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Executive Order 14203 blocks property interests of people designated under its terms, bars certain transactions involving blocked persons, and allows further designations tied to specified International Criminal Court (ICC) activity or support. It also restricts U.S. entry for certain people associated with the Court. These measures can create legal and practical risks for ICC personnel, partners, suppliers, and financial intermediaries, but the order does not say that every organization that works with the ICC is automatically sanctioned. The specific criteria, any designation, and applicable licenses matter.
What Executive Order 14203 does
President Donald Trump signed Executive Order 14203 on February 6, 2025. The order invokes the International Emergency Economic Powers Act (IEEPA), the National Emergencies Act, immigration-law authority, and other presidential authority. It initially named ICC Prosecutor Karim Khan in its annex.
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The order describes 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. That is the order’s stated rationale, not a neutral finding about the Court or its proceedings.
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Property and transaction restrictions
The order blocks property and interests in property belonging to a blocked person when they are in the United States, later come within the United States, or come within the possession or control of a U.S. person. It also prohibits specified dealings involving blocked persons, including providing or receiving funds, goods, or services. Evasion, attempted evasion, and conspiracy to violate the prohibitions are separately prohibited.
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In practical terms, a U.S. person must not treat a blocked person as an ordinary counterparty in a transaction unless an authorization or other applicable exception permits it. The order’s terms, implementing rules, and any license govern what a particular transaction may involve.
Who may be designated later
The order sets criteria for designating certain foreign persons, including people who directly engage in specified ICC efforts involving a “protected person”; materially assist or support that activity or a blocked person; or are owned or controlled by, or act for, a blocked person. The support criteria encompass financial, material, and technological support, as well as goods or services for covered activity or a blocked person.
“Protected person” is a defined term, not a synonym for every American or every person from an allied country. It includes U.S. persons subject to conditions stated in the order, and certain foreign citizens or lawful residents of NATO or major non-NATO allies. For the latter group, the order’s conditions include whether the person’s country has consented to ICC jurisdiction over that person or is a Rome Statute State Party. Covered categories include current and former military members, government officials, and people employed by or working on behalf of the specified governments.
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The order defines an immediate family member as a spouse or child. A relationship with the ICC, by itself, is not listed as an automatic basis for designation: the order’s specified criteria and any subsequent government action must be considered.
Entry restrictions
Separate from the property and transaction rules, the order 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. The order includes stated exceptions. It also excepts transactions conducted for official U.S. government business by government employees, grantees, or contractors; that exception should not be read as a general authorization for other dealings.
What the rules mean for ICC partners
A partner, supplier, financial institution, technology provider, or other service provider may need to assess whether its conduct or a particular transaction falls within the order’s criteria or involves a blocked person. Exposure depends on the facts, the person or entity involved, the nature of the support or transaction, applicable regulations, and any license. The order’s criteria include support for specified activity or a blocked person and entities owned or controlled by, or acting for, blocked persons. They do not make all ICC partners blocked solely because they work with the Court.
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The ICC has described the reach of the measures more broadly. In a June 2025 press release, the Court said the sanctions “also target all those who support the Court, including nationals and corporate entities of States Parties.” That is the ICC’s characterization of the measures’ effects; the order’s specific legal criteria remain the relevant text for assessing a designation or transaction.
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How OFAC administers the program
The U.S. 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 in the program’s legal framework. OFAC publishes sanctions lists, frequently asked questions, and license information.
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General and specific licenses
A general license authorizes the activities it describes for U.S. persons without a separate specific-license application. A specific license is authorization for a transaction that would otherwise be prohibited. Neither label is a blanket permission: the license’s terms, covered persons, transactions, and time limits determine its scope.
OFAC’s August 18, 2026 notice announced designations of ICC President Tomoko Akane and Office of the Prosecutor Senior Trial Lawyer Abdoulaye Seye, and issued General License 12 for a wind-down of transactions involving certain persons blocked on that date. A wind-down authorization is limited to its terms; it should not be treated as permission for continuing business or as covering every blocked person or transaction.
The ICC said on August 19, 2026, that nine of its eighteen judges, both deputy prosecutors, the former prosecutor, and one staff member had been sanctioned. This is the Court’s count as of that statement, not a count of every sanctioned person or partner. Because designations and licenses can change, anyone assessing a real transaction should check OFAC’s current program materials, current Specially Designated Nationals (SDN) List, and the actual license text, and obtain qualified sanctions counsel where appropriate.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What is known about operational and financial effects
The ICC’s financial statement treated the 2025 orders as events after its December 31, 2024 reporting date. The Court said it was evaluating potential effects, could not reliably estimate its financial exposure, and was monitoring developments to mitigate potential operational impacts. It also recorded authorization for exceptional use of its Contingency Fund for resources that might be needed if sanctions affected business continuity. Those disclosures show recognized uncertainty and continuity concerns at that time, not a quantified estimate of eventual losses.
The ICC has said it will continue its mandate. In its August 19, 2026 statement, it said it would continue its work with independence and impartiality despite the designations. The materials cited here do not quantify current overall operational costs, establish effects on every partner, or show that all Court work stopped.
How the sanctions relate to older U.S. restrictions
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 includes exceptions relating to investigations and prosecutions concerning Ukraine. Those pre-existing statutory restrictions are distinct from Executive Order 14203: ASPA addresses specified cooperation and assistance, while the executive order establishes sanctions criteria and related prohibitions. They should not be collapsed into a single rule.
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What to check before a transaction
- Identify the people and entities involved. Check the current OFAC SDN List and determine whether any party is blocked or owned or controlled by, or acting for, a blocked person under applicable rules.
- Map the transaction and support. Identify what funds, goods, services, technology, or other assistance would be provided or received, by whom, and in connection with what activity.
- Apply the order’s actual criteria. Do not assume that ICC affiliation alone resolves the question. Consider whether the conduct or relationship falls within a defined designation criterion or a prohibition involving a blocked person.
- Read any claimed authorization in full. Confirm that a general or specific license covers the relevant parties, conduct, dates, and transaction, and comply with its conditions.
- Get advice for the particular facts. The rules are legally and factually specific; use current OFAC materials and qualified legal advice rather than relying on a general description of the program.
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