After a three-month postponement (discussed here), the United States sanctions against Sudan have finally been revoked. The State Department recently determined that the Sudanese government “has sustained the positive actions that gave rise to” Executive Order 13761, the initial step toward revocation in January 2017. That EO terminated the two previous ones under which the sanctions had been imposed. Upon EO 13761’s issuance, the Office of Foreign Assets Control published a General License authorizing most previously-prohibited transactions with Sudan.
The revocation was to be effective six months afterward, as long as State issued a positive finding regarding Sudanese actions. That deadline was extended by three months to give more time for review. Now that State’s determination has been made, the revocation is final under the terms of EO 13761. OFAC simultaneously removed from the Specially Designated Nationals List those parties that had been designated under the Sudanese Sanctions Regulations.
There is one area where OFAC-administered restrictions continue, however. Since Sudan’s status as a “State Sponsor of Terrorism” remains unchanged, the country is subject to license requirements for exports and reexports of agricultural items, medicine and medical devices as required by the Trade Sanctions Reform and Export Enhancement Act of 2000. OFAC has issued a General License authorizing those transactions “provided that the exports and reexports are shipped within the 12-month period beginning on the date of the signing of the contract for export or reexport.”
While Sudan remains subject to Commerce Department license requirements for pretty much everything on the Commerce Control List, the all-encompassing OFAC sanctions are now a thing of the past.
