Torture still occurs in a small number of liberal democracies despite several international treaties such as the International Covenant on Civil and Political Rights and the UN Convention Against Torture making torture illegal. Despite such international conventions, torture cases continue to arise such as the 2004 Abu Ghraib torture and prisoner abuse scandal committed by personnel of the United States Army. The U.S. Constitution and U.S. law prohibits the use of torture, yet such human rights violations occurred during the War on Terror under the euphemism Enhanced interrogation. The United States revised the previous torture policy in 2009 under the Obama Administration. This revision revokes Executive Order 13440 of 20 July 2007, under which the incident at Abu Ghraib and prisoner abuse occurred. Executive Order 13491 of 22 January 2009 further defines United States policy on torture and interrogation techniques in an attempt to further prevent another torture incident. Yet apparently the practice continues, albeit outsourced.