Serving a blocked institution: ICC vendors and four different licenses
OFAC's ICC designation comes with four licenses. Vendors and banks need to match the service, the payment and the other parties to the right permission.
Sanctions · 10 Oct 2026
A software subscription, a facilities invoice and a pension payment can all involve the same institution while requiring different sanctions analysis. On October 9, OFAC added the International Criminal Court to its blocked-persons list and issued four licenses addressing different activities. For a vendor or bank with U.S. exposure, the operational task is to identify which permission covers the work and its payment path before continuing performance. The institution's name alone does not supply that answer.
What happened
OFAC's October 9, 2026 action added the International Criminal Court in The Hague to the Specially Designated Nationals and Blocked Persons List. It also announced ICC-related General Licenses 13, 14, 15 and 16.
The licenses authorize specified transactions otherwise prohibited under the ICC sanctions program. Their conditions differ. A payment connected to an authorized service still needs to fit the relevant license, including its treatment of blocked accounts and other blocked parties.
Maintaining operations under GL13
General License 13, paragraphs (a)–(c), authorizes transactions ordinarily incident and necessary to maintaining or winding down operations, contracts or other agreements involving the ICC through 12:01 a.m. eastern daylight time on April 7, 2027. Its examples include States Parties' payments, salaries, health insurance and medical services for employees, grantees or contractors; rent, utilities, taxes and insurance; and routine commercial services such as subscriptions.
The license also covers payments on invoices for transactions authorized by paragraph (a), or invoices incurred before October 9, 2026. The invoice date and the underlying activity should both be identified; the word "invoice" alone is not an unrestricted payment authorization. ICC blocked accounts may be used, debited or credited for transactions authorized by paragraph (a). GL13 excludes transactions otherwise prohibited under the ICC regulations, including those involving a different blocked person unless separately authorized. A routine-service description should therefore be checked against both the work and the parties involved.
Telecommunications and enterprise software under GL14
General License 14, paragraphs (a)–(e) and Notes 1–2, addresses telecommunications, services incident to communications over the internet, and enterprise software involving the ICC. Internet examples include email, collaboration platforms, video conferencing, authentication, web hosting and domain registration. The enterprise-software authorization covers its provision, acquisition, development, implementation, operation, maintenance or repair. The definition includes management, payroll, procurement and cybersecurity software, plus cloud services and Software-as-a-Service supporting the listed functions.
GL14 permits use, debits and credits of ICC blocked accounts for its authorized transactions, with a separate exclusion for otherwise prohibited dealings. It contains no stated expiration date. That does not promise the permission will remain unchanged. Note 2 expressly preserves other federal requirements, including Commerce Department export licensing requirements. The OFAC instrument alone does not establish that an export, reexport or transfer satisfies those requirements.
For a software provider, scope the actual functionality, implementation work and payment rather than treating every technology service as interchangeable. This is a practical review recommendation, not an additional condition written into GL14.
Pensions and detention involve narrower conditions
General License 15, paragraphs (a)–(c), authorizes transactions ordinarily incident and necessary to processing pension payments involving the ICC. Any payment to a blocked person must go into a blocked interest-bearing account in the United States, in accordance with the ICC regulations. It also permits specified use of ICC blocked accounts and preserves its exclusion for otherwise prohibited transactions. Processing a pension is therefore different from making unrestricted funds available to its recipient.
General License 16, paragraphs (a)–(c) and the Annex, covers transactions involving the ICC ordinarily incident and necessary to the continued detention of the nine individuals named in its Annex. It includes health, safety and welfare services and operation of their detention facilities. It is not an authorization for services concerning every detainee. The ICC blocked-account permission and exclusion for otherwise prohibited transactions also apply. GL15 and GL16 contain no stated expiration dates.
What this means for you
For company counsel, procurement and treasury, the useful question is which activity, counterparties and funds are covered. A European vendor's U.S. operations, staff or payment arrangements may be relevant to that inquiry; this article does not assume that every European contract falls within U.S. jurisdiction.
Practical steps include:
- Describe the service and related support work precisely, then identify the license paragraph being relied on.
- Identify the contracting party, other participants, payment beneficiary and accounts. Check whether another blocked person changes the analysis.
- Separate GL13's dated permission from the other licenses. Diary its exact cutoff and recheck the applicable instrument before performance or payment.
- Give the bank the same service and license analysis used internally. An authorized service does not answer every question about an invoice or beneficiary.
These are firm control observations. They do not replace the licenses' conditions, a jurisdictional assessment or review of other applicable law.
Reviewing the contract and payment together
You can request a bounded U.S. sanctions review of the service, counterparties and payment path before deciding how to perform the contract. Contact Zimmermann Law to discuss the proposed scope.
This post provides general information, not legal advice. Sanctions analysis is fact-specific and changes over time.
Sources: OFAC, October 9, 2026 action and SDN addition; ICC-related General License 13 (`icc_gl13.pdf`, p. 1); General License 14 (`icc_gl14.pdf`, pp. 1–2); General License 15 (`icc_gl15.pdf`, p. 1); and General License 16 (`icc_gl16.pdf`, pp. 1–2, including the Annex), all dated October 9, 2026. Original PDFs and operative paragraphs read October 9, 2026. The licenses are mandatory U.S. federal authorization instruments within their terms; OFAC's dated list update is primary evidence of the designation. Scope is the four instruments as issued, not an exhaustive current-law or foreign-law review. Practical recommendations are firm observations, not OFAC findings or added legal requirements.
This post is for general information and is not legal advice.
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