U.S. sanctions can block the property of designated International Criminal Court (ICC) officials, prohibit specified transactions involving them, and expose certain foreign supporters to later designation. Executive Order 14203 does not say that every person or organization working with the ICC is automatically sanctioned: its defined criteria and any subsequent designation matter. The sanctions also include U.S. entry restrictions for specified ICC-associated people. The ICC and the Assembly of States Parties warn that the measures threaten the Court’s work, but the available financial disclosure does not quantify overall losses or effects on every partner.
What Executive Order 14203 does
President Donald Trump signed Executive Order 14203 on February 6, 2025. It invokes the International Emergency Economic Powers Act (IEEPA), the National Emergencies Act, immigration-law authority and other presidential authority. The order states the U.S. administration’s position that ICC actions concerning the United States and Israel are illegitimate and threaten U.S. national security and foreign policy. Those are the government’s stated reasons for the order, not neutral findings established by the order itself.
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Blocking property and restricting transactions
The order initially names ICC Prosecutor Karim Khan. It blocks property and interests in property belonging to a blocked person when that property is in the United States, later comes within the United States, or is in the possession or control of a U.S. person. It also prohibits specified dealings in blocked property, including providing or receiving funds, goods or services involving a blocked person. Evasion, attempted evasion and conspiracy to violate the prohibitions are separately prohibited.
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Who may be designated later
Beyond the person named initially, the order establishes criteria under which a foreign person may be designated. These include directly engaging in specified ICC efforts concerning a protected person; materially assisting or supporting that covered activity or a blocked person; or being owned or controlled by, or acting for, a blocked person. The order’s language encompasses specified forms of material, financial or technological support and provision of goods or services.
These criteria create potential sanctions exposure for some suppliers, service providers, financial intermediaries and other supporters, but the order does not identify association with the ICC alone as automatic grounds for designation. Whether a particular person or transaction is covered depends on the order’s definitions, the facts, any designation, applicable regulations and any license. A partner should not treat this general explanation as a determination about its own legal exposure.
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Who counts as a “protected person”
The order uses a defined term rather than treating all U.S. citizens or allied-country nationals alike. It covers U.S. persons subject to the order’s stated consent and States Party conditions, and certain foreign citizens or lawful residents of NATO or major non-NATO allies that have not consented to ICC jurisdiction over the person or are not States Parties to the Rome Statute. Covered categories include current and former military members, government officials, and people employed by or working on behalf of the specified governments. The precise conditions in the order matter when assessing whether an ICC effort falls within the criteria.
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Entry restrictions are a separate measure
The order also suspends entry into the United States for aliens determined to meet specified designation criteria, their immediate family members, and aliens whom the Secretary of State determines are employed by or acting as agents of the ICC, subject to stated exceptions. For this order, an immediate family member means a spouse or child. The entry provisions are distinct from blocking property and transaction rules. The order also excepts transactions conducted for official U.S. government business by its employees, grantees or contractors.
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How OFAC administers the program—and what the latest notice says
The Treasury Department’s Office of Foreign Assets Control (OFAC) administers the sanctions program. Its ICC-related program materials identify Executive Order 14203, IEEPA, the National Emergencies Act and 31 CFR Part 528 within the program’s legal framework, and provide sanctions-list, FAQ and licensing information.
OFAC’s latest reviewed program update is dated August 18, 2026. In that notice, OFAC designated ICC President Tomoko Akane and Abdoulaye Seye, a Senior Trial Lawyer in the Office of the Prosecutor, and issued General License 12 authorizing a wind-down of transactions involving certain people blocked on that date. The license is limited by its own terms; its issuance should not be read as permission for ongoing business or as covering transactions outside its scope.
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General licenses and specific licenses
| Authorization | What it means | What to check |
|---|---|---|
| General license | OFAC says a general license authorizes the activities it describes for U.S. persons without a separate specific-license application. | Read the license’s exact terms, covered persons, activities, dates and conditions. General License 12 was a wind-down authorization for certain persons blocked on August 18, 2026. |
| Specific license | OFAC authorization for a transaction that would otherwise be prohibited. | Do not assume authorization exists before OFAC issues it; confirm that the license covers the exact transaction and parties. |
Sanctions lists, licenses and program guidance can change. For a real transaction, check OFAC’s current ICC-related program page, the current Specially Designated Nationals (SDN) List and the full text of any relevant license, and obtain advice from qualified sanctions counsel. A past notice or this article cannot establish whether a person remains blocked or a transaction is currently authorized.
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The key distinction is between a direct designation and potential exposure under the order’s support and ownership criteria. A directly designated person is subject to blocking restrictions. A foreign person who has not been designated is not automatically blocked just because it is an ICC partner, but the order permits designation of certain people for covered support or activity. U.S. persons must also consider whether a transaction involves blocked property or a blocked person, even when the U.S. counterparty is not itself an ICC partner.
- For banks and payment providers: determine whether a party, owner, beneficiary or transaction involves a blocked person or property, and whether an OFAC license applies.
- For suppliers and service providers: assess whether the work could constitute material support for covered ICC activity or a blocked person under the order’s criteria. A Court-related contract alone does not answer that legal question.
- For organizations and their affiliates: examine ownership, control and agency relationships, as the order includes entities owned or controlled by, or acting for, a blocked person within its designation criteria.
- For people considering travel: the order’s entry provisions apply to specified aliens and immediate family members, subject to its terms and exceptions; property sanctions and entry restrictions should not be conflated.
The ICC described the reach more broadly in a June 2025 press release, saying the sanctions “are not only directed at designated individuals, they also target all those who support the Court, including nationals and corporate entities of States Parties.” That is the Court’s characterization of the measures’ effects. It should be read alongside, not substituted for, the order’s operative criteria and OFAC’s implementation.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What the ICC and Assembly say about the impact
The Assembly of States Parties Presidency characterized the measures as attempts to impede the Court and warned that they risk undermining investigations and international accountability. This is the Assembly Presidency’s assessment, not an independent measurement of the effect on each investigation, partner or transaction.
In its financial statement, the ICC treated the 2025 executive orders as events after its December 31, 2024 reporting date. It said it was evaluating potential effects, that financial exposure could not be reliably estimated, and that management was monitoring developments to mitigate potential operational impacts. The statement also recorded authorization for exceptional use of the Contingency Fund for resources that might be needed if sanctions affected business continuity. This documents concern and contingency planning; it does not provide a quantified estimate of eventual losses.
In a statement dated August 19, 2026, the ICC said that nine of the Court’s eighteen judges, both deputy prosecutors, the former prosecutor and one staff member had been sanctioned. That is the Court’s reported count on that date, not an independently compiled tally of every sanctioned person or a count of affected partners. The same statement said the Court would continue its work with independence and impartiality. The reviewed material does not quantify current aggregate operational costs, establish effects on every partner or show that all ICC work stopped.
How this differs from older U.S. restrictions on ICC cooperation
The American Servicemembers’ Protection Act (ASPA), codified in Title 22 of the U.S. Code, contains provisions concerning cooperation with the ICC and restrictions on using certain U.S. assistance. The statute also contains exceptions relating to investigations and prosecutions concerning Ukraine. These pre-existing statutory rules are distinct from Executive Order 14203’s sanctions program: ASPA addresses specified cooperation and assistance, while the executive order sets blocking, transaction and designation criteria. They should not be collapsed into a single rule.
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Practical checks before an ICC-related transaction
- Identify every relevant party. Check the parties, intermediaries, owners, beneficiaries and any person on whose behalf the transaction is conducted against current OFAC materials.
- Read the applicable rules, not just the headline. Assess whether the transaction involves blocked property or a blocked person, or whether the facts raise a question under the order’s criteria for designation. The connection to the ICC by itself does not decide the issue.
- Verify any authorization. Review the full text of a general or specific license for its covered parties, activities, conditions and dates. A wind-down license is not general permission to continue the relationship.
- Get case-specific advice where needed. Because the list, licenses and rules may change, organizations facing a material exposure question should consult qualified sanctions counsel before proceeding.
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