Hearing "asset freeze," most people picture a measure that locks up bank accounts and real estate in the United States. But under the US sanctions regulations on the International Criminal Court (ICC), "property" includes services and contracts of any kind. Receiving email, syncing to the cloud and updating apps are all services that US companies continue to provide. As of August 24, no suspension of any individual service had been made public for ICC President Tomoko Akane, who was sanctioned on August 18, 2026. Still, combining the law with the experience of ICC-related people designated earlier helps explain why the effects can reach so far beyond bank accounts.
"Property" Is Far Broader Than Deposits
On August 18, the US Treasury's Office of Foreign Assets Control (OFAC) added Akane to the Specially Designated Nationals and Blocked Persons List (SDN List). The General License No. 12 issued at the same time authorizes activities ordinarily incident and necessary to wind down transactions with Akane and others until 12:01 a.m. US Eastern Daylight Time on September 17. It is not a license to keep doing business as usual; it is a grace period for service providers and financial institutions to close out their relationships.
Section 528.314 of 31 CFR Part 528, the underlying regulation, defines property and interests in property through a long list. In addition to deposits, securities and copyrights, it includes "services of any nature whatsoever" and "contracts of any nature whatsoever," regardless of whether they are tangible or intangible, or whether the rights are present, future or contingent. Section 3 of Executive Order 14203 further prohibits the provision and receipt of funds, goods or services to, for the benefit of, or from a designated person.
This two-layer structure makes a "freeze" broader than simply leaving the contents of a safe untouched. Renewing an existing cloud contract, syncing stored data and keeping apps available for re-download could all be scrutinized as acts by which a company continues to provide service after designation.
The SDN List is less like a padlock on a bank vault than a screening table that turns a red light on for ongoing dealings with US companies. But OFAC does not cut off accounts worldwide with a single switch. Each company matches its customer data against the list and decides how far to suspend service, taking into account general and specific licenses, its own contracts and the level of risk it can tolerate. This decentralized enforcement is why the effects can vary even under the same designation.
An Account Is Not Something You Bought but an Ongoing Contract
An integrated account such as an Apple ID is both the entry point for identity verification and the hub that ties together cloud storage, photo syncing, app distribution and payments. Even if a user has already purchased a device, retrieving photos from iCloud or updating an app on the App Store each time requires server-side authentication and provision. Ownership of the device and the services received through the account are separate things.
A typical sanctions-compliance process follows a chain like the one below. The actual determination steps and degree of automation differ by company, but there are multiple decision points between a name appearing on the list and restrictions on use.
| Stage | What happens on the company side | What may appear on the user side |
|---|---|---|
| SDN List update | Names, dates of birth, nationalities and so on are matched against customer data | Flagged as a potential match and put on hold |
| Identity verification | Additional review to determine whether it is a false match or the designated person | Login or transactions temporarily restricted |
| Legal and license review | Check the extent to which service can continue under a General License or specific license | Decisions diverge: continue, limit or terminate |
| Handling of related functions | ID, storage, app distribution and payments are stopped function by function | One ID suspension cascades across multiple services |
Using a service for free is not necessarily a safe zone. Free accounts also involve contracts, and authentication infrastructure, backups and support continue to be provided. If paid features are used, card companies and payment processors become separate screening points. With hotel bookings or ride-hailing apps, if any one of the booking site, the merchant or the payment network halts the transaction, the user gets the same result: it doesn't work.
Measures such as keeping data on European servers are also insufficient here. Even if data is stored in Europe, a US entity that holds the contracting party status and account administration authority can control access under US law. Data location matters for thinking about personal-data protection and government data access. But it does not mean the legal authority to keep providing the service has moved to Europe.
Three Routes Reaching Beyond US Borders
The "United States person" defined in Section 528.318 includes US citizens, permanent residents and entities organized under US law. The text of the regulation also covers those entities' foreign branches, subsidiaries and employees. One cannot say that a service run by a US company in the Netherlands or Japan is unrelated to US sanctions.
The second route is payments. Section 528.504 requires blocking of funds or credit in which a designated person has an interest if they come into the possession or control of a US financial institution. Even a card issued by a foreign bank may touch a US entity along the way through card brands, payment processors and correspondent banks. Even if the digital-service contract itself could continue, there remains a route by which service stops because a renewal fee cannot be paid.
The third is risk avoidance beyond the boundary of legal obligation. OFAC's FAQ 65 explains that civil liability for sanctions violations is strict liability, meaning one may be held liable even without knowing of the violation. The executive order also contains provisions allowing the designation of foreign persons who materially assist ICC activities subject to designation or provide goods or services to a designated person. This does not mean non-US companies are automatically punished. Still, for companies that depend on the US market and dollar settlement, the loss from being suspected of a violation can easily look larger than the revenue from continuing the business.
The legal reach needs to be considered in three parts: prohibitions that apply directly to US persons, points of contact with the United States that arise mid-transaction, and over-compliance that companies choose on their own. When a European bank closes a euro account, it does not necessarily mean US law expressly ordered all of that action. But from the user's perspective, direct enforcement and over-compliance can land on the same day.
Precedents Showed the Cascade, and the Limits of the Testimony
A report published in April 2026 by the Coalition for the International Criminal Court (CICC) was based on research from September 2025 to March 2026, during which 45 people were interviewed between October 2025 and March 2026. The interviewees included ICC-related people who were designated at the time, as well as civil society groups and experts in IT, banking and sanctions law. The CICC is a coalition of organizations that support the ICC, and this report is not a neutral regulatory audit. It must be read with the source of the testimony and the investigators' standpoint in mind.
Even so, the specific examples in the report match the breadth of the law. Several designated persons said their Apple IDs were suspended, leaving them unable to access photos in iCloud or to download or update apps. ICC judge Beti Hohler testified that her PayPal and Amazon accounts were canceled and that she also lost access to her Apple ID and iCloud. Courthouse News, drawing on the report, said the effects extended beyond email and the cloud to apps and travel bookings.
The example of Hohler's friend neatly illustrates the cascade of over-compliance. According to the report, after the friend sent Hohler a gift through Amazon, the friend's Amazon account, including Kindle and Audible, was suspended, and it took five weeks to restore. The friend is not a designated person. This testimony shows that company screening can ripple out to associates, but it is not evidence that the law uniformly requires suspending third parties.
A line must be drawn regarding Akane. The OFAC materials published as of August 24 contain no statement that any specific email, Apple ID or bank account has been suspended. No disclosure from Akane's side could be confirmed by that date either. The precedents are material for explaining processing that could occur in future; they do not prove the current state of Akane's accounts.
Why Tomoko Akane Was Designated
The US State Department's August 18 announcement, reproduced by GlobalSecurity.org, explained that Akane was directly involved in ICC efforts to investigate, arrest, detain and prosecute "officials whose governments have not consented to the ICC's jurisdiction." The provision applied is Section 1(a)(ii)(A) of Executive Order 14203. However, the announcement does not clarify which decision or act in which case it refers to. The reason for the designation cannot be pinned to a single cause from Akane's title or past rulings.
The background is a fundamental conflict over ICC jurisdiction. The United States argues that the US and Israel are not parties to the Rome Statute and have not consented to ICC jurisdiction over their nationals. In response, Article 12(2) of the Rome Statute provides that in certain cases the court can exercise jurisdiction if either the state where the conduct occurred or the state of nationality of the accused is a party or has accepted jurisdiction. It is not a provision under which the nationality state's non-consent is always decisive.
US sanctions do not leave this clash of legal interpretation confined to US domestic argument. An SDN designation enters the decisions of banks and cloud companies, and moves the contracts of app stores and travel and payment services as well. It is not a procedure for overturning the ICC's legal judgments on appeal but a policy tool that sharply raises the cost of connecting to the American economic sphere.
Not Where the Data Is, but Who Controls the ID and Contract
When an organization assesses its digital dependence, checking only server location leads to oversights. The layer where the data itself sits, the layer that manages login authority and the layer that processes contracts and payments are separate. Even if a European data center is chosen, if administrators log in with a US company's ID, pay fees on a US-linked card network and receive the authentication app from a US company's app store, points of contact with sanctions remain.
What needs to be checked in practice goes beyond redundancy for outages. One must examine as a single chain which country's entity the service company is, whether the ID can be moved to another provider, whether the data can be retrieved locally, and which company controls the payment route. Even with an alternative service under contract, if it depends on the same ID infrastructure or card network, the exit is shared.
That said, this does not mean that preparing alternative routes lets a designated person evade sanctions. Transactions with a sanctions target may require an OFAC general or specific license, and non-US companies also have points of contact with the United States and local laws. What an organization can do is, while complying with the law, separate objections to false matches from data preservation, and prepare in advance the procedures for license applications and business continuity.
After the GL 12 grace period expires on September 17, the first things to check will be how each company handles its contracts with Akane and whether OFAC issues additional authorizations. The yardstick for what happens to Akane's digital environment is not whether she holds assets in the United States, but how many layers of US company contracts, IDs and payments her work and daily life pass through.