US Sanctions Al-Haq, Al Mezan and the Palestinian Centre for Human Rights Under ICC Sanctions Order (September 2025)

What Happened

On 4 September 2025 the Treasury Department's Office of Foreign Assets Control (OFAC) added three Palestinian human rights organisations to its list of Specially Designated Nationals:

• Al-Haq – Law in the Service of Mankind, Ramallah, founded in 1979;
• Al Mezan Center for Human Rights, Gaza City, founded in 1999;
• Palestinian Centre for Human Rights, Gaza City, founded in 1995.

Each listing carries the tag [ICC-EO14203], the sanctions programme created by Executive Order 14203 of 6 February 2025. That order blocks the property of foreign persons found to have "directly engaged in any effort by the ICC to investigate, arrest, detain, or prosecute a protected person", defined to include US persons and citizens or residents of US allies that have not consented to ICC jurisdiction or are not States Parties, or to have materially assisted such efforts (Federal Register). OFAC also issued ICC-related General License 10, authorising a wind-down of transactions with the three groups (OFAC).

The State Department announced the action under the title "Sanctioning Foreign NGOs Directly Engaged in ICC's Illegitimate Targeting of Israel" (linked from OFAC's notice). By invoking EO 14203, the US determined that the three groups had engaged in or assisted ICC efforts concerning Israeli nationals. They are among the most prominent Palestinian organisations documenting alleged violations in Gaza and the West Bank.

Human Rights Watch called the move "a cruel and vindictive effort to punish those simply advocating for victims of serious crimes", and described the three as "widely respected" (HRW).

Earlier ICC sanctions targeted the Court's own officials; see the ICC sanctions entry.

Legal Analysis

What designation does. Blocking sanctions freeze any property of the designated organisations that is in the US or held by US persons, and generally prohibit US persons from providing funds, goods or services to them. In practice they cut organisations off from banks that clear dollars, from US donors and foundations, and from partners worried about secondary exposure.

Obstruction of international accountability. The stated reason for these designations is the groups' engagement with an international court. Palestine is an ICC State Party, and the Court has an open investigation into its territory. Sanctioning the organisations that gather and submit evidence to that investigation targets the evidence base of an international accountability mechanism. Article 70 of the Rome Statute makes it an offence to impede or retaliate against witnesses or those who assist the Court, but it applies to individuals and has not been invoked here, and the US is not a State Party. This entry does not treat it as an international crime.

Freedom of expression and association. Punishing organisations for advocacy, documentation and communication with an international body engages Articles 19 and 22 of the ICCPR. The US disputes that the ICCPR applies outside its territory, which weakens the treaty argument for foreign organisations, though the effect on US donors and partners is domestic.

Strongest defence argument. The US says the ICC lacks jurisdiction over Israeli nationals because Israel is not a State Party, that the investigation is "illegitimate", and that the President has statutory authority under the International Emergency Economic Powers Act to impose sanctions to protect US and allied personnel. Domestic legal authority for the sanctions is not the question here. Labelling an international court's investigation illegitimate does not change the fact that the measure is designed to stop victims' advocates from engaging with it.

Why This Grade

This entry is graded critical, with no war-crime classification.

• The critical grade names "obstruction of international accountability mechanisms" as one of its anchors. Sanctioning the main Palestinian organisations that document violations and submit evidence to the ICC, for doing so, fits that description directly.
• The facts are not in dispute: the designations are on the official sanctions list.
• It is not an international crime. No element of an Article 6, 7 or 8 crime is engaged.

Confidence in this grade: high.