1954: Agreement on the deployment of US forces to the Netherlands in 2002: agreement on the status of US forces in Romania (agreement before Romania`s accession to NATO) NATO SOFA is a multilateral agreement applicable to all NATO member countries. Since June 2007, 26 countries, including the United States, have either ratified the agreement, nato joined NATO.126 NATO SOFA127 is the only SOFA, 128 agreement under Article V of the Mutual Defence Treaty on facilities and territories and the status of the US armed forces in Korea (17 U.S.S.1677), cited mutual Defense Treaty (5 U.S.T. 2368) 2006 Memorandum of Understanding about the use of airspace, ranges, airports, seaports, and training facilities by U.S. forces in Europe The counterpart agreement contains provisions on criminal juristv over Philippine personnel while in the United States. The agreement was reached in the form of an executive agreement and was not ratified by the U.S. Senate. Probably, according to the logic of the U.S. District Court for the District of Columbia in Clifford, because the agreement probably reduced the impact of U.S. jurisdiction, it would have to be ratified by the Senate to be constitutionally valid. But the counter-agreement can be distinguished from SOFA with the Republic of Korea and SOFAs with other foreign jurisdictions, because the United States does not completely waive jurisdiction for crimes committed on the territory of the United States. On the contrary, the agreement stipulates that the U.S. authorities will require, at the request of the Philippine government, that the competent authorities lift jurisdiction in favor of the Philippine authorities.107 However, the State Department and the U.S.

Department of Defense retain the ability to determine that U.S. interests require the United States to exercise federal or state jurisdiction over Philippine personnel.108 In any discussion of SOFA It should be noted. that there are currently at least 10 classified agreements. The agreements are classified for national security reasons. They are not covered in this report. To Wilson v. Girard,76 The Supreme Court first considered the jurisdictional provisions of the administrative agreement.