Historically, criminals were required to make restitution directly to the victim but by the 20th century compensation had been transferred to the collective society until 1964 when New Zealand implemented the first victim compensation program. Great Britain followed shortly with the Criminal Injuries Compensation Scheme. The amount of compensation is assessed on the basis of common law damages for personal injury in civil proceedings. The Criminal Justice Act, 1988 increases the powers of the courts and effectively requires the courts to make such orders. In contrast, in the United States, the Victims of Crimes Act, 1984 (VOCA) grants compensation funds to States which administer individual programs with some offering benefits only to those in financial need. 12 references.