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LICENSE No. ICC-EO14203-1370890-1
LICENSE
Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, Pub. L. 113-278, and Executive Order 14203.
To: Association of International Criminal Law Prosecutors
c/o Jason Wright
Steptoe LLP
1114 Avenue of the Americas
New York, NY 10036
1. Based upon your request dated April 7, 2025, on behalf of the Association of International Criminal Law Prosecutors, to the Office of Foreign Assets Control (the “Application”), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and instructions issued under any of the authorities cited above.
3. This License expires on June 30, 2027, and is not transferable. The transactions...
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1) Albeit in a context in which the license applies to a narrow subset of individuals (i.e. “members of the Association of International Criminal Law Prosecutors”), this SL authorizes a fairly broad range of otherwise prohibited transactions vis-à-vis the ICC. Read in conjunction with Rona v. Trump, 1:25-cv-03114, (S.D.N.Y.) - Order on Motion for Preliminary Injunction (Dkt. 70) and Smith v. Trump (1:25-cv-00158) (D. Maine 2025) - Order on Motion for Preliminary Injunction (Dkt. 30) (U.S. courts ruling that enforcing EO 14203 against U.S. person litigants in connection with transactions similar to those licensed by this SL would be unconstitutional). The constitutional issues (pending but not yet decided at the time the SL was issued) are likely why the SL is issued “the extent authorization is required”.
2) Many...