In March 2010, the UN Special Rapporteur on human rights in Burma, Tomas Quintana, urged the UN “to establish a commission of inquiry with a specific fact finding mandate to address the question of international crimes” in Burma. This suggestion comes in response to allegations by Burmese activists and non-governmental organizations (NGOs), such as Human Rights Watch, that Burmese government actors have committed crimes against humanity and war crimes. The United States, the United Kingdom, Canada, Australia, and New Zealand, among other nations, have voiced support for Rapporteur Quintana’s proposal to investigate charges including murder, torture, rape, warrantless detention, widespread forced relocations, and forced labor. In light of the Burmese government’s failure to act upon these allegations, accountability will likely be achieved only through cooperation from the international community. The United Nations can establish a commission of inquiry to investigate crimes against humanity through a resolution from the Human Rights Council (HRC), the General Assembly (GA), or the Security Council (SC). Alternatively, the Secretary-General can establish a commission on his own initiative. Such a commission is not without precedent. In 2004, the UN was faced with a serious challenge in Darfur, where an uncooperative government was accused of being complacent in systematic crimes against humanity. The SC passed Resolution 1564, establishing the International Commission of Inquiry on Darfur (Darfur Commission). The Darfur Commission’s mandate was to “[immediately] investigate reports of violations of International humanitarian law and human rights law in Darfur by all parties, . . . and to identify the perpetrators of such violations with a view to ensuring that those responsible are held accountable.” The largely successful investigation methods of the Darfur Commission may offer a model from which a Burmese commission could learn. The Darfur Commission’s fact-finding delegation conducted visits to Sudan to interview members of the national government, provincial and local leaders, members of the armed forces, IDPs, victims and witnesses of violations, NGOs, and UN representatives. Because it gathered testimony representative of many viewpoints in the conflict, the international community regarded the Darfur Commission as credible and impartial. Once the investigation was complete, the Darfur Commission was able to recommend, based on its findings, that the SC refer the matter to the ICC. Even though allegations of abuses in Darfur were often denied or downplayed by the Sudanese Government, the Darfur Commission was able to convey to the world the extent of the atrocities being committed in an impartial and trusted manner. For over twenty years, the UN has passed various resolutions urging the Burmese government to respect human rights. A commission of inquiry would provide credible answers to allegations that crimes against humanity and war crimes have been perpetrated, and would help establish accountability for the acts. If the commission were to find that these allegations were true, it would have two principle options. It could follow the example of the Darfur Commission and recommend that the SC refer the matter to the ICC, although it is unlikely that the SC would follow this suggestion. For a SC referral, nine of the fifteen countries on the SC must vote yes and there can be no veto from the five permanent members of the SC. China has actively opposed past resolutions against Burma, and would likely oppose ICC involvement. Because of the difficulties inherent in passing an ICC referral though the SC, a commission of inquiry would likely seek another means of accountability. Confronted with the difficulties in convincing the SC to refer the Burmese government to the ICC, the commission could instead recommend that the SC establish a compensation commission to bring redress to victims. This commission would be established under the terms of the GA’s Declaration of Basic Principles of Justice for Victims of Crime and Abuse of Power (GA’s Declaration), and would preside over compensation claims made by victims of the crimes found by the initial commission of inquiry. Because of the broad definition of victim under the GA’s Declaration, anyone harmed physically, mentally, emotionally, or economically by way of human rights violations could seek compensation. Compensation could include medical and psychological rehabilitation, access to legal and social services, or forms of widespread remedy such as an official public apology in which leadership would take responsibility for the crimes committed, or official guarantees of non-repetition. Were a UN commission of inquiry to find that crimes against humanity had indeed occurred, it would be a powerful statement to the SC that the Burmese government must be held responsible. A credible investigation based on objective evidence would be difficult for the international community to ignore. Referring the perpetrators to the ICC, or creating a compensation commission, would be one of the first steps in bringing justice to victims and ensuring accountability.