The US government is preparing institutional sanctions against the International Criminal Court (ICC) that could restrict most transactions involving the court. The measures are expected to include a six- to seven-month transition period. If adopted, they would mark the first time Washington has expanded sanctions from ICC personnel to the institution itself, potentially disrupting salaries, supplier payments and witness-related expenses.
Why Dollar Clearing Matters to the ICC
A February 2025 executive order signed by the Trump administration declared that the ICC's investigations involving US and Israeli nationals constituted a national emergency. In November 2024, the court issued arrest warrants for Israeli Prime Minister Benjamin Netanyahu and former Defence Minister Yoav Gallant over allegations linked to the war in Gaza. Israel does not recognise the court's jurisdiction.
The US has since placed some ICC judges and prosecutors at The Hague on its sanctions list. In August 2026, it also designated ICC President Tomoko Akane. The measures have led to some staff members' bank accounts being closed and credit cards cancelled. ICC judge Kimberly Prost said the central problem was uncertainty: issues that initially appeared to be minor inconveniences could accumulate over time.
Dollar payments generally pass through US correspondent banks. Even when both parties are outside the United States, overseas banks may avoid a sanctioned entity to protect their access to dollar settlement. If the sanctions are extended to the ICC as an institution, salaries, supplier invoices and witness expenses paid in other currencies could also face additional bank reviews or settlement restrictions.
Stablecoins Are Not a Guaranteed Workaround
Dollar-backed stablecoins can theoretically transfer value without a conventional bank account, making them a possible alternative payment channel. US rules, however, place specific limits on that route.
In April 2026, the US Treasury issued rules under the Guiding and Establishing National Innovation for US Stablecoins Act, known as the GENIUS Act. Licensed stablecoin issuers must have the technical ability to block, freeze and reject transactions. They must also screen wallet addresses for entities listed by the US Office of Foreign Assets Control (OFAC).
Stablecoin issuers had already been using similar controls before the rules took effect. In April 2026, Tether worked with OFAC to freeze about $344 million in USDT on the Tron network, the company's largest single freeze. Tether Chief Executive Paolo Ardoino said at the time that USD₮ would not become a safe haven for illegal activity and that the company would act when it identified credible links to sanctioned entities or criminal networks.
Tether had previously frozen wallets linked to Iran, while the US directly sanctioned two UK-based cryptocurrency exchanges in February 2026. These cases show that, although stablecoins operate on blockchains, their issuers remain centralised entities capable of enforcing US sanctions policy.
Bitcoin Still Depends on Fiat Off-Ramps
Bitcoin has no issuer and no single control mechanism that can directly freeze accounts on the network. Technically, that distinguishes it from dollar stablecoins managed by an issuer. But holders generally still need an exchange, custodian or bank to convert bitcoin into euros or dollars.
Regulated trading platforms and financial institutions are required to screen customers and transactions against sanctions lists. Bitcoin therefore does not automatically remove restrictions at the fiat off-ramp. For the ICC and its staff, the key issue is not only whether assets can move on-chain, but also whether counterparties, custodians and the final settlement bank are willing to process the funds.
The final text of the proposed measures, their scope and the ICC's ability to use alternative financial channels remain unclear. What is clear is that the dollar correspondent-banking system, stablecoin issuers' freezing powers and compliance checks at the point where crypto is converted into fiat will all affect the court's ability to maintain day-to-day payments under a sanctions regime.