# Executive Order 14203 Signed 6 February 2025, *Imposing Sanctions on the International Criminal Court* authorizes asset freezes and entry bans against officials of the [[International Criminal Court]] and those who assist its investigations of the United States or its allies. It is the instrument that moved American opposition to the Court from non-participation to active punishment of its personnel. The order builds on precedent from the first Trump term, when the administration sanctioned then-Prosecutor Fatou Bensouda over the Court's Afghanistan investigation and the Biden administration subsequently lifted those designations. What distinguishes EO 14203 is scale and durability: the designations have accumulated across seven tranches over eighteen months and now reach a third of the Court's bench. ## Designation Tranches | Date | Designated | |---|---| | 2025-02-13 | Prosecutor Karim Khan | | 2025-06-05 | Four individuals | | 2025-07-09 | UN Special Rapporteur Francesca Albanese | | 2025-08-20 | Four individuals | | 2025-09-04 | Three entities | | 2025-12-18 | Judges Gocha Lordkipanidze (Georgia) and Erdenebalsuren Damdin (Mongolia) | | 2026-05-27 | ICC-related designation | | 2026-08-18 | ICC-related designations, plus one general license | | 2026-10-09 | **The International Criminal Court itself**, added to the SDN list as an entity under tag `[ICC-EO14203]` | The December 2025 pair is the most legible: the State Department cited the judges' votes on the 15 December ruling that rejected Israel's challenge to the Netanyahu and Gallant warrants. The designation followed the ruling by three days. Whatever the order's stated rationale, that sequence establishes what the program does in practice — it attaches a personal financial cost to a judicial vote. **Cumulative individual designations as of 11 August 2026:** eight ICC judges, former Prosecutor Karim Khan, two deputy prosecutors, Francesca Albanese, and three Palestinian human-rights NGOs — Al-Haq, Al Mezan, and the Palestinian Centre for Human Rights. ## The Institutional Turn, 9 October 2026 On **9 October 2026** the program stopped sanctioning the Court's people and sanctioned the Court. OFAC added the [[International Criminal Court]] to the Specially Designated Nationals list as an entity, at its Hague address, under this order's authority. Four general licenses issued the same day — **GL 13** (certain transactions involving the Court), **GL 14** (telecommunications and enterprise software), **GL 15** (pension payments) and **GL 16** (certain ICC detainees) — define what survives the designation. Reporting on the action describes blocked assets under US jurisdiction, a general bar on US persons and companies transacting with the Court, a prohibition on dollar dealings, and a **180-day wind-down** offered as negotiating room for the Court's 125 states parties. [[Marco Rubio]] announced it: "Either the ICC will end its threats, or we will end the ICC." The escalation is legible in one line. Eighteen months of tranches attached a personal cost to individual judicial votes; this one attaches an institutional cost to the Court's continued existence as a going financial concern. It also lands the same day the 2026 Nobel Peace Prize went to [[Navi Pillay]], who sat on that bench from 2003 to 2008 — a coincidence of calendar, and the sharpest available snapshot of two systems valuing the same institution in opposite directions. > [!warning] Litigation exposure now runs to the designation itself > The two pending challenges below were filed against designations of individuals. Whether the reasoning in either reaches an entity designation of a treaty-based international court is untested. ## The Albanese Sequence The litigation over Francesca Albanese's designation is the clearest window into the program's legal exposure, and it happened fast: 1. **February 2026** — suit filed challenging the designation. 2. **13 May 2026** — Judge Richard Leon (D.D.C.) grants a preliminary injunction on First Amendment grounds. 3. **21 May 2026** — OFAC delists her. 4. **24 May 2026** — a D.C. Circuit panel issues an administrative stay. 5. **27 May 2026** — OFAC re-designates her. She remains sanctioned pending appeal. The government lost on the merits at the district level and restored the designation within a fortnight through appellate procedure — a pattern worth noting for anyone tracking how this administration metabolizes adverse rulings. ## The August 2026 Challenge On 11 August 2026 the American Friends Service Committee, the Center for Constitutional Rights, [[Human Rights Watch]], and the Open Society Institute filed a broad constitutional challenge to EO 14203 in the Southern District of New York, naming [[Donald Trump]] and senior officials. The core claim is that the order's prohibition on providing "services" to designated persons criminalizes protected speech and association by Americans who work with the Court. Two active cases now run against the program — the Albanese appeal in the D.C. Circuit and this one. A ruling either way is a significant 2026–27 story. > [!warning] Live litigation > Both cases were pending as of 13 August 2026. Anything written here about outcomes will go stale; check the docket before citing. In January 2026 a UN special rapporteur formally demanded withdrawal of the sanctions and repeal of the order. ## Why It Matters Here Sanctions are an instrument built for hostile states, terrorist financiers, and transnational criminal networks. EO 14203 points that instrument at judges — including judges of a court the United States helped design the law for, sitting in an allied democracy, applying a treaty ratified by 125 states. The move fits a pattern the vault tracks across domains: where an institution's authority cannot be legally denied, attack the personnel who exercise it. The through-line runs from [[Schedule F]] and the civil service, through the campaign against prosecutors and judges documented across the [[Trump Retribution Ecosystem]], to the Hague. The target changes; the theory — that constraints on executive power are illegitimate and their enforcers are fair game — does not. ## See Also - [[International Criminal Court]] — the target institution, designated as an entity on 9 October 2026 - [[Navi Pillay]] — ICC judge 2003–2008, 2026 Nobel Peace Prize laureate - [[Rome Statute]] — the treaty the US never ratified - [[Executive Order 14199]] — the companion order on UN bodies, signed two days earlier - [[2026 International Organizations Withdrawal Memorandum]] — the escalation a year later - [[Sanctions Designation Pipeline]] — the machinery every tranche above ran through, and the delisting and judicial-review posture the designees face - [[International Law Hub]] — the folder MOC - [[American Exceptionalism]] — the doctrine underwriting the position