By The Children's Commission for England...

“I think the Government should do more about protecting children on the internet. Of course, it is very hard but just educating about the dangers of the internet is not enough” – Girl, 17. A year has passed since the Online Safety Act 2023 became law. This Act, a landmark piece of legislation, was welcomed by the Children’s Commissioner, following her extensive campaigning, as an important step towards a new era of the online world: one that presented an opportunity for children to learn, play and develop there safely. One year on, the legislation has yet to be implemented and important decisions regarding what those regulations will look like remain unclear. This report illustrates the extent to which children are still experiencing harm online. It sets the Children’s Commissioner’s expectations for the future of online safety policy making, and bolder steps towards robustly protecting children online. This report draws on the responses of 253,000 children and adults to The Big Ambition: a large-scale consultation of children in England carried out between September 2023 and January 2024. 2 The survey asked a broad set of questions about their lives, and in response, children shared their views on what they think needs to change to make their lives better. One of the areas they wanted action on was online safety. Children told the Children’s Commissioner’s Office that some children are more vulnerable to online harms than others, and that a variety of content and non-content factors cause them harm online. They also shared their views on who should take responsibility and make the online world safer for them. This report sets out what they said:

London: The Children's Commissioner for England, 2024. 80p.

By Charles C. Lanfear, Ross L. Matsueda, and Lindsey R. Beach

An important criminological controversy concerns the proper causal relationships between disorder, informal social control, and crime. The broken windows thesis posits that neighborhood disorder increases crime directly and indirectly by undermining neighborhood informal social control. Theories of collective efficacy argue that the association between neighborhood disorder and crime is spurious because of the confounding variable informal social control. We review the recent empirical research on this question, which uses disparate methods, including field experiments and different models for observational data. To evaluate the causal claims made in these studies, we use a potential outcomes framework of causality. We conclude that, although there is some evidence for both broken windows and informal control theories, there is little consensus in the present research literature. Furthermore, at present, most studies do not establish causality in a strong way.

Annual Review of Criminology, Vol. 3 (2020), pp. 97–120

By Callie H. Burt

Over the past several decades, Gottfredson & Hirschi's self-control theory (SCT) has dominated research on self-control and crime. In this review, I assess the current state of self-control knowledge and encourage the field to move beyond SCT, as its peculiar conceptualization of self-control and the causal model present challenges for integrative scholarship. Drawing heavily on scholarship outside criminology, I clarify the definition of self-control; describe the malleable nature of trait self-control; highlight its situational variability as state self-control; and consider the multiplicity of contextual, situational, and individual factors that affect its operation in relation to crime. This specification of contingencies and the interplay between impulse strength and control efforts in the process of self-control is intended as a springboard for research moving beyond SCT and its key premise that self-control (ability) is sufficient to explain individual variation in crime (i.e., is tantamount to criminality). Finally, I address what I see as important areas for further study in light of current knowledge.

Annual Review of Criminology, Vol. 3:43-73, 2020

By Esteban Morales, Jaigris Hodson, Yimin Chen, Chandell Gosse, Kaitlynn Mendes, George Veletsianos

Gender-based technology-facilitated violence and abuse (GBTFVA) is a common experience for those engaging with digital technologies in their everyday lives. To better understand why GBTFVA persists, it is necessary to understand the false beliefs and cultural narratives that enable and sustain them. Drawing on the literature on rape myths, this paper explores the prevalence of seven gender-based online violence myths among Canadian men. To achieve this, we adapted the Illinois Rape Myth Acceptance (IRMA) (Payne et al., in J Research in Personality 33:27–68, 1999) to assess GBTFVA, and surveyed 1,297 Canadian men between 18 and 30 years old on their GBTFVA beliefs. Our results show that GBTFVA myths and cultural narratives are prevalent across participants, though endorsement levels vary. Four myths were more strongly endorsed: It Wasn’t Really Gender-Based Online Abuse, He Didn’t Mean To, Gender-Based Online Abuse Is a Deviant Event, and She Lied. Overall, these findings help to name and thus begin to address the narratives that sustain and perpetuate gender-based online violence.

Sex Roles (2024) 90:1521–1533 https://doi.org/10.1007/s11199-024-01514-w

By: Arantza Alonso Berbotto and Spencer Chainey

The theft of refined oil products provides criminal groups with significant financial resources that threaten the environment and socio-economic stability of countries where it occurs. Violence is also associated with this criminal activity. Using crime script analysis, a detailed interpretation of the theft of oil via the illegal tapping of pipelines in Mexico was constructed. The analysis revealed the roles performed by members of criminal groups, the recruitment of individuals outside of the criminal group to provide information about the pipelines and perform technical activities, and the supporting role of citizens and businesses from local communities. The analysis also revealed the decision-making necessary for the successful commission of oil theft via the illegal tapping of pipelines. The use of situational crime prevention measures and improvements in the use of deterrence are identified as offering opportunities for preventing this criminal activity.

GLOBAL CRIME 2021, VOL. 22, NO. 4, 265–287https://doi.org/10.1080/17440572.2021.1925552© 2021

By Camilo Pardo-Herrera 

The environment is under increasing pressure from global economic dynamics and the constantly increasing demand for raw materials. In this context, environmental crimes in general, and illegal mining in particular, play a key role as they disregard any consideration for sustainable resource extraction. In the Amazon region, one of the most vital ecosystems around the world, illegal gold mining has been identified as the most critical threat to the sustainability of the life of its ecosystems. There is evidence of large quantities of illegal mining production both in Colombia (two-thirds of all production) and Peru (25 to 30 percent of all production). However, since gold is extremely valuable, and portable, it stores value —even under extreme market conditions—, it can be reshaped in any way thinkable, and is not intrinsically illegal, introducing illicitly extracted gold into official supply chains is fairly easy. Once introduced, it flows freely through national, regional, and global markets, and its proceeds do so through the international financial system. It is estimated that illegal mining accounts for up to USD 48 billion a year in criminal proceeds.1 In this context, organized crime associated with the illegal extraction of gold in the Amazon continues to grow in number, size, and scope in response to the insatiable global demand, and thanks to the possibility of laundering and reinvesting their proceeds through illicit financial flows. Thus, an efficient response to the challenges posed by illegal gold mining should be comprehensive and include not just efforts to curb illegal mining, but also, more importantly, efforts to address the illegal flows of money taking place through the gold trade. Although it only analyzes a small sample of the entire global gold market, this paper provides substantive evidence of the illegal flows of money through the gold trade from Peru and Colombia into the United States. While this report is in no position to assert the commission of crimes —since it is only analyzing data— it presents enough evidence to identify points of entry for further criminal investigations and potential judicial action. There is evidence of companies smuggling gold from Venezuela into Colombia, which is then exported to the United States. Between 2010 and 2021, a total of 68,2 tons of gold worth a total of 2.6 billion US dollars, were smuggled through the border in vicinities of Cucuta. Three companies, one in Colombia (CIJ Gutierrez) and two in the United States (Asahi Refining USA Inc., and Johnson Matthey Inc.) concentrate over 90 percent of this trade. Gold trade through this route stopped after 2018 when an Executive Order was signed targeting all parties involved in the trade of Venezuelan gold. There is also evidence of gold and mercury smuggling along the border between Peru and Bolivia and illegal gold production shifting geographies after policy decisions are made. Data show an inexplicable spike in Bolivian gold export in 2014 —with no increases in production— which coincides both, with a ban on mercury by Peru, and a decrease in Peruvian production and exports. This suggests the shifting of illegal mining from Peru into Bolivia, and also of gold smuggling in the same direction. There are clear indications of mis-invoicing of gold trade between these three countries. Peruvian data show significantly higher weight values than those reported at US destinations between 2016 and 2018. A very similar pattern can be seen in Peruvian total exports to the world. Concurrently, trade data show that 29 percent of all shipments from Peru to the US were priced at 70 percent or less than the actual international price during that same time. Although available data does not permit us to assert whether it is a case of overstating the weight of the gold or undervaluing its value, the temporal coincidence of weight and value discrepancies allows us to suggest a general case of mis-invoicing during this time. Colombian data also suggests potential cases of mis-invoicing. Between 2015 and 2016, US statistics reported weight about 50% above those reported by Colombian customs. Price data show that in nine percent of the shipments —approximately 16 tons— gold was paid at 70 percent or less of the global gold price at the time of the transaction. Only a handful of businesses on both sides of the transactions explain most of this trade and are identified — 85 percent of the undervalued shipments are executed by five Colombian firms, and six businesses on the US side concentrate 86 percent of undervalued purchases. Trade in overpriced gold is also identified. Data analysis suggests irregular patterns in the rate between net and gross weights, which could respond to fraudulent reporting and concurrent illicit flows of value. For example, while most shipments use 0.2 grams (or less) of packaging per every gram of gold sent, an important percentage report uses three and up to five times that weight. Of these irregular shipments, over 90 percent were sent by one company in Colombia —Metales Procesados Industriales— to two businesses in the US —Atomic Gold Inc., and United Precious Metal Refining Inc. The analysis also raises warnings as to how certain reports are made. This is the case of the volume of shipments reported by Colombian customs, which is not the result of a measurement, but of an estimation using the net weight of the shipment. Instead of measuring the volume of each shipment, this field is populated using the density of gold, which is a constant, derived from the net weight of the shipment. Although not the result of fraud, but a standard procedure, this hinders transparency and the possibility of monitoring the trade between Colombia and the US. There is evidence of a trend to create shell companies to engage in the trade in gold; presumably of illegal gold. Peruvian tax data shows large numbers of companies participating in the trade in a very sporadic fashion, which contradicts stable and long-lasting trade relationships usual in the international gold market. These companies have a very short legal life, and concentrate all of their commercial activity within a few months, only to cease to exist shortly after. Between 2016 and 2021, these companies traded gold for a total of 230 million USD. 

The Terrorism, Transnational Crime and Corruption Center. George Mason University. Arlington, Va. 2022. 34p.

By Layla Hashemi, Edward Huang & Louise Shelley 

 Over 58 million counterfeit respirators of substandard quality unable to protect individuals from infection have been seized globally since the start of the COVID-19 pandemic. These seizures have primarily occurred in urban warehouses and ports around the world according to analysis of public and corporate data shared with the authors. The presence of tens of millions of respirators in storage facilities prior to distribution demonstrates that urban areas are key elements of illicit supply chains. Data suggests that the concept of urban insecurity needs to be reconsidered in light of illicit supply chains for counterfeit respirators and their role in facilitating disease transmission in urban areas. The analysis presented in this article suggests that threats to human life should not be confined narrowly to violent acts or the consumption of drugs. Human life can also be threatened through the massive distribution of counterfeit N95 masks during a pandemic, a problem that has become more acute with more contagious mutations of COVID-19. 

Urban Crime - An International Journal Vol. 3-No 2-September 2022 

By Mahmut Cengiz  and Oguzhan Omer Demir 

Because of supply and demand factors, human trafficking for sexual exploitation has always been a profitable industry. Turkey, as a host country for immigrants from both former Soviet countries and the Middle East, combines supply and demand, attracting illicit business. Few studies have been conducted in the previous two decades to investigate the organized criminal element of human trafficking in this region. This research is based on ethnographic research in which trafficking victims (N = 11) were interviewed, and on-site observations were made. Our findings revealed that the trafficking industry in our study area was carried out by persons who were only loosely related to one another. There was no sophisticated, long-lasting sex trafficking organization. Membership was not severely limited, and individuals did not identify themselves as members of a well-known criminal organization. We provided policy recommendations and proposals for future research to address female trafficking for sexual exploitation

Social Sciences 11: 511. 2022. 

By Louise I. Shelley

In 1994, the second full year of Demokratizatsiya’s publication, I analyzed the impact of organized crime on the development of post-Soviet states in an article entitled “Post-Soviet Organized Crime: Implications for Economic, Social, and Political Development.”1 This article was written at a time when many in the West were sure that the future course of development for Russia and other post-Soviet states was one of free markets and democracy. Most research on organized crime and high-level corruption in Russia would not be published until much later.2 My article provided a very different and contrarian approach to this rosy scenario for Soviet successor states. In the article’s introduction, I asserted that the infiltration of organized crime into the state would ensure that organized crime would “play a significant role in determining the future course of developments in the Soviet successor states.” In my view, organized crime represented an amalgam of traditional criminals, members of the state security apparatus, former military personnel, and law enforcement officials. I did not associate post-Soviet organized crime exclusively with the very v zakone, the traditional thieves in law or professional criminals. I was especially concerned at the time that the rapid and non-transparent privatization of state property to the benefit of corrupt politicians, organized crime, and their business partners would have persistent and deleterious long-term consequences, leading to the monopolization of key sectors of post-Soviet economies rather than the competitive economies needed for growth.

Demokratizatsiya: The Journal of Post-Soviet Democratization, Volume 30, Number 4, Fall 2022, pp. 411-419

By Yulia Krylova  and· Louise Shelley

The last decade witnessed increasing involvement of criminal street gangs in domestic sex trafficking in the United States. This paper analyzes business models and practices of gang-controlled sex trafficking in Northern Virginia, based on the cases available from PACER, an electronic public access service of the United States federal court. This analysis shows that business models of gang-controlled sex trafficking have become more sophisticated, taking advantage of the globalized financial system, new technology, social media, and the increasing prevalence of illicit commerce in a digital world with greater connectivity. Gangs’ flexible structures combined with loyalty enforced among their members have shielded them from much law enforcement action. The analysis of different gangs involved in sex trafficking in Northern Virginia provides new insights into anti-trafficking policies and law enforcement responses tailored to their structures and modi operandi.

Crime, Law and Social Change, February 2023

Organized Theft Groups (OTG) and Organized Retail Crime (ORC) .  A Comprehensive Educational Guide for Law Enforcement and Financial Crime Investigators  

By Lauren Kohr and Tiffany Polyak,

Organized retail crime (ORC) remains at the forefront of most major news channels across the United States. High-profile “smash-n-grab” robberies, and nationwide cases involving major retailers in Chicago, Los Angeles, and San Francisco, garner the headlines. Recent hearings by the United States Congress, that discuss and debate proposed legislation, target the ability of criminal organizations to resell stolen goods online with relative anonymity.1 ORC is a low-risk, high-reward business line for transnational criminal organizations’ portfolios that presents a significant financial and public safety risk. While retailers and law enforcement partner to investigate ORC cases and provide education on the misconceptions and misunderstandings, it is clear there is a missing link in these partnerships, and that link is financial institutions. Criminal organizations need to launder the nearly 70 billion US dollars of illicit proceeds gained from ORC activities annually. These organizations are looking to launder their billions through the formal financial sector, unregulated payment processors, and online marketplaces. 1. The Brand Protection Professional, Professional Pointer: What Is ORC And Is It Related To IPRC? To combat ORC and take down organized theft groups (OTGs) more effectively, first, financial institutions must be brought into the awareness and education triangle. Second, public-private partnerships and information-sharing channels between retailers, law enforcement, and financial institutions need to be created. Third, as law enforcement and retailers prioritize investigations involving ORC, financial institutions should look to reasonably enhance their anti-money laundering (AML) and counter-terrorist financing (CTF) programs to detect and report illicit proceeds stemming from these crimes. Financial institutions should ensure proper controls are in place to detect and report illicit activities tied to or involving ORC. While not specifically addressed in the National AML/CFT Priorities issued by the Financial Crimes Enforcement Network (FinCEN) on June 20, 2021, it should be addressed that ORC has been tied to many of the priorities issued and other heinous crimes, as reflected in this guide.  

ACAMS and Homeland Security Investigations, 53p.

By Spencer P. Chainey & Arantza Alonso Berbotto 

Crime script analysis is becoming an increasingly used approach for examining organized crime. Crime scripts can use data from multiple sources, including open sources of intelligence (OSINT). Limited guidance exists, however, on how to populate the content of a crime script with data, and validate these data. This results in crime scripts being generated intuitively, restricts them from being scrutinized for their quality and limits the opportunity to combine or compare crime scripts. We introduce a practical process for populating the content of a crime script that involves simple coding procedures and uses document analysis to quality assure data that are extracted from open sources. We illustrate the process with the example of the theft of oil from pipelines in Mexico committed by organized crime groups. The structured methodical process we introduce produces a crime script of high quality, helps to improve the systematic analysis of decision-making performed by members of organized crime groups, and can improve the identification of opportunities for crime control.

Published: 23 August 2021, Trends in Organized Crime, Volume 25, pages 272–300, (2022)

By Roderic Broadhurst, Katie Skinner, Nicholas Sifniotis, Bryan Matamoros-Macias and Yuguang Ipsen

In an exploratory quasi-experimental study, 138 students recruited during a university orientation week were exposed to social engineering directives in the form of fake emails, or phishing, over several months in 2017. The study assessed the risks of cybercrime for students by observing their responses. Three types of scam emails were distributed that varied in the degree of individualisation: generic, tailored, and targeted or ‘spear’. The study explored the influence of scam type, cybercrime awareness, gender, IT competence and perceived internet safety on susceptibility to email scams.Although tailored and individually crafted email scams were more likely to induce engagement than generic scams, differences were not significant. Analysis of the variables showed that international students and first year students were deceived by significantly more scams than domestic students and later year students.

Trends & issues in crime and criminal justice no. 587. Canberra: Australian Institute of Criminology. 2020. 16p.

Edited by Erica Charters, Marie Houllemare, and Peter H. Wilson

This is the first extensive analysis of large-scale violence and the methods of its restraint in the early modern world. Using examples from Asia, Africa, the Americas and Europe, it questions the established narrative that violence was only curbed through the rise of western-style nation states and civil societies. Global history allows us to reframe and challenge traditional models for the history of violence and to rethink categories and units of analysis through comparisons. By decentring Europe and exploring alternative patterns of violence, the contributors to this volume articulate the significance of violence in narratives of state- and empire-building, as well as in their failure and decline, while also providing new means of tracing the transition from the early modern to modernity.

Manchester, UK: Manchester University Press,  2020.  317p.

By Melissa Farley & M. Alexis Kennedy

Background: Extreme violence and psychological abuse have been extensively documented and are pervasive in prostitution. Survivors of prostitution report high levels of posttraumatic stress disorder, dissociation, depression, and self-loathing. These are the same sequelae reported by torture survivors. Objective: Severe forms of violence have been categorized as torture by experts. The authors note that torture is commonly suffered during prostitution and should be appropriately named. Method: Using standardized measures and including a new measure of torture, we interviewed 45 women in the United States about their torture experiences in prostitution and their symptoms of PTSD, dissociation, childhood trauma, health status and somatic symptoms. The interviewees had exited prostitution and were in supportive programmes. Results: Formerly prostituted interviewees reported acts of physical, sexual, and psychological torture, including strangulation, rape, beatings, restriction of movement, denial of privacy, sleep, or food, and being forced to witness the torture of others. The 45 women had high levels of PTSD and dissociation. They endorsed needs for individual counselling, substance abuse treatment, and other medical care. Conclusions: A recognition of the physical, sexual, and psychological torture experienced in prostitution would strengthen psychological and medical interventions for survivors. Naming specific acts of prostitution as torture will reduce the survivor’s shame and selfblame. Holistic treatment includes medical and psychological interventions and peer support, as seen in torture rehabilitation programmes for survivors of state-sponsored torture. This research supports the perspective that private or non-state-sponsored torture against women and marginalized populations should be clinically and legally understood in the same way as state-sponsored torture.   

European Journal of Psychotraumatology, 15:1, 2404307, DOI: 10.1080/20008066.2024.2404307 To link to this article:

By Jonah Rexer

Multinationals in the extractive sectors of weak states may face resource theft by armed groups. This criminality is often abetted by state corruption, even though firms are willing to pay for protection. I study indigenization in Nigeria's oil sector, which increased participation by Nigerian firms substantially. Despite evidence that local firms are of lower quality, localization increases output and reduces oil theft. A bargaining model illustrates that political connections align law enforcement incentives, solving commitment problems. Data on raids by government forces show that local firms receive preferential law enforcement protection. I find that connections to military elites drive the local advantage.

.Princeton, NJ:  Princeton University, 2022. 113p  

By Malore Dusenbery, Josh Fording, Jennifer Yahner, Jeanette Hussemann, Robbie Dembo

Victims of crime can experience serious harms and face significant costs with long-term implications for their economic security and safety. From 2022 to 2024, the Urban Institute and NORC at the University of Chicago conducted a National Study of Victim Compensation Program Trends, Challenges, and Successes, which included evaluations of four state crime victim compensation programs. This brief presents our evaluation of New York State’s victim compensation program to understand its utilization and professionals’ and victim claimants’ perspectives on its ability to meet victims’ needs. We conclude that the New York compensation program serves a vital role helping victims address the financial burden of crime with many strengths and recent improvements. Although participants identified some gaps in coverage, the program is overall comprehensive, with no limits on medical costs and increases to property and funeral coverage. And despite challenges making changes to compensation coverage, professionals appreciate that the program has been able to evolve eligibility and benefits based on victims’ needs, which we hope they continue to do for new communities (e.g., migrants) and emerging costs (e.g., informal economy wages). The program has made great efforts to be accessible, with multiple ways to submit a newly shortened application, frequent training and outreach to victim assistance providers and other programs, and a statewide awareness campaign and needs assessment in 2023. The program also recently enacted several major changes to improve the accessibility and equity of the program, particularly eliminating the requirement to report to law enforcement and changing the policy on contributory conduct for homicide claims. Professionals in the compensation program and the community offered recommendations for improving New York’s compensation program regarding awareness and accessibility, compensation coverage, and program funding and staffing. The most common suggestion was to do more public information campaigns and advertising to increase people’s awareness of the program before they become victims. The program could also conduct training and education alongside providers and educate programs in underserved communities beyond victim assistance programs, including schools, hospitals, YMCAs, social services, and family service providers. Additional staff are needed to efficiently process claims, respond to claimant outreach, and help claimants understand the appeals process. Spanish-speaking staff in particular could help reduce the number of Latino claimants who want but do not get help. Potential solutions to increase staff recruitment and retention include increasing salaries, providing more resources on vicarious trauma, and opening up more career paths for staff who start in the compensation program. Many of these findings and recommendations align with those emerging nationally in conversations about how to improve victim compensation programs. We are grateful that programs such as New York’s remain open to evaluation and eager to understand how to continue increasing awareness and accessibility of the program across the state and within underserved communities, maximizing coverage, and improving their efficiency and effectiveness so they may best serve all victims in need.

Washington, DC: Urban Institute 2024. 24p.

By Shana Conroy and Danielle Sutton

"This Juristat article relies on multiple data sources to examine the nature and prevalence of violent victimization of seniors. In addition, the article presents the various factors associated with perceptions of crime and safety among seniors. Self-reported data from the 2019 General Social Survey on Canadians’ Safety (Victimization) are presented first, detailing seniors’ experiences of violent victimization and their perceptions of safety. The sections that follow present police-reported data from the Uniform Crime Reporting Survey and the Homicide Survey, providing detail on annual trends, accused-victim relationships and incident characteristics. While 2020 was an unusual year due to the COVID-19 pandemic, police-reported incident data were similar for 2019 and 2020. As such, this article reports the latest police-reported data from 2020"

Ottawa] : Statistics Canada = Statistique Canada, 2022. 35p.

By Michael T. Light , Julia T. Thomas

Unauthorized immigration, already a divisive and controversial subject in American society, was reframed as a grave national security threat after the terrorist attacks on Sept. 11, 2001. Yet, despite substantial public, political and policy attention to the issue of undocumented immigration and terrorism, there has been relatively little empirical assessment of the relationship between unauthorized immigration flows and terrorist activity. We attempt to fill this gap by combining newly developed estimates of the unauthorized population, a novel use of sentencing and prosecutorial data to measure terrorism-related activity, and multiple data sources on the criminological, socioeconomic, and demographic context from all 50 states from 1990 to 2014. We then leverage this unique dataset to examine the longitudinal, macro-level relationship between undocumented immigration and various measures of terrorism. Results from fixed effects negative binomial models suggest that increased undocumented immigration over this period is not associated with terrorist attacks, radicalization, or terrorism prosecutions.

Soc Sci Res. 2021 February ; 94: 102512. doi:10.1016/j.ssresearch.2020.102512. 

By Michael T. Light and Isabel Anadon

The dramatic increase in both lawful and unauthorized immigration in recent decades produced a groundswell of research on two questions: (1) Does immigration increase violent crime? and (2) What policy responses are most effective at addressing unauthorized immigration (e.g., sanctuary policies, deportations, etc.)? For the most part, these bodies of work have developed independently, and thus we know little as to whether the insights from one inform the other. This Article fills this gap by first reviewing both areas of research and then triangulating shared findings between them. In doing so, we focus on three contemporary immigration policies: (1) increased deportation; (2) “sanctuary” policies, and (3) “amnesty” laws. Our review provides little evidence to suggest that immigration increases the prevalence of violence. For this reason, policies aimed to enhance public safety by reducing immigration are unlikely to deliver on their crime reduction promises.

103 Marq. L. Rev. 939 (2020).