Coalition for the ICC launches groundbreaking report on US sanctions: "Criminalising Accountability: The US lawfare against the international justice system"
The Coalition for the International Criminal Court (CICC) publishes its report on US sanctions "Criminalising Accountability: The US lawfare against the international justice system".
Drawing on interviews with all individuals and organisations designated under US Executive Order 14203, as well as subject-matter experts, the report finds that sanctions imposed since February 2025 extend beyond US jurisdiction, excluding those designated from basic banking and IT services with service providers around the world extraterritorially applying sanctions. They even extend beyond those designated, generating a wider chilling effect across the international justice system.
“The greatest risk of sanctions is not to those who have already been sanctioned, but to the hundreds of people who will not take the decisions they need to take because they are afraid” - ICC Judge Nicolas Guillou
The report traces the escalation of sanctions from early 2025, beginning with the designation of the ICC Prosecutor Karim Khan under Executive Order 14203 “Imposing Sanctions on the International Criminal Court”, for his work investigating alleged crimes in Palestine and Afghanistan. It was followed by designations of the two Deputy Prosecutors, eight judges, the UN Special Rapporteur on the occupied Palestinian territories, and Palestinian civil society organisations.
The report explains how sanctions have been used by the Trump administration to unlawfully coerce judicial institutions and prevent any form of accountability. It describes the impact on both designated and the broader justice system, revealing a resilience determined to continue the fight for justice and accountability. It concludes with recommendations that states, institutions, and others should follow to match that resilience with concrete and structural support.
“All interviewees have been very clear. While they remain resilient and undeterred, state parties and the European Union need to take their responsibility and act to protect the Court and international justice. In the face of such a systemic attack, responses have remained ad-hoc, limited and have excluded civil society organisations” - Alison Smith, CICC Director.
The impact of sanctions beyond the US: a threat to justice and states’ sovereignty
Those targeted have faced immediate visa bans and the seizing of any property they held in the US, including ICC Judge Bossa’s US bank account and Francesca Albanese’s home in Washington. “The inconvenience started within 24 hours. I received a message informing me that due to the EO, my account in the US is blocked, and there is nothing I can do about it,” says ICC Judge Bossa.
But the report illustrates how these measures function way beyond US territory and jurisdiction, ultimately challenging states’ sovereignty. Through reliance on US financial infrastructure, the US dollar, US IT and globally dominant US service providers, sanctions restrict access to banking, payment, and essential online services worldwide for those targeted. “The international financial architecture is centred on and facilitates the global use of the US dollar,” highlights FIDH's Antoine Madelin. “That architecture is what gives the United States its leverage”.
In practice, this translates into a sanctioned individual in The Hague being unable to open a bank account, book a flight or a hotel, and a Palestinian human rights organisation having its website and social media accounts closed, reflecting a pattern of over-compliance observed across all sectors and countries.
Due to sanctions, Francesca Albanese’s accounts in the US were closed, and she has been unable to open bank accounts in Italy, Switzerland and the Netherlands. ICC Prosecutor Karim Khan had all his bank accounts in the United Kingdom frozen. Going further in over-complying, the bank account of his ex-wife was frozen after he transferred her money for their children. ICC Judge Hohler had her bank account closed in Slovenia after decades of being a client in that bank. Judge Lordkipanizde had his bank account closed in Georgia, and he was requested to pay back his loan in full, or his property under the mortgage would have been seized.
“I accept that American banks and other US persons may have to comply with the sanctions, but the automatic compliance by some European banks and service providers is extremely worrying” - ICC Judge Hohler
Affecting those targeted differently based on their nationality, those designated are unable to do international bank transfers, leaving Judges and Prosecutors from countries outside of the eurozone unable to send money to their families.
“In Latin America all of our major trading is done in dollars. I cannot even send money in euros or have euro accounts in Peru” - ICC Judge Ibáñez.
The impact on civil society organisations: silencing, isolating and making them unable to operate
The designated organisations, Al-Haq, the Palestinian Centre for Human Rights (PCHR), Al Mezan and Addameer have faced catastrophic impacts. US staff had to immediately resign, US partners stopped working with them, and they lost up to 60% of funding within weeks. They have lost access to their bank accounts, are not able to receive funds, process any payments, and pay their staff or operations. YouTube deleted their accounts with hundreds of videos containing evidence of international crimes.
These restrictions have had severe and immediate consequences for the more than 100 staff employed by the designated organisations and their families. Al-Haq’s Director, Shawan Jabarin, described the impact of such measures, which was felt across all organisations: “It affected all our staff, we are speaking about 45 people, it means that 45 families are affected.”
The chilling effect: the biggest threat to the rule of law
The intention is clear: to “target a few with the aim of impacting the whole”, states Agnès Callamard, Amnesty International Secretary General. The report finds that a significant impact of sanctions lies in their chilling effect. Evidence shows that actors across the international justice system have altered their behaviour in response to risks of designation.
In the US, work on justice and accountability in relation to the situations in Afghanistan and Palestine is effectively criminalised. “[These sanctions] are another example of the US government's abuse of power and repressive action against civil society and human rights bodies,” says Jamil Dakwar, Director of the Human Rights Program at the American Civil Liberties Union (ACLU). Any US person providing material support or services to these investigations, or to designated individuals and organisations, face up to 20 years in prison and heavy fines. Any US person providing material support or services to these investigations, or to designated individuals and organisations, faces up to 20 years in prison and heavy fines. As a result, many organisations in the US and US nationals have stopped working with designated organisations, including essential strategic litigation and advocacy, limited public engagement, and withdrawn from professional exchanges.
The report concludes that this dynamic extends beyond designated individuals, affecting the willingness of legal professionals, civil society organisations and experts to engage in accountability work. It highlights the risk of “invisible” impacts, where decisions not taken, partnerships not formed and evidence not submitted gradually weaken the functioning of the international justice system.
“We Will Never Give Up”: Sanctions Will Not Silence Justice
Despite the challenges, those targeted continue their work undeterred. In their own words:
“I speak for everyone, when I say that these measures are futile and have no effect on our work” - ICC Judge Prost.
An unintended consequence that those imposing sanctions perhaps did not foresee: designated individuals and organisations have refused to be cowed. Driven by their mission and mandate to support victims seeking justice for the most serious crimes, designated individuals and organisations, and the broader ecosystem, have strengthened their resolve and found ways to work around the restrictions unjustly imposed on them.
Prosecutors will continue their prosecutorial policy: “The Rome Statute establishes how we do our work. We would be extremely poor lawyers if we did not abide by it", underlines ICC Deputy Prosecutor Khan.
Judges will continue to apply the law equally: “Some people express the suggestion that in order to survive, the Court should give up certain cases. But to do so would mean compromising the principles of international criminal law and justice” - ICC Judge Damdin.
Judge Alapini-Gansou highlights how: “These measures have no effect on our dedication to our work because we are assigned to this task and we must answer for it. The victims around the world are waiting for us and watching us.”
Solidarity Alone is not Enough: States Must Act
The Court, and the international justice system need support from states. As ICC Registrar Osvaldo Zavala Giler explains: “I am very grateful for political support from states, including in terms of allowing us to find banking solutions, but what happens when political support is not enough? This is why we advocate for the EU blocking statute to be adopted: we need solutions that are more permanent.”
Yet, solutions have remained ad-hoc, limited, and have excluded civil society organisations. “States have to stand for international justice. We are talking about prosecutors, judges, independent experts and civil society actors who have dedicated their lives for victims of mass atrocities, and are now treated like criminals,” concludes Zoe Paris, CICC Advocacy Coordinator.
Recommendations to states include:
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Publicly and firmly denouncing the unlawful sanctions,
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Calling for their immediate revocation,
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Immediately adopting and implementing national and regional blocking legislation,
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Providing legal certainty and protection to service providers through letters and public statements,
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Engaging proactively with banks, financial institutions, IT companies and other service providers, and build and invest in economic sovereignty and financial resilience,
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Ensuring solutions found extend to all those designated, including civil society organisations.
About the Coalition for the International Criminal Court (CICC)
The Coalition for the International Criminal Court is a global network of over 2,500 civil society organisations in more than 150 countries working to strengthen international cooperation with the International Criminal Court and ensure justice for victims of genocide, crimes against humanity and war crimes.
Media contact
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Keila McFarland Dias, Communications and Campaign Manager, Coalition for the International Criminal Court - Email: mcfarlanddias@coalitionfortheicc.org
