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On April 1, 2021, President Biden signed Executive Order 14022, revoking Executive Order 13928 “Blocking Property of Certain Persons Associated with the International Criminal Court” (the “ICC EO”), which authorized the imposition of sanctions and visa restrictions on non-US ICC officials. The US Treasury Department’s Office of Foreign Assets Control concurrently removed two senior ICC officials from the Specially Designated Nationals and Blocked Persons List (“SDN List”), including Fatou Bensouda, the ICC’s chief prosecutor.

The ICC EO was signed by President Trump in June 2020, and authorized the designation of non-US persons as SDNs if they were determined to have engaged in efforts by the ICC to investigate, arrest, detain, or prosecute any US or allied government personnel without the consent of the United States or the allied government. In September 2020, OFAC designated the two senior ICC officials as SDNs.

Please see our prior blog post on the signing of the ICC EO in June 2020.


Terry Gilroy is a partner in the New York office of Baker McKenzie and a member of the Compliance and Investigations Practice Group. Prior to joining the Firm in 2018, Terry served as Americas Head of the Financial Crime Legal function at Barclays. Terry advises businesses and individuals on white collar and financial crime issues and has significant experience conducting investigations relating to compliance with the US Foreign Corrupt Practices Act (FCPA) and related bribery and corruption statutes, economic sanctions regulations as administered by the US Department of the Treasury's Office of Foreign Assets Control (OFAC), and the Bank Secrecy Act and related anti-money laundering (AML) regulations and statutes. Terry spent six years on active duty in the United States Army as a Field Artillery officer.


Lise Test, an associate in Baker & McKenzie’s International Trade Group in Washington, DC, practices in the area of international trade regulation and compliance — with emphasis on US export control laws, trade sanctions, anti-boycott laws and the Foreign Corrupt Practices Act. Prior to joining Baker & McKenzie, Ms. Test served as a lawyer at the Danish Ministry of Defence where she focused on international public law and Danish torts, administrative law and military criminal law. In addition to her practice, Ms. Test also taught international humanitarian law and contract law at the Danish Royal Naval Academy.


Daniel Andreeff is an associate in the Firm’s International Trade practice group in Washington, DC. Prior to joining the Firm, he interned with the Department of the Treasury’s Office of Foreign Assets Control.