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Economic Sanctions Against Sudan Largely Revoked

Tuesday, October 10, 2017
Sandler, Travis & Rosenberg Trade Report

The U.S. will formally revoke most economic sanctions against Sudan as of Oct. 12 in recognition of additional positive developments in that country. Earlier this year the U.S. responded to progress in five key areas by taking steps to restore bilateral trade. Ties could be normalized further, the State Department states, but “much more progress is needed” and the U.S. is prepared to use additional tools to pressure Sudan if it regresses or takes negative actions in other areas of concern.

According to information from State’s Office of Foreign Assets Control, as of Oct. 12 U.S. persons will no longer be prohibited from engaging in transactions that were previously prohibited under the Sudanese Sanctions Regulations. As a result, a general license that authorized all such transactions will cease to be operable as of that date because U.S. persons will be able to engage in such transactions without a general or specific OFAC license. OFAC also expects to remove the SSR from the Code of Federal Regulations.

OFAC states that it is not removing Sudan from the state sponsors of terrorism list and that as a result the Trade Sanctions Reform and Export Enhancement Act of 2000 will still require a license to export agricultural commodities, medicine, or medical devices to the government of Sudan or any other entity in that country. However, effective Oct. 12 a new general license A will authorize exports and reexports of certain TSRA items to Sudan and no OFAC license will be required for financing these shipments.

In addition, U.S. and non-U.S. persons will still need to obtain any licenses required by the Bureau of Industry and Security to export or reexport to Sudan certain items (commodities, software, and technology) that are on the Commerce Control List. In limited circumstances, U.S. and non-U.S. persons may also need to obtain BIS licenses to export or reexport to Sudan items that are subject to the Export Administration Regulations but are not specifically listed on the CCL (EAR99 items) if such transactions implicate certain end-use or end-user concerns.

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