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ICC registrar presses European Commission for urgent guidance on US sanctions

Osvaldo Zavala Giler says Commission's silence leaves firms and NGOs unable to judge compliance risks before April deadline.

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Pierre Dubois
· 2 min read
The International Criminal Court building in The Hague, Netherlands · Photo: Thomas Wolf, www.foto-tw.de / Wikimedia Commons (CC BY-SA 3.0 de)

The International Criminal Court's registrar has called on the European Commission to act "as soon as possible" to clarify how private companies and NGOs should respond to US sanctions targeting the Hague-based court.

Osvaldo Zavala Giler told POLITICO that the Commission's "lack of clarity" left those organisations unable to assess their legal exposure. The Trump administration imposed an escalating sanctions regime beginning in February 2025, then announced blanket restrictions on 9 October. The new measures are set to take effect in April next year.

EU foreign policy chief Kaja Kallas, who visited the court's headquarters, told the European Parliament earlier this week that Brussels would use the coming months "to open dialogue" on the issue. Zavala Giler cautioned that the space for dialogue should not become a space for inaction.

To prepare for the restrictions, the court spent six months replacing US technology providers with open-source alternatives and 20 months restructuring its financial transactions to remove any US nexus — eliminating US persons, banks or currency from payments and requiring all staff to hold European bank accounts.

Zavala Giler said continued dependence on US platforms remained a vulnerability. Even where current sanctions include a carveout for telecommunications, he said that guarantee could be revoked at any time, describing it as "a sort of Damocles sword on top of our head."

The EU has repeatedly backed the court against Washington but has so far declined to activate a blocking mechanism that would prohibit firms from complying with US law.

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