The Treasury Department on Wednesday placed Francesca Albanese, a United Nations legal expert on the occupied Palestinian territories and a critic of Israel’s conduct there, back on a financial blacklist amid a court battle over the unusual move.
Last week, the U.S. government had removed Ms. Albanese from the sanctions list to comply with a federal court order. The judge in the case, Richard J. Leon, had issued a preliminary finding that the sanctions had violated Ms. Albanese’s First Amendment right to free speech, and ordered they be removed while the case played out.
After the Trump administration appealed the decision, however, the District of Columbia Court of Appeals last Friday allowed the sanctions to be reinstated pending further court orders, according to Brett Shumate, an assistant attorney general in the Department of Justice. On Wednesday, Ms. Albanese’s name was added again.
Ms. Albanese, an Italian, serves as the U.N.’s special rapporteur for the Israeli-occupied West Bank and Gaza. She is not a U.N. staffer, but was instead appointed as an unpaid independent expert to monitor human rights in the territories.
Ms. Albanese has become a lightning rod amid Israel’s war in Gaza, drawing both criticism and plaudits. As special rapporteur, she issued fierce denunciations of Israel’s military campaign, which she described as a genocide, and called for an arms embargo on Israel, as well as the sanctioning and prosecution of top Israeli leaders.
Israel firmly rejects the charge of genocide, saying it was fighting Hamas, not ordinary Palestinians.
Secretary of State Marco Rubio imposed the sanctions on her last July, and at the time linked the decision to a broader American effort to retaliate against the International Criminal Court, which in 2024 had issued arrest warrants for Benjamin Netanyahu, the Israeli prime minister, and Yoav Gallant, the former defense minister, as well as a Hamas leader, Muhammad Deif. Mr. Rubio said then that Ms. Albanese had “directly engaged with the International Criminal Court in efforts to investigate, arrest, detain, or prosecute nationals of the United States or Israel, without the consent of those two countries.”
But after Ms. Albanese’s family in February filed a lawsuit on her behalf challenging the sanctions, Judge Leon wrote in his opinion granting the preliminary injunction that she had only offered her “nonbinding opinion” to the court, well within her free speech rights.
“Not only do defendants seek to regulate Albanese’s speech, they want to regulate her speech because of the ‘idea or message expressed,’” he wrote, referring to the Trump administration.
Many Palestinians view Ms. Albanese as a passionate defender of their rights on the world stage. More than 70,000 people were killed during the Gaza war, including thousands of children, according to local health officials, who did not say how many of the dead were combatants.
But Ms. Albanese also drew criticism from Israel and American Jewish groups. They argued she minimized the violence carried out by Palestinian militant groups like Hamas, whose Oct. 7, 2023, assault on Israel killed about 1,200 and saw some 250 abducted, igniting the war.

