost publicly acknowledged that IRGC teams, as well as paid Basque separatists, had been involved in carrying out several of these European assassinations on behalf of the Iranian regime. This rare admission provided further confirmation of the state’s direct involvement in these operations.

In the Netherlands, authorities have linked the 2015 murder of Ali Motamed (real name Mohammad Reza Kolahi Samadi) in Almere and the 2017 assassination of Ahmad Mola Nissi in The Hague to Iranian intelligence networks. Dutch intelligence services have also connected subsequent plots to the same operational structures, indicating a persistent and ongoing threat.

Since 2020, Western governments and investigative organizations—including Reuters, the Washington Institute, and national intelligence agencies—have reported a marked escalation in Iran-linked plots across Europe. Unlike earlier operations, many recent plots appear to have been outsourced to criminal gangs or third-party actors rather than carried out directly by Iranian diplomats or IRGC officers. Reported targets have included Iranian dissidents, journalists, Jewish and Israeli sites, and outspoken critics of the regime, including former European Parliament vice-president Alejo Vidal-Quadras, who survived a shooting in Madrid in November 2023. The United Kingdom has stated that it has disrupted more than 20 Iran-linked kidnap or assassination plots on British soil since 2022, with similar disruptions reported in Germany, France, Sweden, and Greece.

Comprehensive datasets compiled by organizations such as the Abdorrahman Boroumand Center and the Washington Institute record well over 100 Iranian external operations in Europe since 1979, with a notable surge in activity between 2021 and 2024. While not every plot has succeeded—many have been thwarted by law enforcement and intelligence agencies—the consistent pattern, as reflected in court documents, intelligence assessments, and occasional admissions by Iranian officials, is that these campaigns are centrally directed from Tehran. The targets have ranged from political opponents and journalists to, increasingly, Jewish and Israeli-linked sites across multiple European countries, underscoring the broad and persistent nature of the threat.

There are numerous documented circumstances that could potentially support a referral of certain cases to the International Criminal Court (ICC). While the series of assassinations in Europe provides a possible jurisdictional basis for ICC involvement, these incidents alone do not automatically meet the established criteria for an ICC investigation or a referral by the United Nations Security Council.

1. Jurisdiction Over Killings in Europe

Iran is not a State Party to the Rome Statute, so the ICC cannot rely on the nationality of Iranian officials as a basis for jurisdiction. The Court may, however, exercise territorial jurisdiction under Article 12(2)(a) for crimes committed on the territory of a State Party. Germany, France, the Netherlands, Austria, Spain, Sweden, and the United Kingdom are all States Parties to the ICC. Assassinations in Berlin, Paris, Vienna, The Hague, Almere, Madrid, and other cities could therefore fall within the Court’s territorial jurisdiction. In principle, the ICC could investigate those specific acts even if the alleged masterminds were located in Tehran, although jurisdiction would be only the first step in any case.

2. The Nature of the Crimes: ICC Crimes Only

The ICC prosecutes only the most serious international crimes: genocide, war crimes, and crimes against humanity. Ordinary murder or terrorism falls outside its jurisdiction unless the conduct meets one of those legal thresholds. For the European assassinations, the most plausible charge would be crimes against humanity under Article 7 of the Rome Statute: murder or persecution committed as part of a widespread or systematic attack directed against a civilian population, pursuant to a state or organizational policy.

A sustained, centrally coordinated campaign targeting political opponents and journalists abroad could support an argument that the conduct formed part of a systematic attack under state policy. The Mykonos trial in Germany strengthens that argument by establishing state responsibility at senior levels in one major case. However, this theory remains untested at the ICC. The Court has never initiated a case solely on the basis of a pattern of extraterritorial targeted killings of dissidents. Historically, it has focused on large-scale attacks against civilian populations within a country, such as prison massacres, violent crackdowns on protests, or ethnic cleansing campaigns. Isolated or even serial assassinations abroad are more commonly handled by national courts.

3. Complementarity Principle

The ICC operates as a court of last resort, intervening only when national jurisdictions are unwilling or unable to prosecute. In the European assassination cases, several countries have already taken action. Germany prosecuted and convicted the perpetrators of the Mykonos killings and publicly identified Iranian officials as responsible. France, the Netherlands, and other affected countries have also investigated or prosecuted related incidents. When a State Party is actively pursuing justice for crimes committed on its territory, the ICC will generally consider those cases inadmissible. The remaining accountability gap concerns senior officials who remain outside the reach of national courts, especially those in Iran. That is where an ICC referral or a separate international mechanism could still be relevant.

4. Triggers for an ICC Referral

The ICC can gain jurisdiction over a situation involving a non-party state through a referral by the UN Security Council under Article 13(b) of the Rome Statute. This is the mechanism that organizations like Amnesty International are advocating for in relation to the 2022 “Woman, Life, Freedom” crackdown and the January 2026 protest killings inside Iran. These referrals are focused on the broader pattern of state violence within Iran, not specifically on the European assassinations.

The European cases could serve as evidence of an ongoing state policy of targeting civilians for political reasons, but they would probably not, by themselves, provide the primary basis for a Security Council referral. A referral would more likely focus on broader patterns of state violence inside Iran, where the scale and systematic character of the alleged crimes are more central to Amnesty International’s appeal. Any such referral would also face significant political obstacles, including the possibility of a veto by Russia or China in the Security Council.

Conclusion

The documented assassinations in Europe could provide the ICC with a territorial basis to examine specific incidents and may contribute to a broader evidentiary picture of a state policy of repression. However, these cases alone are unlikely to satisfy the legal and political requirements for an ICC investigation or a Security Council referral. National prosecutions in Europe remain the most immediate avenue for accountability, while a Security Council referral or UN-mandated mechanism would more likely focus on the wider pattern of crimes committed inside Iran. Together, these pathways offer the most realistic prospects for justice, even though each faces significant legal and political obstacles.

Ultimately, international mandates, criminal investigations, and accountability mechanisms can help expose abuses and pursue justice. But lasting change will also depend on the determination and collective action of the Iranian people, supported by sustained pressure and practical assistance from the international community, to end these atrocities and secure freedom for Iran.