The International Police Academy (IPA) in Washington was an example of a training facility mm by the CIA. Those states taking training at the IPA included Chile, Nicaragua, Panama, Guatemala, Mexico, Brazil, the Philippines, Hong Kong, Belize (then British Honduras), Korea, Paraguay, Peru, Iran, and Uruguay. Agents from these states enrolled in the "Technical InvesHipation Course" which involved classroom work in Washington and fieldwork at the Border

Bureau of Investigation (FBI) reports to the CIA fill in most of the gaps. The CIA makes no objection to the continuation of those activities. It fails to transmit to the State Department any particulars of its tacit agreement with THRUSH.21

The CIA is fully aware that the information gathered by THRUSH or given to THRUSH_by_the_FBI is used to identify those targeted for “countering,"22 and the CIA so informs the FBI. Neither United States agency23 gives this consideration any weight when formulating policy concerning liaison with THRUSH.24 Each regards its current relationship with THRUSH as rewarding. THRUSH provides intelligence information both from within and without the United States Patrol Academy in Los Fresnos, Texas. Fieldwork lectures were given by CIA agents. Id. at 53– 56.

The IPA was founded by the United States Agency for International Development. Damaging publicity forced the academy to close. The IPA had earned the reputation for being the “School for Torturers," although this was denied by the IPA. See id. at 54, 163-64, 347-51 n.7. The United States, however, did not go out of the business of training foreign intelligence agents. Rather, it turned to alternative means. In 1968, the Federal Police Academy, a recipient of United States monies, opened its doors in Brazil to train Chile's DINA agents, who in turn instructed anti-Castro Cubans living in Costa Rica, Guatemala, and Nicaragua. Id. at 53–56. Given that it is quite likely torture was taught, at least informally, at the IPA, it is reasonable to assume that American-acquired torture skills were put to use in the home states of trainees. Furthermore, it follows that other skills, including surveillance and harassment techniques, were employed against citizens in the home state. It is not a quantum leap to posit that dissident emigres from the trainee state living in the United States probably have been subject to those skills.

Other skills taught by the CIA include agent recruitment and handling, physical and electronic surveillance, surreptitious entry, methods of infiltration, and assassination and torture techniques. See T. POWERS, supra, at 126.

21. CIA failure to notify the State Department would constitute a violation of the Case Act. See infra text accompanying notes 49-52. One author has noted, however, that "[f]rom the CIA's point of view the Secretary of State's office was about as secure as the floor of Congress with a full press gallery." T. POWERS, supra note 20, at 130.

22. It has been suggested that George Bush, when CIA Director, knew of the DINA operation against Orlando Letelier in the United States, yet chose not to dissuade DINA from its goal. T. PLATE & A. Darvi, supra note 19, at 275. However, after the assassination, the FBI conducted so exemplary an investigation that DINA officials were reportedly quite uneasy. Id. Cf. Marwick, supra note 10, at 5.

23. It has been alleged that the FBI also maintains "liaisons" (a term of art describing "the interchange of intelligence of mutual interest {between] two governments," see W. SULLIVAN, supra note 20, at 97) with foreign intelligence agencies, primarily for exchange of information and training. The FBI has acknowledged that it maintained a liaison relationship with SAVAK and that it accepted information from SAVAK. In a 1977 letter to the American Civil Liberties Union, FBI Director Clarence K. Kelley wrote that “we have established liaison with SAVAK officers who have contacted our field offices," and that "we accept any information which is volunteered." Letter from Clarence M. Kelley, Director, FBI, to Aryeh Neier, Executive Director, and Jack D. Novik, National Staff Counsel, ACLU (Dec. 23, 1977) (on file with author). See also Anderson & Whitten, U.S. Is Said to Aid Shah's Police, Wash. Post, Aug. 20, 1977, at B11, col. 3 ("An FBI official acknowledged that Mansur Rafizadeh (the principal representative of SAVAK in the United States] was a 'foreign liaison source' of the FBI.").

24. Besides “official” United States foreign policy, other facts may explain why United States agencies fail to restrict the activities of friendly agents. Consider first the personal reaction of United States officials toward foreign dissidents. Because these officials "deal only with the regime in power... and actively support that regime against foreign threats and internal

a reason. All the evidence indicates, however, that the
authorities in Taipei have made concerted efforts, over the
years, to meet international human rights standards and
enhance the life circumstances of the population on Taiwan
and associated territories. There is no convincing evidence
of a concerted government policy violative of human rights
in the ROC.

At best, any action by the United States government as a consequence of the unfortunate Liu case, in terms of sanctions against the authorities in Taipei would be premature. Whatever its failures in the past, the government of the Republic of China on Taiwan has been sensitive to U.S. concerns with respect to fundamental, civil and political human rights. As we have seen, in the judgment of the U.S. Department of States, the "outlook for continued improvement in human rights [on Taiwan] appears favorable." Any actions on the part of the government of the United States which would obstruct that improvement, by increasing the measure of threat under which

the government in Taipei must operate, would be counterproductive. Any imposition of sanctions would contribute to the measure of threat--and should be abjured. They would do nothing to increase the availability of human rights on Taiwan, and could very well threaten very fundamental U.S. and Chinese interests.

Notes to the Henry Liu Murder Case

1. See the discussion in A. James Gregor and Maria Hsia Chang, The Republic of China and U.S. Policy: A Study in Human Rights (Washington, D.C.: Ethics and Public Policy, 1983).

2. Country Reports on Human Rights Practices for 1979 (Washington, D.C.: U.S. Department of State, 1980), p. 526. 3. Country Reports on Human Rights Practices for 1983 (Washington, D.C.: Department of State, 1984), p. 756.

4. See the testimony of A. James Gregor, before this subcommittee in Martial Law on Taiwan and United States Foreign Policy Interests (Washington, D.C.: U.S. Government Printing Office, 1982), pp. 7-46.

5. See the comprehensive discussion in Raymond D. Gastil (editor), Freedom in the World: Political Rights and Civil Liberties 1983-1984 (Westport, Conn.: Greenwood Press, 1984). 6. In this regard, see the discussion in Hungdah Chiu, Chinese Law and Justice: Trends Over Three Decades (Baltimore: University of Maryland School of Law, 1982) and Socialist Legalism: Reform and Continuity in Post-Mao People's Republic of China (Baltimore: University of Maryland School of Law); Tao-tai Hsia, "Legal Development in the People's Republic of China, 1949-1981," in Hungdah Chiu and Shao-chuan Leng (eds.), China: Seventy Years After the 1911 Hsin-hai Revolution (Charlottesville: University of Virginia, 1984).

a reason. All the evidence indicates, however, that the
authorities in Taipei have made concerted efforts, over the
years, to meet international human rights standards and
enhance the life circumstances of the population on Taiwan
and associated territories. There is no convincing evidence
of a concerted government policy violative of human rights
in the ROC.

At best, any action by the United States government as a consequence of the unfortunate Liu case, in terms of sanctions against the authorities in Taipei would be premature. Whatever its failures in the past, the government of the Republic of China on Taiwan has been sensitive to U.S. concerns with respect to fundamental, civil and political human rights. As we have seen, in the judgment of the U.S. Department of States, the "outlook for continued improvement in human rights [on Taiwan] appears favorable." Any actions on the part of the government of the United States which would obstruct that improvement, by increasing the measure of threat under which the government in Taipei must operate, would be counterproductive. Any imposition of sanctions would contribute to the measure of threat--and should be abjured. They would do nothing to increase the availability of human rights on Taiwan, and could very well threaten very fundamental U.S. and Chinese interests.