Numerous forms of non-state actor conduct in violation of treaty- based and customary international law have been subject to criminal and civil sanctions in various international and domestic fora for centuries.
Paust, Jordan J.
"Sanctions Against Non-State Actors For Violations of International Law,"
ILSA Journal of International & Comparative Law: Vol. 8
, Article 9.
Available at: http://nsuworks.nova.edu/ilsajournal/vol8/iss2/9