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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Key Dates
Department and Agencies
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Previous / Next Documents
Previous: 2025-22653 — Publication of Russian Harmful Foreign Activities Sanctions Regulations and Ukraine-/Russia-Related Sanctions Regulations Web General License 125
The U.S. Treasury’s Office of Foreign Assets Control (OFAC) published General License 125, allowing certain transactions that are usually banned under Russia-related sanctions to support official U.S.-Russia meetings in Alaska. This special permission started on August 13, 2025, and lasts until August 20, 2025. It helps government officials meet without breaking sanctions, but doesn’t allow releasing blocked property or other forbidden actions.
Next: 2025-22656 — Publication of International Criminal Court-Related Sanctions Regulations Web General License 10
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.
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