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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Key Dates
Department and Agencies
Related Federal Register Documents
2026-16573, Notice of OFAC Sanctions Action
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons that have been placed on OFAC's Specially Designated Nationals and Blocked Persons List (SDN List) based on OFAC's determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.
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2026-15996, Notice of OFAC Sanctions Action
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2026-15785, Notice of OFAC Sanctions Action
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2026-15356, Notice of OFAC Sanctions Action
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing the names of one or more persons that have been placed on OFAC's Specially Designated Nationals and Blocked Persons List (SDN List) based on OFAC's determination that one or more applicable legal criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.
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Previous: 2025-22655, Publication of International Criminal Court-Related Sanctions Regulations Web General License 9
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.
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