The United States Treasury Department removed Francesca Albanese, the UN Special Rapporteur on Palestinian territories, from its sanctions list on May 20, 2026, complying with a federal court injunction [1, 2, 3, 4, 5, 6, 7]. Albanese had been sanctioned in July 2025 by the Trump administration for calling on the International Criminal Court to investigate alleged war crimes by Israeli and US officials [1, 8, 3, 9, 10, 6]. The sanctions barred Albanese from entering the US and accessing US banking and financial systems [1, 2, 6, 7].
The removal followed a May 13 ruling by US District Judge Richard Leon, who issued a preliminary injunction blocking enforcement of the sanctions. Leon ruled that the sanctions likely violated Albanese’s First Amendment free speech rights. He wrote that "protecting the freedom of speech is 'always' in the public interest" [1, 2, 3, 4, 6, 7]. The judge found the sanctions had been imposed to regulate Albanese's expression, deeming them unconstitutional [1, 3, 6, 7].
Albanese's husband and US citizen daughter filed a lawsuit in February 2026 challenging the sanctions as violations of free speech and constitutional rights [1, 9, 6]. Albanese is an Italian lawyer residing abroad who has issued widely publicized reports accusing Israel of genocide in Gaza and implicated 48 US companies in complicity [1, 2, 3, 9, 10, 6, 7]. One report cited an estimated Palestinian death toll of more than 75,000 in Gaza [9].
The US government, including the State Department, said the removal is temporary and does not reflect a policy change. They have appealed the injunction and plan to reinstate sanctions if the courts overturn the ruling. The State Department stated: "In the event the D.C. Circuit stays or overturns that order, the Government intends to restore Ms. Albanese's name to the SDN List" [8, 9, 10]. US Justice Department Assistant Attorney General Brett Shumate said Albanese "has undermined the national security and foreign policy of the United States" [10]. Secretary of State Marco Rubio accused her of having "spewed unabashed antisemitism, expressed support for terrorism and open contempt for the United States, Israel and the West" [2].
Disputes remain over whether Albanese’s First Amendment rights apply despite living outside the US. The court ruled they do, but the Justice Department argues foreign citizens outside US territory lack constitutional protections [1, 3, 10, 6, 7].
The US Justice Department filed an emergency appeal on May 21 seeking to reinstate the sanctions following Albanese’s removal [10].