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. 

     Contact GCSG experts at info@globalcompliancesg.com with any questions or for more information on how we can assist you with your compliance program.  Visit our website at http://www.globalcompliancesg.com to learn more about our products and services. 

Key Link(s):

• Commerce Control List, Supplement No. 1 to part 744
• Executive Order 13067 - Blocking Sudanese Government Property and Prohibiting Transactions with Sudan (November 5, 1997)
• Executive Order 13400 - Blocking Property of Persons in Connection with the Conflict in Sudan's Darfur Region (April 26, 2006)
• Executive Order 13412 - Blocking Property and Prohibiting Transactions with the Government of Sudan (October 17, 2006)
• Executive Order 13761 - Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions (January 13, 2017)
• Executive Order 13804 - Allowing Additional Time for Recognizing Positive Actions by the Government of Sudan and Amending Executive Order 13761 (July 11, 2017) 
• Office of Foreign Assets Control FAQs Here and Here - Frequently Asked Questions regarding the revocation of certain sanction with respect to Sudan and the government of Sudan
• State Sponsors of Terrorism List
• Sudan General License A - Authorizing Certain Transactions Pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (October 6, 2017)
• The US Department of State: The Secretary's Report on Whether the Government of Sudan has Sustained the Positive Actions that Gave Rise to E.O. 13761 (2017)
• 15 CFR 744 - Control Policy: End-User and End-Use Based
• 31 CFR 538 - Sudanese Sanctions Regulations