LICENSE No. ICC-EO14203-1370890-1

Date issued: Jun. 05 2025

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TURBOFAC Commentary (182 words)

Notes:

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...