Treasury Allows Quick Wrap-Up of ICC Sanctions Deals
Published Date: 12/12/2025
Rule
Summary
The Treasury’s Office of Foreign Assets Control (OFAC) gave a special green light (General License 9) to wrap up business with five specific people blocked under International Criminal Court sanctions. This permission was valid from August 20 to September 19, 2025, letting folks finish up deals but only if payments went into frozen U.S. accounts. If you’re dealing with these folks or their companies, you had a limited time to act without breaking the rules.
Analyzed Economic Effects
2 provisions identified: 1 benefits, 1 costs, 0 mixed.
Temporary wind-down authorization for five persons
If you were doing business with Nicolas Yann Guillou, Nazhat Shameem Khan, Mame Mandiaye Niang, Kimberly Prost, or any entity 50% or more owned by them, OFAC authorized you to wind down transactions from August 20, 2025 through 12:01 a.m. eastern daylight time on September 19, 2025. Any payment to those blocked persons had to be made into a blocked interest-bearing account located in the United States.
No wind-down authorization for other blocked persons
The general license did not authorize wind-down transactions for any blocked person other than the individuals and entities listed in the license. Transactions involving other persons blocked under the International Criminal Court-Related Sanctions Regulations remained prohibited unless separately authorized by OFAC.
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