ICC SDNs Announced

Following up on our earlier reports on two new OFAC sanctions programs, a number of persons have already been designated under the Caesar Act and now we have the first ICC listings.

Executive Order 13928, “Blocking Property of Certain Persons Associated with the International Criminal Court" which initially did not designate any individuals, has been used to add Fatou Bensouda and Phakiso Mochochoko to OFAC's Specially Designated Nationals (SDN) List.  Both individuals are officers of the International Criminal Court (ICC) and responsible for assertions of jurisdiction over U.S. and allied personnel by the ICC, countries which are “are not parties to the Rome Statute or have not otherwise consented to ICC jurisdiction.”

It is not clear whether any additional individuals or entities will be added under the ICC sanctions program, but the SDN list (which reflects many OFAC sanctions programs) and other sanctions lists are subject to change on a daily basis, making continuous screening a business necessity.