Notice with Regard to International Criminal Court-related Sanctions

Date issued: May. 15 2026

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TURBOFAC Commentary (168 words)

Notes:

1) See L.C. v. Trump (1:26-cv-00688) (D.D.C. 2026) - Memorandum & Opinion (May 13, 2026) for the opinion and order (in PDF) to which this notice relates. As of the date of the publication of the “notice,” Albanese remained on the SDN List. This is the first of these “notices” of which we are aware, and it is not clear what it means for (i) the unblocking of property of Albanese and (ii) prospects for retroactive enforcement in the event that the order is overturned on appeal (OFAC says “[t]he designation of Francesca Albanese is not being implemented or enforced while this order remains in effect,” but what about enforcement while the order is not in effect in connection with transactions that occurred while the order was in effect)?

2) On 5-20-26, Albanese was...