Sudan Sanctions Lifted

The U.S. government has lifted sanctions against Sudan in a major step toward normalizing relations with that country. The change, announced by the Office of Foreign Assets Control (OFAC) in a publication dated October 6, 2017, follows 16 months of diplomatic negotiations initiated under President Obama and continued under President Trump. U.S. persons are no longer prohibited from engaging in the majority of transactions with or involving Sudan or its government.

U.S. persons and certain non-U.S. persons will still need to obtain licenses required by the Department of Commerce’s Bureau of Industry and Security to export or reexport to Sudan certain items (commodities, software and technology) that are controlled for export and reexport by the Export Administration Regulations, 15 C.F.R. Part 730 et seq.; and from the Department of State’s Directorate of Defense Trade Controls for exports of all items subject to the International Traffic in Arms Regulations, 22 C.F.R. Part 120 et seq.

The revocation of sanctions against Sudan also does not affect:

• The need for OFAC authorization to export to Sudan agricultural commodities, medicine and medical devices, although such authorization has been granted in the form, and subject to the requirements, of General License A;
• OFAC designations of any Sudanese person or entity as a Specially Designated National pursuant to OFAC list-based sanctions related to Darfur, South Sudan, or other OFAC sanctions programs; and
• U.S. laws prohibiting money laundering and support of terrorist activities.

If you would like additional information about the issues addressed in this client alert, please contact Rich Matheny or Jacob Osborn, or the Goodwin attorney with whom you typically consult.