International Civil Society's Tech Stack is in Extreme Danger
Many in the international community are not ready for the US to abuse its hegemonic power in ways that directly destroy the ability for international NGO's and even liberal democratic governments to function. The little known ability for President Trump to issue economic sanctions has been and can continue to be weaponized to target enemies of this administration. For an example of this, Microsoft recently closed the International Criminal Court’s accounts on its services, including the email account of the ICC’s chief prosecutor, due to U.S. sanctions. This move has completely paralyzed parts of the ICC’s work such as investigations into the genocide being committed by Israel in Gaza. Now, the Hague found itself suddenly cut off from its U.S.-based email and cloud platforms. In short, the tech stack full of American companies has become a critical vulnerability that has now left the ICC unable to carry out its work.
The disruption to the ICC's work stems from Trump-era sanctions: In February 2025, President Trump signed Executive Order 14203, which declared the ICC’s investigations a national security threat and authorized freezing ICC officials’ assets. Under that order, any U.S. company providing “services” to sanctioned ICC staff could face civil or criminal penalties, forcing firms like Microsoft to sever ties. They had no choice in the matter. Had Microsoft not cutoff the ICC, it would have left their executives and staff liable to criminal prosecution.
It wasn't just the tech stack, banks in the U.K. froze Khan’s accounts, and an NGO working with the court hastily moved its funds out of U.S. banks, fearing seizure by U.S. authorities. Even U.S.-based human rights organizations stopped replying to ICC emails out of fear of penalties. In effect, a single U.S. executive order allowed Washington to digitally and financially strangle an international judicial body, simply by leveraging American companies’ global hegemonic power. This should be a massive wake-up call to international civil society that any organization relying on U.S. tech can be digitally shut down by the stroke of a pen by Trump.
How could a U.S. order have such power over a court prosecuting war crimes in The Netherlands? The answer lies in U.S. sanctions law. Trump invoked the International Emergency Economic Powers Act to create a sanctions program against ICC personnel. It authorized the U.S. government to freeze any assets of certain ICC officials that fall under U.S. jurisdiction. More frightening and relevant for NGOs and tech companies, it also made it illegal for any U.S. person or company anywhere in the world to provide “funds, goods, or services” to those sanctioned officials. In practice, that meant companies like Microsoft had no choice but to cut off services such as email, cloud storage, CDN provision, you name it, or risk heavy fines and even criminal charges.
While this isn't the first time Trump has sanctioned the ICC, which he did in 2020, the recent sanctions come at a time when the guardrails around Trump are completely gone. The ICC’s “crime” in Trump’s eyes was investigating possible U.S. and Israeli war crimes in Gaza. Trump’s order branded these investigations “illegitimate” and an “unusual and extraordinary threat” to U.S. national security, thereby justifying emergency economic measures. The ICC chief Prosecutor, Karim Khan, was promptly added to the Treasury Department’s sanctions blacklist – the same list that holds terrorists and hostile regimes such as Russia and North Korea. Once blacklisted, those individuals become radioactive in the eyes of banks and businesses worldwide. U.S. law required everyone from Citibank to Microsoft to freeze any accounts or services linked to them, and ban any transactions or support involving them.
What’s more, the order is sweeping: it threatens sanctions against any foreign person who even helped the ICC’s investigations. In other words, if a human rights NGO overseas provided information or assistance to the court, they too could potentially be designated and frozen out of the global financial system. By criminalizing support, the U.S. created a chilling effect which is exactly the intent. The result is that ICC staff and partners found themselves isolated, and the court’s pursuit of justice for war crimes was hampered by fear while Israel's genocide in Gaza accelerates with US backing for full ethnic cleansing of the Gaza Strip.
A Roadmap to Target International Human Rights and Advocacy Groups
This aggressive use of sanctions sets a dangerous precedent. If an international court can be targeted, what about NGOs and human rights activists abroad? The ICC case shows that a U.S. president, simply by declaring a foreign organization’s work a “threat," can invoke emergency powers to freeze its funds and ban any U.S. support to it. Today it’s the ICC, tomorrow it could be a foreign NGO whose work angers Trump.
Consider organizations like Aid Access, a European-based group that mails abortion pills to people in countries where abortion is restricted. Or global LGBTQ+ advocacy networks like ILGA (the International Lesbian, Gay, Bisexual, Trans and Intersex Association) and WPATH (World Professional Association for Transgender Health), which promote LGBTQ+ rights and gender affirming care health standards worldwide. The work that these orgs do have already been targeted by several countries that have backslid into authoritarianism such as Hungary, Russia, and Turkey.
With the ICC sanctions as a blueprint, the Trump administration could declare such organizations a threat to American interests or values, and wield sanctions against them. For example, Trump might claim that Aid Access is “undermining U.S. law” or “threatening public health” by helping Americans obtain medication abortions, and then blacklist its leaders. Trump could take its hostile stance against LGBTQ+ people international and could absurdly label international queer rights advocates as a cultural threat or accuse them of “destabilizing” allied governments, and similarly freeze their U.S.-held funds or bar U.S. companies from doing business with them. Trump has already baselessly accused US health orgs of engaging in "female genital mutilation" by providing gender affirming care. Such a pretext for sanctions would be sufficient to gut international medical bodies working on transgender healthcare.
This isn’t mere paranoia. As we've seen in the first few months of the Trump administration, if there is a lever of power that can be abused, Trump is abusing it. The legal mechanisms are already in place. Under U.S. law, the president needs only a broad national emergency declaration to target a foreign entity with sanctions. Trump’s ICC order proved how elastic that definition can be – he stretched “national security threat” to cover a court seeking accountability for war crimes. Likewise, Trump could stretch it to cover, say, “foreign actors promoting policies that conflict with U.S. family values," a possible pretext to go after abortion or LGBTQ+ groups abroad. The threshold for abuse is dangerously low.
Once on a sanctions list, those groups would effectively be cut off from much of the world economy and communications. No U.S. bank transfers. No PayPal or Visa transactions. Most crucially, no services from U.S. tech firms (email, CDNs, cloud infrastructure, or social media). Even non-U.S. companies might drop them, since many major providers have U.S. ties or fear secondary sanctions. The ICC episode has shown that even elite institutions aren’t safe: if it can happen to the world’s war crimes court, it can happen to any NGO or advocacy network.
These actions don’t just threaten NGOs, they also endanger foreign governments, including U.S. allies, if they rely on American infrastructure. Many liberal democracies and international bodies depend on U.S. technology and banking for day-to-day operations. The ICC itself learned the hard way that its heavy dependence on a U.S. tech stack made it vulnerable. Imagine a liberal European government or UN agency that runs its official email on Office 365 or Google Workspace, only to have user accounts suspended because a U.S. sanction hit one of its units or leaders. What happened to the ICC is a clear warning that U.S. companies will shut down even a government or international organization’s access if Washington orders them to. As some have warned, the U.S. President could “digitally shut down any organization that depends on US technology” at will.
Foreign liberal governments could find their policies policed by U.S. sanctions if they’re not careful. For example, if a U.S. administration disapproves of another country’s progressive policy (say, funding for reproductive services or LGBT inclusion programs), it might sanction a key government official or state-run program to intimidate them. Even if not directly targeted, allies may self-censor to stay in Washington’s good graces which has already been the case with US media companies, law firms, and academia. This undermines national sovereignty and democratic choices abroad. Ironically, sanctions meant to defend “U.S. interests” could wind up exporting U.S. culture wars to other countries, punishing liberal governments for policies that are mainstream at home but controversial to American conservatives.
Americans Who Help Could Face Legal Jeopardy
Another under-discussed aspect of these sanctions: they don’t just target foreign entities, they put Americans in danger if they dare to support in any way the blacklisted groups. U.S. sanctions law applies to all U.S. “persons,” including citizens, residents, companies, and even NGOs. Once an organization is on the Specially Designated Nationals (SDN) list, any American providing it “material support” – even unpaid services or small donations – is committing a crime.
This means if, for instance, Aid Access were sanctioned, a U.S. volunteer who helps connect patients to that service could face serious penalties. If ILGA or WPATH were sanctioned, American activists, doctors, or donors working with them might have to choose between abandoning international LGBTQ causes or risking fines and jail.
The penalty for knowingly violating sanctions can be up to 20 years in prison and hefty fines, under U.S. law. This justice department has made no equivocation that it would pursue criminal charges against the president's perceived enemies as the Justice Department has become Trump's personal retribution department.
Even passive support becomes problematic. Americans who try to send money to a sanctioned group will likely see their payments blocked or accounts frozen. Online platforms will shut down fundraising campaigns linked to the group. Cloud providers might suspend an American user’s account if they collaborate with a sanctioned organization using those services. The chilling effect silences not just the targeted group but also its entire international support network.
While we haven’t yet seen U.S. sanctions explicitly used against a foreign abortion provider or LGBTQ+ organization, the writing is on the wall. The Trump administration demonstrated a willingness to weaponize every tool of U.S. policy to squash international efforts it opposed. For example, Trump repeatedly used the “Global Gag Rule” (Mexico City Policy) to withhold U.S. aid from any overseas health group that even mentioned abortion services. This policy, while not a financial sanction in the legal sense, has a similar punitive effect: it forces foreign NGOs to choose between U.S. funding and their free speech and medical services. The message was clear: align with the U.S. conservative stance or suffer financially. Sanctions would take that coercion up another notch, from defunding to complete debanking and blacklisting.
The Trump administration since day 1 has sought to rollback LGBTQ+ rights while the administration has embarked on a campaign of eradication against trans people in the US. It has threatened criminal prosecutions and investigations of gender affirming care providers, eliminated legal recognition in the federal government, purged the military and intelligence community of trans people, and has effectively banned trans tourists and immigrants from entering the country.
It’s not a huge leap for the Trump administration to argue that an international "gender ideology" is interfering in other nations’ cultural or religious norms, a flimsy pretext, perhaps, but enough to trigger a sanctions order if politically desired. We have seen extremist lawmakers in the U.S. willing to target any entity that doesn’t fit their worldview; some have even threatened to hold up global health programs over unrelated abortion policies. Given that mindset, using sanctions to attack a foreign NGO would just be an expansion of tactics already in play. from funding cuts to visa bans.
There have been hints of such threats. Far right influencers have laid the misinformation bedrock by baselessly accusing groups like WPATH of “corrupting” youth and have lobbied to shut down training for transgender healthcare even abroad. Anti-abortion activists in the U.S. have tried to get government agencies to block the import of abortion pills and harass groups like Aid Access via FDA warnings. Should Trump pursue it, an executive order could emerge to “block property of persons providing illicit abortion drugs” or some similarly titled sanctions program. It would only require a Trump willing to brand global abortion access as a national crisis. As bleak as that sounds, this is effectively what happened with the ICC. No matter how noble the work of an organization, it could find itself in Trump's crosshairs at any time.
Reducing Reliance on U.S. Tech and Finance: A Matter of Survival
All of this points to a sobering conclusion for liberal governments and international NGOs worldwide: dependence on American tech infrastructure and financial systems has become a serious strategic vulnerability. The United States has proven it will use its dominance in these sectors as leverage, even against allies and international institutions, whenever Trump wants to. To protect themselves, foreign governments and civil society groups must proactively diversify away from U.S.-controlled platforms and banks. In their place, alternative tech stacks need to be developed and an alternative to the Silicon Valley dominated ecosystem needs to be deployed.
The ICC’s experience prompted calls for exactly this in Europe. When the chief prosecutor of a major international court has to scramble for a secure email account because an American corporation shut him out, it’s a clear sign that betting everything on U.S. tech companies is a potential cataclysmic risk.
What might a more secure setup look like? For starters, choosing national or regional providers for critical services. Governments in Europe and elsewhere can invest in homegrown cloud services or use those from jurisdictions less likely to capitulate to political whims. Indeed, the brain drain that is beginning to occur in the United States is a ripe opportunity for the EU to gain an advantage by building up its own tech ecosystem.
Services such as encrypted email and file storage services based in Europe such as ProtonMail aren’t under U.S. legal control. Open-source software and self-hosted servers, though less convenient, offer freedom from big tech’s kill-switch. On the financial side, institutions can hold reserves and process payments in alternative currencies or through non-U.S. banks to limit exposure. The European Union has even explored creating its own payment channels to circumvent U.S. sanctions on other occasions. These steps come with costs, but failing to take them could mean being caught helpless when the Trump administration decides to flip the off switch on their email or freeze their funds. In essence, digital and financial sovereignty is becoming as important as political sovereignty for liberal democracies and NGOs in the 21st century.
Closing Thoughts
The modern economic sanctions regime was established as an alternative to kinetic engagements and open conflict. When most of the western world was on the side of the US, having that kind of economic super-weapon aimed at human rights organizations or liberal governments seemed unthinkable but now its here. We've never seen a country with such a death grip on crucial services worldwide go authoritarian in this manner and it is a unprecedented threat to liberal and social values. Ultimately, this means that for the values of liberal democracy to survive, US tech hegemony must be dismantled lest it become a fatal vulnerability to the entire international civil society ecosystem.
Europe needs to immediately begin to decouple itself from US tech companies and begin massive investments into European alternatives. China is waiting in the wings to capitalize on this crumbling American empire and implement its own tech hegemony over the rest of the global south, further perpetuating hegemonic power driven by an illiberal view skeptical of human rights. Europe is increasingly becoming one of the last bastions of liberal and social democracy in a world that is increasingly falling to authoritarianism. Ensuring its future requires a generational investment in tech services that respect fundamental human rights.
International NGO's working on critical issues of human rights need to begin migrating their tech stack to alternatives that do not do business in the United States. This means severing access to Microsoft 365, Gmail, Cloudflare CDN services, etc. or else risk being suddenly cutoff should the Trump administration choose to target them. The president is at the height of his power on issues of foreign policy and determining national emergencies so the chances of congress or the courts restraining Trump's powers to issue sanctions in such ways are virtually nonexistent. In short, no one is coming to save you and you must do what you can to prepare to save yourself.
