Moving Beyond Treating Cancer with a Band-Aid: Addressing the Domestic Hindrances to Eradicating Child Sex Tourism & Child Prostitution in Cambodia
Timothy R. Spaulding†
Thirty years ago, in a span of four years, the Khmer Rouge murdered more than one million of its own people. A generation was lost and a country was crippled. Teachers, doctors, anyone who was educated, worked for the government, or fell prey to a soldier’s whim was murdered.
Today, the impact of the Khmer Rouge is still felt as the country struggles to heal the wounds of the past and look to tomorrow. One would think that this type of systemic destruction of a generation would not take hold again; that a people would stand up in outrage; that a government would legislate and quell the slightest hint of similar patterns in its society. However, despite the legislative efforts of the Cambodian government to outlaw Child Sex Tourism (“CST”) and Child Prostitution, and the international outcry against such heinous acts, the destruction continues as a generation of young Cambodian girls is being systematically destroyed encounter-by-encounter, in the name of lust and pleasure for just a few dollars.
Lest anyone be unaware, CST and Child Prostitution are rampant in Cambodia, and the horrors inflicted upon young Cambodian girls are becoming more repugnant with each passing day. In response to a fear of contracting AIDS, the sex industry has responded with younger girls and sought to suppress these fears by offering virgins. These girls can be sold for upwards of $500 USD. For this sum, the customer will keep the girl imprisoned in his hotel room for about a week, raping and molesting her again and again. Once a girl’s virginity has been stolen her value to the brothel owner drops drastically where at first she brought a high price, now fetching only a few dollars per customer. However, the worst atrocity is not subjecting virgin children to rape for money, but in response to the demand for virgins, many girls are sewn up after having sex with a customer and sold to another customer, again as a “virgin.” This second customer cannot tell the difference and is satisfied that she is a virgin due to the girl’s bleeding and pain. In the same way the Khmer Rouge ravaged a generation of Cambodians, prostitution is destroying young Cambodian women today. Recovery is a difficult road, as many have no place to go once rescued from prostitution. Sadly, many often end up back in prostitution due to social stigmas and poverty.
The last five years have seen a large public outcry against CST & Child Prostitution. In response, many countries have passed legislation and enacted laws to combat CST.  Most often, these laws give the country extra-territorial jurisdiction to prosecute its citizens for engaging in CST abroad. While these laws are a step in the right direction, they do not address the heart of the problem. Australia’s initiatives are listed by the U.S. State Department among “international best practices” despite only having one prosecution under its extra-territorial laws in 2005. Originally, Canada’s CST laws only granted extra-territorial jurisdiction if the country where the act occurred requested intervention. In 2002 that requirement was dropped; however three years passed before the first Canadian sex tourist was convicted under anti-CST laws.
In 2003 the U.S. passed the PROTECT ACT, which streamlined and strengthened the government’s ability to prosecute U.S. citizens who travel abroad to have sex with children. Additionally, the U.S. government has been combating CST by funding a public awareness campaign by World Vision. While these efforts and those of other countries are to be commended, they are largely passive and only marginally successful as they do not address the domestic issues that make it possible for pedophiles to commit these acts in the first place.
Despite these and other international efforts, the number of rape victims in Cambodia has been on the rise, with most victims being under the age of eighteen. In 2002 and 2003, almost 80% of the victims identified by LICADHO were under the age of eighteen with close to 10% being age five and under. If ground is to be gained in the fight against Child Prostitution, the international community must put pressure on countries like Cambodia to reform the domestic problems that foster Child Prostitution. Until this is done, CST and Child Prostitution will continue to destroy the lives of countless children not only in Cambodia but worldwide. By passing laws addressing CST and ignoring the internal mechanisms that allow this practice to fester, the international community is effectively treating cancer with a band-aid.
This article discusses, three central issues hindering the fight against CST and Child Prostitution in Cambodia. Section one discusses the primary stumbling block to eradicating CST and Child Prostitution in Cambodia. It sets out the history and current pervasiveness of corruption in the government, particularly in the judiciary and law enforcement. Section two focuses on the obstacle of poverty and discusses how it can lead to a life of prostitution and involvement in the sex industry, even for the very young. Section three addresses certain cultural paradigms in Cambodia that adversely affect the fight against CST and Child Prostitution. It discusses the traditional view of women and men as well as the impact Theravada Buddhism has on the public perception of justice. While international efforts to combat CST and Child Prostitution are a start, the only way to successfully combat and strike a crippling blow to the child sex industry in Cambodia is through domestic reformation in the areas of government corruption, poverty, and cultural paradigms.
While primarily seen as an impediment to the economic and business prospects of Cambodia, corruption is one of the largest problems facing the fight against CST and Child Prostitution. The hallmark of any democracy is the rule of law. In Cambodia, however, law has taken a back seat to corruption. The phrase lex rex accurately describes the key ingredient in a democracy where government is strong enough to protect its citizens but also restrained and balanced so as not to trample the rights of the citizenry. While on the surface Cambodia appears to be a democracy, the key ingredient is not lex rex but opulens lex, or “wealth over law.” Seemingly the key to success in Cambodia is obtaining a position of power and then exploiting that position by extorting citizens and requiring “fees” and protection money. In many nations even the slightest hint of impropriety all but destroys any chance of maintaining a position of power. However the opposite is true in Cambodia; exacting bribes and extorting money out of the citizenry is seen as a “right” for those in positions of power. While a veneer of honesty and legitimacy is touted to both the outside world and the Cambodian people, beneath the surface a hierarchy of corruption serves as the backbone of government. Power is tightly held among a few and measured out to those who pledge support, finances, and loyalty.
Cambodia’s institutionalized corruption has its roots in the country’s recent history. The transitions from Maoist authoritarian rule to democracy, from war to peace, and from economic isolation to a place in the global economy led to intricate and cryptic state-society relationships, poor fiscal accountability, and a powerful elite. During these transitions much of Cambodia’s wealth passed to a select few during times of spontaneous privatization. Further amplifying and exacerbating the situation is the tight control the seated government has held over the country during the fourteen years since the Paris Peace Agreement. In theory, Cambodia emerged from the Peace Agreement a democratic nation, but Hun Sen’s government has continued to maintain autocratic control over the country by exerting power over all aspects of the government, and neither parliament nor the judiciary acts as a counter-balance to the executive power. Despite Constitutional mandate, the government has yet to develop neutral government institutions with any substantive power, check on the executive, or means to enforce human rights violations.
Few areas of citizen interaction with government appear to be free from corruption; no one is immune. Corruption has become such an integral part of life that it is normal and accepted in certain situations. Children routinely pay bribes to their teachers for good grades; without bribes their grades are poor, regardless of actual student performance. However, this is expected in Cambodian culture – a teacher cannot live on a meager and poor government salary. Likewise, extraction and expectation of bribes are built into most government jobs in the same way restaurant wages account for tips from patrons, as few government officials are expected to, or actually do, live off of their official salary. Furthermore, simple tasks such as registering a birth, a death or a marriage require “fees.” Accessing supposed public records, even when required by international treaty or contract with donor countries, often require bribes due to what appear to be the purposeful inefficiency of the government. Even when not directly required, inefficient and opaque procedures create confusion and impatience, which ultimately lead to bribes and “special fees” intended to speed up the laborious and drawn out process of accessing information.
While all government corruption hinders the fight against Child Prostitution in some way, the most lasting and as damaging corruption is found in the judiciary and law enforcement. Like other positions in government, judgeships are routinely purchased. The Cambodian Constitution calls for senior judges to be selected by a supreme council headed by the King, however the reality is that this Supreme Council of Magistrates has little power, as Judgeships are largely open to the highest bidder. Routinely, Cambodia’s judiciary fails to deliver justice to countless victims. When the government is neutral on the outcome of a case, verdicts go to the highest bidder, which predictably leave the poor without justice. Additionally, despite constitutional law to the contrary, judges, prosecutors and policemen alike often push for illegal, out-of-court settlements in cases of rape and sexual assault. When this occurs, victims are given a few dollars but no true justice. No one is punished; no one is prevented from victimizing another child. By even suggesting an out of court settlement, the government treats victims of rape or sexual abuse as sex workers, coercing them to take money in exchange for the atrocities done to them. While there are instances of justice being carried out in rape and sexual abuse cases, more often cases are not prosecuted, particularly where money is involved.
When a verdict of not guilty in a case of rape or murder can be purchased for a few dollars despite overwhelming evidence to the contrary, public perception of both the severity of the crime and the value of human life is diminished. Rape becomes equivalent to the cost of a moto or a few nights stay in a hotel. Additionally, by equating rape victims to sex workers, the government creates a tiered view of human rights. Over time the public view of sex crimes and prostitution becomes one of tolerance towards prostitution and forced sex, whether with an adult or a child.
Public and social acceptance of prostitution and the ability to bribe officials has lead to the creation of safe-havens for CST and Child Prostitution. In Sihanoukville, open acts of molestation go unpunished because officials either ignore the acts or persons with a conscience cannot find any police to whom they can report the crime. While it is easy to say that the government has a difficult time policing Child Prostitution due to small numbers and low salaries among the police force, the fact remains that profit often comes before justice. Regardless of the size of the police force, officers are often paid to look the other way. Hostel owners say that if they enforce the prohibitions against CST and Child Prostitution they will lose businesss – there is always another hostel that will not object. Whether in the government or in private business, corruption has become an accepted and essential part of life. Those who eschew corruption are punished; morals stand for nothing.
While the quantitative cost of corruption is generally measured transactionally by looking at which transactions take place, those that do not, and those that could, these formulae do not take into account ramifications that are less friendly to objective analysis and numeric sums. Chief among these less quantifiable consequences is the toll on human life, especially children. Corruption provides ripe soil for the proliferation of Child Prostitution. In societies where anything can be bought for a negligible cost, the underbelly of humanity tends to congregate. As a result, countless children are inflicted with AIDS at a young age due to their enslavement in the sex trade. Abused by their captors and unwanted by their families, these young victims are left unprotected with no hope of rescue.
Perhaps the single greatest contributing factor to Cambodia’s poverty is the four-year period from 1975-1979 during which the Khmer Rouge slaughtered over one million Cambodians. The goal of the Khmer Rouge was to make Cambodia a rural, agrarian society, which led to the extermination of both educated and urban Cambodians. When the Khmer Rouge was toppled, Cambodia had been effectively wiped clean of any formally educated citizens. When the country began to rebuild, jobs that typically had specific educational requirements, required little more than a warm body and a possible bribe. Since 1979 Cambodia has continued to see strife and war as factions fight for control, the Khmer Rouge attempted resurgence, and as the authoritarian government continues to control the country. As a result, Cambodia is still trying to recover from the loss of an educated population. Today, most Cambodians lack access to basic healthcare, education, potable water, electricity, and serviceable roads. Additionally, much of Cambodia’s valuable agricultural land is rendered useless by landmines; yet another scourge on the country left by the Khmer Rouge.
Further compounding the situation is the issue of land grabs and land claims. When the Khmer Rouge came to power all titles to land were abolished and all land was owned by the state. After the Vietnamese victory over the Khmer Rouge in 1979, land was free for the taking and squatter’s rights prevailed as people scrambled for a place to call their own. Some returned to land they owned before the Khmer Rouge came to power, and others found new land and stayed for decades eventually securing rights to the land, while still others never found a permanent place to stay and live nomadic lives. Today, only 14% of Cambodia’s land is registered, and much of the registered land was done so fraudulently. Unfortunately due to the way power is centralized, Cambodians have no way to assert their land rights and claims without traveling to Phnom Penh and making a direct appeal to Hun Sen himself.
While urban Cambodia has no immunity to poverty, the incidence of poverty in rural areas is four times higher. Additionally, three-fourths of Cambodia’s poor are found in households where the primary source of income is agricultural. This proclivity towards poverty in rural Cambodia has lead people to make decisions based on necessity and not on the ramifications of their decisions. A simple loan for $100 with a repayment period of twelve months can end up costing the borrower 140% of the value of the loan. Commonly when a loan cannot be paid off or some other financial strain besets a family, parents are often left with no other choice than to send their children to the city to beg. Routinely, children will go to Phnom Penh for a few weeks at a time to make money begging. Other times, parents buy into the sweet words and immediate cash offered by recruiters, unwittingly selling their children into slavery, as many of these children are trafficked into prostitution at the hands of the recruiters. These recruiters play on the hopes of parents for a better life for their children, promising education, job skills, and work. They go to rural villages making promises and offering cash advances on wages. After leaving their homes, many girls are sold to brothels where they incur even more debt than they are required to pay off before they can go home. Combined with the cost of living, many prostitutes are unable to pay off their indebtedness for many years, sometimes never as with each transfer to a new brothel they incur more debt. However, not all girls involved in prostitution are tricked into it, others end up in the mire of prostitution after fleeing poverty or abuse at home. Further still, 40% of women and girls involved in prostitution say they were sold directly to a brothel by either their parents or a relative.
In the early 1990′s, UNTAC pumped millions of dollars into the Cambodian economy, much of which was siphoned off through corruption, yet it appears that the economic booster shot did not have any long-term effect of alleviating poverty. Instead, the financial injections caused the sex industry to flourish as it sought to meet the desires of the UN personnel and the demand from Khmer with newfound prosperity.
The fight against poverty is integral in the fight against CST and Child Prostitution. People in extreme poverty are often at the mercy of those looking to exploit. While the high incidence of poverty in Cambodia is not responsible for CST and Child Prostitution, it is without a doubt an exacerbating factor. If adequate protection of property rights existed, land grabs by the elite were reversed, and economic assistance directed towards bolstering the agricultural industry were infused into the economy, rural Cambodians would have a greater chance of providing for their families without the need to send children off to work in the cities, or worse yet, to sell them to traffickers.
To truly understand the exploitation of girls in Cambodia, one must understand the traditional and cultural view towards women, and the role of Buddhism in shaping Cambodian culture. The role of females in Cambodia has always been a strong one. Since ancient times when the Angkor kingdom was a flourishing center of trade in Asia, women have held important leadership roles in almost all aspects of life. The Aspara, celestial goddesses representing water and purity, which are carved throughout the temples of Angkor, have always been the embodiment of a true Cambodian woman. Additionally, Khmer literature portrays Cambodian women as industrious, virtuous, well mannered, respectful of their husbands, and above all, silent in the presence of men.
A woman’s identity centers around marriage, serving her husband and caring for her children, and her honor and reputation are largely based upon chastity before marriage and fidelity thereafter. While the traditional role of women is one of service to her family, she also wields a considerable amount of power. A woman’s reputation directly affects the reputation of the men in her life: her husband, sons, and father. If she embodies the traditional values, pleases her husband, raises her children well, and is industrious, the status of the men in her life increases. However, if she deviates in any way, the men in her life are degraded and their social standing decreases. So despite commanding great control over the social status of their families, Cambodian women are also held prisoner to the exacting standards of tradition and culture. Because Cambodian society holds strongly to the traditional and cultural roles of women, there is little room for divergence. In Cambodia it is said, “to be an improper woman is to cease to be Khmer, [and] to cease to be Khmer is to cease to be fully human.”
However, Cambodia presents a contradiction in many ways. Despite this great power in society women are also regarded as property, living only to serve the men in their lives. The biggest problem is not so much that men hold this view, but that women do. The combination of a Khmer woman’s traditional role and the belief that women hold value as property has lead to the cultural acceptance and government tolerance of prostitution. While premarital or extramarital sex for a woman is forbidden and a permanent stain on her reputation, the same does not hold true for men. Cambodian custom and tradition holds that men have uncontrollable sexual appetites and as such, men are free to express and feed these desires in any way they see fit, regardless of their marital status. The natural outlet of these sexual urges in a noncommittal, emotionally detached relationship is prostitution. Hence, if a man has the money, sex with prostitutes has been and continues to be a culturally and socially accepted activity. These views are reflected in an old Khmer saying: “a Cambodian girl [is like] white cotton wool. A boy is compared to a gem… when white is muddied, it can never be washed to the purity and cleanness it once had. Gems, on the other hand, can be cleaned to shine brighter.”
As such, these views toward men and women are in large part responsible for the rampant sex industry and violent crimes against women. All too often sex crimes against women and children are ignored by the justice system, illegally settled out of court, or not pursued because of women’s role in society and the cultural acceptance of the sex industry. Despite the realities of a life of prostitution, there is a readily available flow of girls due to combinations of poverty, greed, and the keen sense of duty and obligation felt towards families. Despite being sold into prostitution by a parent or relative, many girls still feel a strong sense of tradition and feel a responsibility to be a dutiful and respectful daughter regardless of how they have been treated. Feeling compassion for their family’s plight, girls often see themselves in a position to help their families survive. Whether a coping mechanism or culturally based, many girls view their work in brothels as pulling their weight in their family; allowing younger siblings to go to school, helping their families purchase a plot of land, or paying for medicine for a sick family member. However, sometimes these feelings are betrayed when families take additional advances on the daughter’s wages without her knowledge. Where a girl may have had to prostitute herself for three months to repay the original advance, she may end up staying indefinitely depending upon the advances taken on her earnings, costs incurred by the brothel, and her living costs. Additionally, once a woman has been raped or prostituted, she is often ostracized by her family and village. With nowhere to go, many women end up back in prostitution facing few other choices. Remarkably, despite being shunned many prostitutes report using a portion of their wages to support the very family that spurned them.
The sad fact remains that the strong cultural values held by many girls and the cultural and societal expectations placed upon them by society have aided in the exploitation of numerous Cambodian girls. One of the more recent outgrowths of the cultural view towards women is bauk. Bauk, or gang rape, is a sort of sport among young Khmer men looking for a night of fun and entertainment. Often targeting prostitutes as there is less chance for legal recourse, groups of young men, generally in their 20′s-30′s, prowl the night looking for a woman to rape; all in the name of fun and bonding with their friends.  The prevalence of this horrific sport continues to grow, as 34% of men in Phnom Penh know someone who has been involved in bauk. Among university students that number skyrockets to 60%.
Furthermore, while possessing numerous qualities, the predominance of Theraveda Buddhism in Cambodia offers little help against injustice in this life, but looks to the next life for relief. The Khmer social system emphasizes, “serenity, acceptance of injustice, conformity to a higher authority and Buddhist principles of accepting suffering as the expected order of life.” The belief in Karma and predestination based on behavior in past lives causes people to believe that if they or someone else is suffering injustice they must deserve it based upon some wrong committed in a past life. As such, many girls believe that providing for their families through prostitution will help them in their next life.
Despite the passage of numerous laws against rape, sexual assault, and the prostitution of minors, the lack of enforcement of these laws does not rile many Cambodians because of their Buddhist beliefs. Furthermore, until the status of women in Cambodia changes and men and women are treated equally in all aspects of life, women and girls will continue to be victims of prostitution without a voice for recourse or a society that views their treatment as wrong.
Similar to Juvenal’s age-old conundrum, “Who will guard the guards?” the question in Cambodia is this: How do you reform a system when the system is a requisite component of the reform; how do you drive out corruption when the mechanism used for such a task is itself corrupt? The fact remains that there are few answers and none of them easy. While current international efforts to stem the flow of child sex tourists have had some positive results, the root of the problem remains. If CST and Child Prostitution are to be seriously combated in Cambodia, true internal reform must take place. Currently, the Cambodian government has numerous laws against the horrific practices of CST and Child Prostitution yet these practices continue to flourish. The International Community must ensure that Cambodia’s government does not just put a new skin on the same old government and call it reformed. Ultimately, the success of the struggle against CST and Child Prostitution is directly linked to the enforcement of law, the development of a unified legal framework, streamlined administrative procedures, accurate record keeping, and a capable body of government officials.
Achieving this goal is no small feat; however, the international community can and must play a role in its facilitation. First, international aid to Cambodia must be conditioned upon steps taken toward reform. While this approach could result in a stripping away of funding that would have adverse consequences on the citizens of Cambodia, it is one of the only ways to attempt to force the government to comply with substantive reform. Without leverage against the government, it has no incentive to change. Additionally, conditioning aid on audits or inspections would provide a monitoring mechanism for ensuring that steps are taken towards reform.
Second, while the problem of corruption in the government still exists, the international community can have a positive impact upon the daily lives Cambodians by limiting its contact with governmental bureaucracy. While direct funding to independent NGOs might be more inefficient than working with a larger organization or a government, it ensures that funding reaches those who need it instead of lining the pockets of corrupt officials. Organizations like PEPY though small in size, are a wonderful avenue for bringing change to rural Cambodia while circumventing the government where aid is engulfed by profiteering officials. PEPY has made great strides toward increasing the opportunities for children to receive education without bribes. Money donated goes to teacher salaries, supplies, and the daily expenses of the PEPY School in Siem Reap province and another recently opened PEPY School in Steung Treng province. Another example of external governmental funding in Cambodia is the U.S. government’s funding of World Vision’s campaign for greater public awareness of Child Prostitution and CST. While the actions of PEPY and World Vision are small steps, they are steps in the right direction.
Third, the international community must focus its aid on projects and not dollars. One of the largest issues facing Cambodia’s agriculture industry is the lack of proper irrigation. Cambodians are largely at the mercy of weather patterns when it comes to the size of their crop, as too much or too little rain results in under production, which in turn causes people to take desperate measures to feed their families even if that means sacrificing a child to prostitution. By providing projects aimed at modern irrigation, roads, and other aid that assists with wealth-creation, long-term and lasting investments will be made in Cambodia.
Despite mixed results with international efforts in Cambodia in the past, something must be done. Further research is vitally needed to determine how the international community can effectively “force” reform in Cambodia. Despite the checkered track-record of forcing behavior upon a government that does not itself desire change, and the fact that few in a position of authoritarian rule give up their power easily, the challenge must be undertaken. The international community must now move beyond legislating in the home countries of child sex tourists and attack the problem where it festers – in countries that tolerate and foster CST and Child Prostitution. It is not enough to scold and chain the dog up; the rotten, stinking carcass on the road that it loves to roll in must be removed lest other dogs be lured by its stench. Currently, the international community is deeply concerned with the proliferation of nuclear weapons, stability in the Middle East, and peace between Israel and Palestine, and so it should be. However, the international community must take an equally vigilant stance against CST and Child Prostitution; it cannot and must not tolerate the enslavement of children in the sex trade. Without a rising up from the international community and a call for reform, the prospects of change, justice, and hope are dim. Without reform the future of Cambodia will continue to erode encounter-by-encounter, day-by-day, child-by-child.
† J.D., Regent University School of Law, 12/2007; B.S., Roberts Wesleyan College, 2004. Associate Attorney, Glasser and Glasser, P.L.C., Norfolk, Virginia. I would like to thank my wife for her ever-present encouragement, for believing in me, and for sharing the same passion and desire to bring freedom to the captives and hope to the hopeless. Sola Gloria Deo.
 Karen j. Coates, Cambodia Now: Life in the Wake of War 15 (McFarland & Co. 2005).
 Coates, supra note 1, at 144.
 Wendy Freed, From Duty to Despair: Brothel Prostitution in Cambodia, in Prostitution, Trafficking, and Traumatic Stress 133, 135 (Melissa Farley, ed. 2003).
 Stop the Traffick, supra note 3.
 See Freed, supra note 4, at 145.
 U.S. Dep’t of State, Trafficking in Persons Report, 24 (June 2006), http://www.state.gov/documents/organization/66086.pdf [hereinafter Trafficking].
 Id. at 34.
 David Thompson, Child Sex Tourism Legislation in Canada, http://www.beyondborders.org/Publications/Fact%20Sheet%20-%20CST3.pdf (last visited Dec. 21, 2006).
 Trafficking, supra note 9, at 24; Coates, supra note 1, at 189.
 Trafficking, supra note 9, at 24. With funding from the U.S. Department of State and the U.S. Department of Health and Human Services, World Vision launched a massive targeted public awareness campaign by placing deterrence ads in newspapers, airports, television, billboards and street signs overseas, hotels, airline in-flight videos, taxis, and the internet in a effort to discourage child sex tourists at each step of their journey. Due to the success of this campaign in Cambodia, Thailand, Costa Rica, and the United States, World Vision recently received grant money to expand the campaign to Mexico and Brazil. World Vision, Slavery in the 21st Century, http://www.worldvision.org/get_involved.nsf/child/globalissues_stp?Open&lid=CSTP&lid=main (last visited Jan. 5, 2007).
 LICADHO, Rape and Indecent Assaults Cases, And the Cambodian Justice System, at 5 (Mar. 2004), http://www.asiafoundation.org/pdf/CB_TIPreview.pdf#search=%22COSECAM%20frederic%22 [hereinafter, Rape and Indecent Assault].
Amy Kazmin, World Bank Warns Cambodia on Corruption, Financial Times, Feb. 11, 2005, http://www.ft.com/cms/s/3acce230-7c34-11d9-8992-00000e2511c8.html (last visited Feb. 2, 2008).
 See The Federalist No. 47 (James Madison).
 Michael M. Calavan, et al., Cambodian Corruption Assessment, at 2 (2004), http://www.usaid.gov/kh/democracy_and_governance/documents/Cambodian_Corruption_Assessment.pdf#search=%22cambodian%20corruption%20assessment%20usaid%22 (last visited Feb. 2, 2008) [hereinafter Corruption].
 Id. at 3.
 LICADHO, Human Rights in Cambodia: The Façade of Stability, at 1 (May 2006), http://licadho.org/reports/files/8682LICADHOFacadeDemocracyReport2005-06.pdf. [hereinafter Façade]; See also Corruption, supra note 21, at 11.
 Corruption, supra note 21, at 5.
 See Id. at 2.
 World Bank, Cambodia at the Crossroads: Strengthening Accountability to Reduce Poverty, at 4 (Nov. 2004), http://siteresources.worldbank.org/INTCAMBODIA/Resources/Cover-TOC.pdf (last visited February 18, 2008) [hereinafter World Bank].
 Corruption, supra note 21, at 2.
 See Id. The Paris Peace agreement, the United Nations was tasked with organizing and conducting free and democratic elections, coordinating the repatriation of Cambodian refugees, facilitating a rehabilitation of Cambodia’s economy, supervising the withdrawal of foreign forces, the cease fire and the demobilization of a minimum of 70 % of the faction forces and coordinating with the International Committee of the Red Cross the release of prisoners of war. While the Khmer Rouge initially signed the agreement, they refused to demobilize troops. As the elections grew closer the Khmer Rouge began attacking UN forces, ethnic Vietnamese citizens, and The State of Cambodia (SOC). As a result, the SOC remained fully armed. While the voter turn out in the election was high, the results were mixed. No party won a two-thirds majority required for governance, which lead other parties to protest the election. In the end, as part of settling the dispute, the country ended up with two prime ministers among other things. Judy Ledgerwood, CAMBODIAN RECENT HISTORY AND CONTEMPORARY SOCIETY: AN INTRODUCTORY COURSE, CAMBODIA SINCE APRIL 1975: UNTAC, http://www.seasite.niu.edu/khmer/Ledgerwood/Part5.htm (last visited Jan. 5, 2007).
 See Corruption, supra note 21, at 2.
 Id. at 7.
 Façade, supra note 23, at 14.
 See Corruption, supra note 21, at 3, 5.
 Corruption in Cambodia’s education system sparks concern (2004), http://findarticles.com/p/articles/mi_m0WDP/is_2004_May_10/ai_n6264069 (last visited February 18, 2008).
 See generally Corruption, supra note 21; see generally Façade, Supra note 23.
 Corruption, supra note 21, at 4.
 Id. at 8.
 Id. at 6.
 Id. at 7.
 Façade, supra note 23, at 1.
 Corruption, supra note 21, at 6
 Rape and Indecent Assault, supra note 17, at 15.
 Id. at 1.
 Façade, supra note 23, at 15.
 See id.
 See Corruption, supra note 21, at 5.
 Id. at 12-13.
 Nicholas M. Prescott & Menno Pradhan, A Poverty Profile of Cambodia, v (The International Bank for Reconstruction and Development, ed., The World Bank, 1997).
 See Judy Ledgerwood, Cambodian Recent History and Contemporary Society: An Introductory Course, Cambodia Since April 1975: Democratic Kampuchea (1975-1979), at http://www.seasite.niu.edu/khmer/Ledgerwood/Part2.htm (last visited Dec. 21, 2006).
 See Prescott, supra note 54.
 See generally Corruption, supra note 21.
 See Prescott, supra note 54.
 Coates, supra note 1, at 152.
 Id. at 153.
 Id. at 152.
 Corruption, supra note 21, at 6.
 See Prescott, supra note 54, at ix.
 Id. at x.
 Coates, supra note 1, at 158.
 Id. at 195.
 Freed, supra note 4, at 135.
 Id. at 134.
 Id. at 134-135.
 Id. at 135.
 Freed, supra note 4, at 134.
 Judy Ledgerwood, Contemporary Cambodian Society, http://www.seasite.niu.edu/khmer/Ledgerwood/cs1.htm (last visited Dec. 21, 2006).
 Freed, supra note 4, at 135.
 Id; Coates, supra note 1, at 165, 67.
 Freed, supra note 4, at 135.
 Chey, supra note 86.
 Coates, supra note 1, at 166.
 Id. at 165-67.
 Freed, supra note 4, at 135.
 Chey, supra note 86.
 See Coates, supra note 1, at 165.
 Rape and Indecent Assault, supra note 17, at 24.
 Freed, supra note 4, at 143.
 Id. at 141.
 Id. at 142.
 Freed, supra note 4, at 142.
 Id. at 138.
 Id. at 142.
 Coates, supra note 1, at 169.
 Id. at 148.
 Coates, supra note 1, at 148.
 Freed, supra note 4, at 143.
 See Rape and Indecent Assault, supra note 17.
 Corruption, supra note 21, at 16.
 Trafficking, supra note 9, at 24.
 Prime Minister Samdech Hun Sen, Address at World Day for Water, available at http://www.mfaic.gov.kh/bulletindetail.php?contentid=1199 (March 22, 2001).