US sanctions ICC judges including former UN sanctions Ombudsperson Kimberley Prost

21 August 2025

The US yesterday designated 2 judges and 2 deputy prosecutors under its International Criminal Court (ICC) sanctions – press release. Our US ICC sanctions page has more information on sanctions against the ICC. The designations are under EO 14203, which authorises sanctions on those said to have engaged in the ICC’s ‘transgressions’ against the US and Israel. These designations follow the earlier designation in June 2025 of 4 other ICC judges and the ICC Prosecutor Karim Khan in February 2025.

The judges are:

• Kimberly Prost, designated for “ruling to authorize the ICC’s investigation into US personnel in Afghanistan”. Judge Prost was appointed to the ICC in 2018. Before her appointment, she was the first Ombudsperson for the UN Security Council Al Qaida Sanctions Committee created as a result of the EU Kadi litigation. She advised the UN Security Council on delisting applications and developed the due process of UN designations. Judge Prost was Chef de Cabinet for the ICC’s President, judge of the International Criminal Tribunal for the Former Yugoslavia, and a member of the Canadian delegation negotiating the Rome Statute of the International Criminal Court.  

• Nicolas Yann Guillou for “ruling to authorize the ICC’s issuance of arrest warrants for Israeli Prime Minister Benjamin Netanyahu and former Minister of Defence Yoav Gallant”. Judge Guillou was elected as Judge of the ICC in 2024. He had previously served as Pre-Trial Judge at the Kosovo Specialist Chambers, as Chef de Cabinet to the President of the Special Tribunal for Lebanon, and as Liaison Prosecutor at the US Department of Justice, where he worked on judicial cooperation in civil and criminal matters.

The deputy prosecutors are Nazhat Shameem Khan and Mame Mandiaye Niang. They are both designated for “continuing to support illegitimate ICC actions against Israel, including upholding the ICC’s arrest warrants targeting Prime Minister Netanyahu and former Defense Minister Gallant since they assumed leadership for the ICC’s Office of the Prosecutor”.

OFAC issued a general licence authorising the wind down of transactions involving Prost, Guillou, Khan and Niang until 12.01am eastern daylight time on 19 September 2025.