Sudan Sanctions Revoked

     On January 13, 2017 the US President issued Executive Order (E.O.) 13761 (further amended by E.O. 13804 on July 11, 2017) providing for the revocation of certain Sudan-related sanctions.  The action was taken in recognition of the positive actions taken by the government of Sudan.  Following the initial E.O., on October 6, 2017, the US Government officially revoked economic sanctions on the Government of Sudan under E.O.'s 13067 and 13412

     The revocation of certain sanctions indicates the Government of Sudan has continued to make strides in reducing conflict areas in Sudan, improving humanitarian access, and in cooperating with the US Government with regional conflicts and terrorism.

What changed?

  • Effective October 12, 2017 sections 1 and 2 of E.O. 13067 and all of E.O. 13412 were revoked.  Sections 1 and 2 blocked property of the government of Sudan and prohibited U.S. persons from engaging in transactions with Sudan and the government of Sudan.  The revocation of these provisions will allow U.S. persons to engage in transactions that were previously prohibited under the Sudanese Sanctions Regulations (SSR), 31 CFR 538.
  • Effective October 12, 2017, General License A authorizes exports and re-exports of certain agricultural commodities, medicine, and medical devices still controlled as a result of Sudan remaining on the State Sponsors of Terrorism List (SST List

What hasn't changed? 

  • The national emergency declared under E.O. 13067 remains in effect in regards to Sudan.
  • The OFAC sanction related to the Darfur conflict imposed under E.O. 13400 remains in effect.
  • OFAC designations of any Sudanese persons under E.O. 13067 and 13412 remain in effect
  • Sudan remains on the SST List; and as a result some agricultural, medicinal, and medical device exports and re-exports to Sudan still require an OFAC license (see General License A comment above).   
  • US persons and non-US persons will still need to obtain Department of Commerce Bureau of Industry and Security (BIS) licenses to export or re-export certain items such as commodities, software, and technology that are on the Commerce Control List (CCL), Supplement No. 1 to part 774 of the Export Administration Regulation (EAR), 15 CFR parts 730-774 or that require a license due to end-use or end-user concerns, 15 CFR 744. 

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