U.S. Designates International Criminal Court Under E.O. 14203; OFAC Issues Four General Licenses

In a major development, the U.S. Department of State imposed blocking sanctions on the International Criminal Court (ICC) under section 1(a)(ii)(A) of E.O. 14203 to defend U.S. sovereignty and U.S. citizens against the threat of the ICC. Concurrently, OFAC issued four ICC-related general licenses (GLs). GL 13 authorizes transactions ordinarily incident and necessary to the maintenance or wind down of ICC operations, contracts and agreements, including States Parties’ payments, salaries, rent and utilities, through April 7, 2027, a 180-day window that State says gives States Parties time to show progress on its concerns and can be adjusted. GL 14 authorizes telecommunications, internet-based communications services and enterprise software (including cloud services), GL 15 authorizes pension payments, and GL 16 authorizes the continued detention of nine ICC detainees, including their health, safety and welfare and the operation of detention facilities. GLs 14 to 16 carry no stated expiry.