Sanctions Paused Briefly for Human Rights Groups' Transactions
Published Date: 12/12/2025
Rule
Summary
The Treasury’s Office of Foreign Assets Control (OFAC) gave a special green light called General License 10 to wrap up business with certain blocked groups linked to the International Criminal Court. This license let people finish transactions with these groups safely until October 4, 2025, as long as payments went into frozen U.S. accounts. If you’re dealing with these groups, you had a clear deadline to follow and keep your money secure.
Analyzed Economic Effects
3 provisions identified: 1 benefits, 2 costs, 0 mixed.
Temporary Wind-Down Authorization
If you were transacting with Al Haq Law in the Service of Mankind, Al Mezan Center for Human Rights, the Palestinian Centre for Human Rights, or any entity 50% or more owned by them, OFAC allowed ordinary and necessary wind-down transactions from September 4, 2025 through 12:01 a.m. eastern daylight time on October 4, 2025. These transactions were otherwise prohibited by the International Criminal Court-Related Sanctions Regulations but were authorized only for that limited period.
Payment Placement Requirement
Any payment to a blocked person under this wind-down authorization had to be made into a blocked interest-bearing account located in the United States, in accordance with the International Criminal Court-Related Sanctions Regulations. You had to follow that account-location and interest-bearing requirement for payments during the authorized wind-down period.
Scope Limitation — Others Still Prohibited
The general license did not authorize transactions involving any person blocked under the ICCSR other than the specific persons named in the license. If you deal with other blocked persons under the ICCSR, those transactions remained prohibited unless separately authorized.
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