Commission tells EU operators to continue serving the ICC despite U.S. sanctions

On October 23, 2026, the European Commission issued a notice telling EU operators to continue providing services to the International Criminal Court while diplomatic efforts seek reversal of U.S. sanctions. The notice relied on U.S. general licences, including one running through April 7, 2027, and specifically identified SEPA payments as European infrastructure that should continue supporting the Court. Banks, technology providers and professional-services firms now need documented conflict-of-laws analysis rather than a blanket de-risking response, including the scope of licences, EU blocking considerations and escalation responsibility. The notice is guidance rather than a judicial resolution of the transatlantic conflict, so firms should preserve decision records and monitor licence changes closely.