In February 2006, a senior Bush administration official sat down and wrote something extraordinary: a TOP SECRET memorandum warning that the CIA’s “enhanced interrogation” program was a breach of U.S. war crimes law. The author was Philip Zelikow, counselor to Secretary of State Condoleezza Rice and a respected historian who would later lead the 9/11 Commission.
His audience: the National Security Council’s Principals Committeeโthe most powerful national security body in the U.S. government, including the Vice President, Secretary of Defense, CIA Director, and Attorney General.
His conclusion: The CIA’s physical abuse of detainees was illegal. Period.
The Bush administration’s response? They rejected his legal analysisโand ordered every copy of the memo destroyed.
But one draft survived. Hidden in State Department files, it was declassified in 2012. What it reveals is a story of conscience, cover-up, and the bureaucratic archaeology of crimes.
The Legal Warning That Couldn’t Be Allowed to Exist
Zelikow’s February 15, 2006 memo arrived at a critical moment. The CIA’s torture programโwaterboarding, sleep deprivation, stress positions, and “walling” (slamming detainees against walls)โwas under internal strain. The 2005 Detainee Treatment Act had just passed, and the Supreme Court’s Hamdan v. Rumsfeld decision had thrown the legal basis for military commissions into question.
Zelikow, a former prosecutor and law professor, saw what others in the administration refused to acknowledge: The CIA’s methods weren’t just morally wrongโthey were legally indefensible.
His memo argued that:
The Geneva Conventions’ Common Article 3โwhich prohibits “cruel treatment and torture” and “outrages upon personal dignity”โapplied to all CIA detainees
The War Crimes Act of 1996 made violations of Common Article 3 a federal felony punishable by up to life imprisonment
The CIA’s “enhanced interrogation techniques” likely constituted “cruel treatment” under international law
No presidential authorization could legalize war crimes
According to multiple reports, the Bush White Houseโparticularly Vice President Dick Cheney’s office and the CIAโreacted to Zelikow’s memo with fury. Here was a senior administration official, cleared at the highest levels, declaring that the President’s signature interrogation program made everyone involved criminally liable.
The response wasn’t debate. It wasn’t legal review. It was erasure.
The administration ordered all copies of Zelikow’s memo destroyed. Officials were directed to retrieve and eliminate every version from State Department, CIA, and White House files. The goal: to ensure no prosecutor, no court, no congressional investigator could ever prove that the White House had been explicitly warned its torture program was illegal.
One copy survived. A draft remained in State Department archives, overlooked in the purge. It sat there for six years until declassification in 2012, finally entering the public record for the world to see.
The destruction order is the smoking gun. In criminal law, consciousness of guiltโtaking steps to hide evidenceโdemonstrates awareness of wrongdoing. Ordering the destruction of a legal memo warning of war crimes isn’t “policy disagreement.” It’s cover-up of crimes.
The Torture Architects Knew
Zelikow sent his memo to the Principals Committeeโmeaning Cheney, Rumsfeld, CIA Director Porter Goss, Attorney General Alberto Gonzales, and Condoleezza Rice all received explicit warning that the CIA program violated U.S. war crimes law. They chose to continue the program and destroy the warning.
Obama’s Failure to Prosecute
When the Zelikow memo was declassified in 2012, it provided prima facie evidence that senior Bush officials knowingly authorized torture despite legal warnings. The Obama administration, which had promised to “look forward, not backward,” declined to prosecute. The memo became a historical document rather than evidence in a criminal case.
Precedent for Impunity
The Zelikow memo’s suppression established a template: Classify legal warnings. Destroy inconvenient documents. Declare “national security.” This patternโseen in the CIA torture tapes destruction (2005), the NSA warrantless surveillance cover-ups, and the Abu Ghraib accountability failuresโhas eroded the rule of law in national security policy.
While the full text remains partially redacted, Zelikow’s core argument was devastating in its simplicity:
The Geneva Conventions apply. The War Crimes Act applies. The CIA’s methods violate both. Therefore, U.S. officials are committing federal felonies.
Zelikow specifically addressed the administration’s favorite legal escape hatchโthe claim that “enhanced interrogation” wasn’t torture because it didn’t cause “severe physical or mental pain” lasting months or years. He countered that Common Article 3’s prohibition on “cruel treatment” had a lower threshold and clearly covered waterboarding, stress positions, and sleep deprivation.
He also demolished the “necessity” defenseโthe argument that torture was justified to prevent terrorist attacks. Under the War Crimes Act, Zelikow noted, necessity is no defense for violations of Common Article 3.
The Man Who Wrote It
Philip Zelikow is no radical. He’s a Republican, a former Navy officer, a Harvard Law graduate, and the executive director of the 9/11 Commissionโhardly a profile in anti-government activism. His memo was the product of a conservative national security professional doing his job: telling the truth about the law.
After the memo’s existence became public, Zelikow confirmed its contents and described the administration’s reaction. He noted that his legal analysis was “not welcome” and that senior officials made clear that only the Office of Legal Counsel’s pro-torture memosโauthored by John Yoo and Jay Bybeeโwere to be considered valid.
The Yoo-Bybee memos, later withdrawn by the Obama Justice Department as legally defective, had authorized torture by redefining it out of existence. Zelikow’s memo, which accurately interpreted the law, was suppressed because it was correct.
The Bush administration’s torture program ended in 2009. The Zelikow memo was declassified in 2012. No one has been prosecuted for the torture itself, or for the destruction of evidence warning about it.
But the memo endures. It sits in the public record, accessible to anyone who seeks it, proving that someone in power knew and tried to stop it. It proves that the destruction order was an admission of guilt. And it proves that the legal warnings were accurateโthe CIA’s interrogation program was a war crime under U.S. law.
The question remains: If a TOP SECRET memo warning of war crimes can be ordered destroyed, and no one is held accountable, what else has been burned?
This article is based on declassified government documents and investigative reporting. The allegations contained in the Zelikow memo were contested by the Bush administration at the time.
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Authorities held a secret meeting last week to discuss contingency plans in the event of Pyongyang launching a deadly missile at the US islands.
North Korean dictator Kim Jong-un has threatened to drop a hydrogen bomb over the Pacific Ocean amid fears Pyongyang has developed a nuclear missile capable of reaching Hawaii.
A document shared at the private talks, and obtained by local paper Honolulu Civil Beat, featured chapter headings such as “Enhance missile launch notification process between U.S. Pacific Command and the State Warning Point.โ
The US state, in the middle of the Pacific Ocean, will also begin testing a warning siren system in November, giving residents between 12 and 15 minutes to take refuge.
Resident wil then be advised to stay indoors for 72 hours after an attack.
State representative Gene Ward told the Washington Post: “Now itโs time to take it seriously.”
He said the plan was “not to be an alarmist but to be informing people.โ
Mr Ward said the meeting last week was held in private because officials did not want to worry residents.
He also said talk of bunkers and fallout shelters was “probably more surreal for younger generations” with no experience of a realistic nuclear threat.
But Hawaiians are apparently taking the news in their stride, and carrying on with their daily lives.
Residents are used to disaster warnings, living in an area prone to hurricanes and tsunamis.
Survival guidelines for those scenarios are similar to the ones being issued for a nuclear attack – instead of seven days worth of food, water and medical supplies, residents are advised to double it.
The document distrubted at last week’s meeting suggested that around 90 per cent of the Hawaiian population would survive a nuclear attack by North Korea, based on the estimated yield of North Korea’s missile capability, which suggests an explosion less than eight miles in diameter.
It comes as America’s top military officer said despite an escalation in rhetoric between the US and North Korea, he had not seen Pyongyang change it’s military posture.
Marine General Joseph Dunford, chairman of the military’s Joint Chiefs of Staff, told a Senate Armed Services Committee hearing for his reappointment: “While the political space is clearly very charged right now, we haven’t seen a change in the posture of North Korean forces and we watch that very closely.
“What we haven’t seen is military activity that would be reflective of the charged political environment.”
North Korea has boosted defences on its east coast, a South Korean lawmaker said on Tuesday, after Pyongyang said US President Donald Trump had declared war and that it would shoot down US bombers flying near the peninsula.
Tensions have escalated since reclusive North Korea conducted its sixth and most powerful nuclear test on Sept. 3. Bellicose rhetoric has reached a new level in recent days with leaders on both sides exchanging threats and insults.
North Korean Foreign Minister Ri Yong Ho said on Monday that Mr Trump’s Twitter comments that leader Kim Jong Un and Ri “won’t be around much longer” if they acted on their threats amounted to a declaration of war and that Pyongyang had the right to take countermeasures.
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Venezuela’s President Nicolas Maduro called on his nation’s military leaders Tuesday to prepare for war against the U.S. days after the Trump administration banned Venezuelan officials from entering the nation.
“We have been shamelessly threatened by the most criminal empire that ever existed and we have the obligation to prepare ourselves to guarantee peace,” said Maduro, who wore a green uniform and a military hat as he spoke with his army top brass during a military exercise involving tanks and missiles. “We need to have rifles, missiles and well-oiled tanks at the ready….to defend every inch of the territory if needs be,” he added.
The Trump administration has taken a hard stance against Maduro’s regime by banning money lending to Venezuela’s government or its state oil company PDVSA, and passing sanctions against Maduro and his top officials.
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Maduro referenced the sanctions during his speech at the military base. As he spoke, Russian military plans flew in the sky as part of the training exercise, Agence France-Presse reported.
“The future of humanity cannot be the world of illegal sanctions, of economic persecution,” Maduro said.
It’s unlikely Maduro has the manpower to stand up to the U.S., which has a much larger military. Maduro has maintained power in Venezuela despite mounting political and economic crises that has seen months of violent, anti-government demonstrations across the South American nation. Defense Minister Vladimir Padrino has backed Maduro during the upheaval, but some critics have begun a whisper campaign suggesting that the military could break away and support a coup against the president, Herbert Garcia, a former senior army general and minister, told Reuters in August. There have been three attempted military coups in Venezuela since 1992.
Russia has defended Maduro in recent months, going so far as to accuse Trump of preparing for an invasion of Caracas. “We are strongly against unilateral sanctions against sovereign states,” Russian Foreign Ministry spokesperson Maria Zakharova said in August. “We will carefully analyze the implications of the sanctions imposed by the United States, and their possible effect on the interests of Russia and Russian businesses. We can already say that they will not affect our willingness to expand and strengthen cooperation with the friendly nation of Venezuela and its people.”
President Donald Trump directed his penchant for insulting world leaders toward Venezuela during a United Nations speech earlier this month. He said Washington could intervene in Venezuela to help its citizens “recover their country”
โWe cannot stand by and watch,โ he said.
Maduro oversaw a disputed election earlier this year to muzzle the elected national assembly by creating “constituent assembly” in its place.
Key operative of Adolf Eichmann. Responsible for deportation of Jews from Austria (47,000), Greece (44,000), France (23,500), and Slovakia (14,000) to Nazi death camps.
Status: Lived in Syria for decades; Syrian refusal to cooperate stymies prosecution efforts; convicted in absentia by France. Alois Brunner is the most important unpunished Nazi war criminal who may still be alive, but the likelihood that he is already decreased increases with each passing year. Born in 1912 and last seen in 2001, the chances of his being alive are relatively slim, but until conclusive evidence of his demise is obtained, he should still be mentioned on any Most Wanted List of Holocaust perpetrators.
B. Dr. Aribert Heim – ?? *
Doctor in Sachsenhausen (1940), Buchenwald (1941) and Mauthausen (1941) concentration camps. Murdered dozens of camp inmates by lethal injection in Mauthausen.
Status: Disappeared in 1962 prior to planned prosecution; wanted in Germany and Austria New evidence revealed in February 2009 suggests that he may have died in Cairo in 1992, but questions regarding these findings and the fact that there is no corpse to examine, raise doubts as to the veracity of this information. During the past year, a court in Baden-Baden, Germany closed the case without forensic confirmation of Heimโs death.
Served as the Commander of the Hungarian police in Kosice (Hungarian-occupied Slovakia) and was in charge of the ghetto of โprivilegedโ Jews; helped organize the deportation to Auschwitz of approximately 15,700 Jews from Kosice and vicinity in spring 1944.
Status: : Convicted in absentia and sentenced to death for torturing Jews and his role in the mass deportation to Auschwitz. Escaped to Canada after World War II, but was stripped of his Canadian citizenship in 1997, and chose to voluntarily leave the country. His whereabouts were unknown until fall 2011 when he was discovered living in Budapest by the Wiesenthal Center in the framework of โOperation: Last Chance.โ On July 17, 2012, Csatary was charged with torture of the Jews in the KosiceGhetto, and was placed under house arrest and had his passport confiscated. Currently under house arrest in Hungary, where he awaits possible prosecution. In late March 2013, a Slovak court commuted his death sentence to life imprisonment to enable Slovakia to seek Csataryโs extradition to stand trial for his crimes in Kosice.
Gerhard Sommer – Germany
Former SS-Untersturmfuehrer in the 16th Panzergrenadier Division Reichsfuehrer-SS; participated in the massacre of 560 civilians in the Italian village of Sant’ Anna di Stazzema.
Status: On June 25, 2005, Sommer was convicted in absentia by a military court in La Spezia, Italy for committing “murder with special cruelty” in Sant’ Anna di Stazzema. Since 2002, he has been under investigation in Germany, but no criminal charges have yet been brought against him.
Vladimir Katriuk – Canada
Served as a platoon commander of the first company of Ukrainian Schutzmannschaft Battalion 118 which carried out the murder of Jews and innocent civilians in various places in Belarus.
Status: Escaped to Canada after World War II but was stripped of his Canadian citizenship in January 1999 after his service as a Nazi collaborator was revealed. In May 2007, the Canadian authorities decided to overturn his denaturalization, a decision confirmed by the Federal Court of Appeal in November 2010. New research by Swedish historian Per Anders Rudling revealed Katriukโs active role in the mass murder of the residents of the village of Khatyn, Belarus and provides a firm basis to overturn the decision not to strip Katriuk of his Canadian citizenship.
Hans (Antanas) Lipschis – Germany
Served in the SSโTotenkopf Sturmbann (Deathโs Head Battalion) from October 1941 until 1945 at theAuschwitz-Birkenau death camp where he participated in the mass murder and persecution of innocent civilians, primarily Jews.
Status: Escaped to the United States after World War II, but was deported by the American Office of Special Investigations to Germany in April 1983. Currently under investigation by the German authorities for his role in the Nazi death camp.
Ivan (John) Kalymon – United States
Served in Nazi-controlled Ukrainian Auxiliary Police in Lvov (then German-occupied Poland, todayUkraine) during the years 1941-1944, during which time he participated in the murder, roundups and deportation of Jews living in the Lvov Ghetto.
Status: On January 31, 2011, Kalymon was ordered deported from the United States to Germany,Ukraine, Poland, or any country willing to admit him, for concealing his wartime service with forces in collaboration with Nazi Germany and his participation violent acts of persecution. No such country has yet been found and he therefore remains in the United States.
Soeren Kam – Germany
Volunteered for SS-Viking Division, where he served as an officer; participated in the murder of Danish anti-Nazi newspaper editor Carl Henrik Clemmensen.
Status: In 1999, Denmark requested the extradition of Kam, which Germany refused due to his German citizenship. A subsequent extradition request was refused in early 2007 on the grounds that Clemmensenโs death was not murder but manslaughter, which was under a statue of limitation. Efforts continue to bring Kam to justice either in Germany or in Denmark.
Algimantas Dailide – Germany
Served in the Vilnius District of the Saugumas(Lithuanian Security Police); arrested Jews and Poles executed by the Nazis and local Lithuanian collaborators.
Status: His American citizenship was revoked in 1997 and he was deported from the United States in 2004 for concealing his wartime activities with the Saugumas. In 2006, he was convicted by a Lithuanian court for arresting 12 Jews trying to escape from the Vilnius Ghetto (and 2 Poles), who were subsequently executed by the Nazis, and was sentenced to five years imprisonment. The judges, however, refused to implement his sentence because he was old and was caring for his ill wife and โdid not pose a danger to society.โ In July 2008, in response to an appeal against the refusal to implement his sentence, Dailde was ruled medically unfit to be punished, without being personally examined by the doctors who provided the expertise.
Mikhail Gorshkow – Estonia
Served as interpreter for the Gestapo in Belarus and is alleged to have participated in the mass murder of Jews in Slutzk.
Status: Fled from the United States to Estonia before he was denaturalized for concealing his wartime service with the Nazis; had been under investigation in Estonia since his arrival several years ago, but in October 2011 the Estonian authorities closed the investigation against Gorshkow, claiming the case was one of โmistaken identity,โ a decision which was severely criticized by the United States, Russia, and the Simon Wiesenthal Center.
Theodor Szehinskyj – United States
Served as an armed SS Deathโs Head guard at the Gross Rosen (Poland), Sachsenhausen (Germany) andWarsaw (Poland) concentration camps where he actively participated in the persecution of civilian prisoners.
Status: Escaped to the United States after World War II, but was stripped of his American citizenship in 2000 by the Office of Special Investigations and was ordered deported in 2003. To this date, no country has been willing to admit him and he therefore remains in the United States.
Helmut Oberlander – Canada
Served in Einsatzkommando 10a (part of Einstazgruppe D) which operated in southern Ukraine andCrimea and is estimated to have murdered more than 23,000 people, mostly Jews.
Status: Escaped to Canada after World War II, but was stripped of his Canadian citizenship in August 2001, after his wartime service with the Nazis was revealed. In May 2004 his citizenship was restored but it was revoked a second time in May 2007, and that decision was overturned by a Federal Court of Appeal in November 2009. The case is currently pending again.
NAMES ON PREVIOUS LISTS:
Karoly (Charles) Zentai
Klass Carel Faber (Died May 2012)
Sรกndor Kรฉpรญrรณ (Died September 2011)
Dr.ย Aribert Heim (Died in 1992; Evidence of Death Uncovered in September 2012)
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Dirty Wars follows investigative reporter Jeremy Scahill, author of the international bestseller “Blackwater,” into the heart of America’s covert wars, from Afghanistan to Yemen, Somalia and beyond.
Part political thriller and part detective story, Dirty Wars is a global investigation of the secretive and powerful Joint Special Operations Command (JSOC).
In this excerpt, Scahill travels with a self-proclaimed general who was once an enemy of the US but is now on the Americans’ payroll.
๐ BERND PULCH ARCHIVE | SECURE MIRROR 