A/HRC/34/55 involve adoption, as an option of first resort, rather than providing the required support to families.36 3. Illegal intercountry adoptions 43. Intercountry adoptions have been fuelled by a demand from prospective adoptive parents in higher-income countries for children from lower-income countries. That demand has put major pressure on countries of origin with weak child protection systems and often led to illegal acts and illicit practices that have resulted in the sale of children and illegal intercountry adoptions. 44. In Romania, for example, the fall of the Ceausescu regime was followed by a surge in the number of intercountry adoptions.37 Widespread illegal adoptions were reported, in particular through the use of private procedures that targeted children who had not been placed in institutions. Of note was the rapid development of private adoption agencies, which were allocated a number of adoptable children depending on the size of their financial contributions to local child protection authorities. 38 That system amounted to sale and was further compounded by the direct purchasing of children by intermediaries and the improper inducement of consent. As a response, national authorities implemented legislation to limit the number of adoptions on three separate occasions, namely in 1991, 2001 and 2005. That legislation amounted to a moratorium on adoptions. Throughout that period, external pressures from receiving countries strongly influenced intercountry adoptions in Romania.39 45. As the case of Romania demonstrates, one response to deficiencies in the intercountry adoption procedure has been the provisional suspension of adoptions, often known as moratoriums. In numerous countries of origin and receiving countries, moratoriums have been imposed following scandals revealing illegal practices in adoption procedures. The Hague Conference on Private International Law has noted that many States have a reactive approach to financial malpractice and abuse in intercountry adoption and tend to wait until problems are pervasive before addressing them. 40 46. Certain countries of origin have notably deemed it impossible to ensure probity in intercountry adoptions under the prevailing conditions and in the face of pressure from receiving countries, and have responded in a variety of ways. For instance, Paraguay has decided to apply strictly the principle of subsidiarity after ratifying the 1993 Hague Convention; since then, it has deemed it unnecessary to process intercountry adoptions. Several African countries (e.g. Lesotho, Liberia and Togo) have also found it necessary to suspend intercountry adoptions in order to attempt to resolve serious malpractice. 41 For their part, receiving countries may decide to impose moratoriums on specific countries of origin in the light of evidence that widespread irregularities have been taking place. This has been decided in the cases of Cambodia, Ethiopia, Guatemala, Haiti, India, Nepal and Uganda. 47. As a general rule, suspension decisions are unilateral, uncoordinated and often belated, which reflects the lack of a common understanding (or willingness to implement) by receiving countries as to what the protection of children’s rights demands in the sphere 36 37 38 39 40 41 See http://assembly.coe.int/nw/xml/XRef/Xref-DocDetails-fr.asp?FileID=21567&lang=fr. See https://www.unicef-irc.org/publications/pdf/digest4e.pdf. See https://www.unicef.org/ceecis/UNICEF_ICA_CEE_Guidance_WEB.pdf. Mariela Neagu, “Children by request: Romania’s children between rights and international politics”, International Journal of Law, Policy and the Family, vol. 29, No. 2 (2015), pp. 215-236. See https://assets.hcch.net/upload/wop/factsheet_finasp_en.pdf. See http://resourcecentre.savethechildren.se/sites/default/files/documents/6520.pdf. 11