The Organization for Security and Cooperation in Europe is based on executive agreements. Belmont and Pink have been to American Ins. Ass`n. Garamendi.10Footnote539 U.P. 396 (2003). The opinion of the Court of Justice in Dames & Moore v. Regan, 453 U.S. 654 (1981), was rich in learning experiences on many topics relating to executive agreements, but the preemptive force of agreements based exclusively on the power of the president was not in question, the court concluded that Congress had either authorized various presidential actions or had long been accessible to others. Noting that the Victim Insurance Relief Act in California was anticipated as an interference in the foreign relations of the federal government, as expressed in the executive agreements, the Tribunal reiterated that the executive agreements in force are likely to prevent state law, as are treaties.11Footnote539 U.S. at 416. Although the Supreme Court has not directly addressed the issue, many courts and commentators agree that provisions of international agreements that would require the United States to exercise powers conferred exclusively on Congress should not be considered self-fulfilling, and implementing laws are necessary to give national legal value to these provisions.117 118 Other subordinate courts have proposed that contractual provisions purporting to establish criminal liability119 or generate revenue120 should not be considered self-fulfillment, as these powers are the exclusive prerogative of Congress. Although treaties and agreements between Congress and the executive branch are international agreements, these two instruments are legally different.