Zach Mollengarden, an associate at Three Crowns, and Noam Zamir, an Associate Professor of Law at Lyon Catholic University,  co-authored the article “The Monetary Gold Principle: Back to Basics,” in the January 2021 issue of the American Journal of International Law.


For over half a century, the ICJ has cited The Case of the Monetary Gold Removed from Rome in 1943 for the proposition that the Court will not address claims involving the legal interests of a third state where that state’s legal interests “would not only be affected by a decision, but would form the very subject-matter of the decision.”  The article looks to the most recent case in which the ICJ is expected to apply the Monetary Gold principle—Palestine’s 2018 application challenging the United States’ relocation of its embassy to Jerusalem—as an opportunity to rethink the Court’s approach to non-consenting third parties. The piece argues that the Monetary Gold principle conflicts with the Court’s obligation to decide cases submitted by consenting parties and should be abandoned.


Zach is an associate in the Washington, DC office. Before joining Three Crowns, he clerked for the Hon. Kevin C. Newsom on the Eleventh Circuit Court of Appeals. He previously worked in the New York office of a leading international law firm and in the international affairs department at a global investment bank in London.

Zach holds a JD from Yale Law School, where he served as an articles editor for the Yale Law Journal and submissions editor for the Yale Journal of International Law.

He received an M.Phil in International Relations from the University of Cambridge and graduated from Middlebury College with a BA degree in political science and religion, summa cum laude, Phi Beta Kappa.

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