International Criminal Court-related General License 14, "Authorizing Certain Transactions Related to Telecommunications and Enterprise Software Involving the International Criminal Court"

Date issued: Oct. 09 2026

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TURBOFAC Commentary (402 words)

Notes:

1) One of four GLs issued concurrent with the designation of the ICC (ICC-related General License 13; ICC-related General License 14; ICC-related General License 15 andICC-related General License 16). See designation-related Fact Sheet at https://web.archive.org/web/20261010071446/https://www.state.gov/releases/office-of-the-spokesman/2026/10/imposing-sanctions-on-the-international-criminal-court-2/.

2) Rare GL authorizing “ordinarily incident and necessary to the receipt or transmission of telecommunications involving” a blocked entity that is not a telecommunications services provider. Query whether OFAC would intend this to enable telecommunications services providers to offer services to the ICC where the ICC is the end user. See General Note on General Licenses for Transactions Related to Telecommunications and Mail. Considering that this GL sits alongside the broader internet services and unique enterprise software GLs, one would expect that the provision of non-internet based...