In short
- A total of 17 persons have been sanctioned to date, with new actions announced.
- General licenses authorize certain ICC-related transactions, including IT services and pension plan activities.
What happened
The State Department announced new sanctions against the International Criminal Court, designating it under section 1(a)(ii)(A) of Executive Order 14203. These actions block all property and interests in property of the ICC in the United States or controlled by U.S. persons, requiring them to be reported to OFAC.
Concurrent with the sanctions, the Department of the Treasury issued several general licenses authorizing specific ICC-related transactions, such as maintenance operations for 180 days, IT services, pension plan activities, and detainee-related activities. These licenses aim to protect U.S. interests and allow time for diplomatic resolutions.
all property and interests in property of the ICC that are in the United States or in possession or control of U.S. persons are blocked and must be reported to the Department of the Treasury’s Office of Foreign Assets Control (OFAC).
In numbers
- 17 persons sanctioned to date
- 180-day maintenance general license duration
What compliance teams should check
- Screen all transactions for links to the International Criminal Court and the 17 sanctioned persons under Executive Order 14203.
- Review OFAC’s website for details on the four general licenses covering ICC maintenance, IT services, pension plan, and detainee activities.
- Report any property or interests in property of the ICC in the United States or controlled by U.S. persons to OFAC as required.
Why it matters
This story is significant for AML/CFT compliance because it introduces new sanctions and reporting requirements for any property or transactions involving the International Criminal Court. Compliance officers must ensure that all relevant assets are blocked and reported, and that transactions are only conducted if authorized by specific general licenses. The 180-day maintenance license provides a window for diplomatic solutions, but compliance teams must closely monitor updates and adjust controls as licenses or sanctions evolve.
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