Imposing Sanctions on the International Criminal Court
The order declares a national emergency under IEEPA and immediately imposes asset freezes and U.S. entry bans on International Criminal Court officials, employees, and agents who pursue investigations or arrests of American or allied military and government personnel, along with their spouses and children.
It marks the first use of IEEPA against the ICC, placing the court's personnel under the same financial-sanctions and travel-ban architecture typically reserved for foreign adversaries and terrorist networks.
What this order does
What it orders
The order declares a national emergency under IEEPA and the National Emergencies Act, finding that ICC actions — including arrest warrants for Israeli leaders — constitute an extraordinary threat to U.S. national security and foreign policy. It immediately blocks all U.S.-held property and assets of ICC officials named in an attached annex and authorizes the Secretary of State to designate additional foreign persons who assist ICC efforts to investigate, arrest, or prosecute U.S. or allied military and government personnel without their country's consent. It also suspends U.S. entry for all ICC officials, employees, and agents, along with their immediate family members.
The order carves out an exception for official U.S. government business transactions and allows the Secretary of State to waive individual entry bans when admission would serve U.S. interests, including law enforcement. The Secretary of the Treasury is authorized to write implementing rules under IEEPA and must report to the President within 60 days on additional candidates for designation. No prior notice to designated persons is required before their assets are blocked.
Who it affects
ICC officials, employees, and agents listed in the order's annex or subsequently designated by the Secretary of State, along with their spouses and children, face asset freezes and U.S. entry bans. Foreign individuals and entities that materially support covered ICC actions are also subject to designation.
Why it matters
ICC officials and their immediate families lose access to U.S.-held financial assets and cannot enter the United States from the moment of designation. Any U.S. person or company that transacts with a designated ICC official risks violating the sanctions regime and facing penalties under IEEPA.
What must happen and when
How the order is supposed to work
The Secretary of State designates sanctioned individuals in consultation with Treasury and the Attorney General; Treasury then implements asset freezes using IEEPA rulemaking authority and may redelegate functions within the department. The Secretary of State controls entry waivers and consults Homeland Security on admissibility questions. All executive agencies must support implementation. Treasury must report to the President within 60 days on expanded designations and submit recurring congressional reports required by IEEPA and the National Emergencies Act. No advance notice to targets is required before assets are frozen.
Actions and deadlines
- Submit report to the President on additional persons who should be sanctioned under this order
- Secretary of Treasury to adopt rules and regulations implementing IEEPA-based asset-blocking provisions
- Secretary of State to implement the entry suspension program for ICC officials and their immediate family members
- Secretary of Treasury to submit recurring and final reports to Congress on the declared national emergency