US Government Revokes County-Based Sanctions on Sudan

As of October 12, 2017, the broad country-based sanctions on Sudan were removed by the US government. Originally, the restrictions on Sudan were extensive like those on Iran, Cuba, and Syria. With the recent update, various persons and entities now have the legal ability to engage with Sudanese business entities.

Details of the Sudan Sanctions Regime

There are still a number of restrictions on Sudan due to its designation as a state sponsor of terrorism (SST). As an SST, the US government recognizes that Sudan has sponsored terrorist organizations in the past and continues to do so. However, it has been reported that Sudan is currently undergoing negotiations with the US to remove this designation.

Due to Sudan’s designation as a state sponsor of terrorism, the US government restricts or bans the exportation of arms and other goods it believes may be used to support terrorism. It also severely limits economic and financial assistance to the Sudanese government.

Additionally, US persons and entities are not permitted to receive donations from the Sudanese government, with the exception of certain scholarship or financial aid funding for students in the United States.

As a state sponsor of terrorism under the Trade Sanctions Reform and Export Enhancement Act (TSRA), US persons and entities are required to obtain an OFAC license for the exportation of medical devices, medical goods and agricultural commodities to Sudan. Although these specific licenses are readily provided, US entities still must undergo the application process with OFAC.

Ask an OFAC Attorney About Your Transactions with Sudan

With the latest news of the uprisings in Sudan, it is critical to keep up to date with any changes or additions to the SDN list and designations in Sudan. Any person or company doing business with Sudanese entities should consult an export controls lawyer to determine what licensing is necessary to export goods or services to Sudanese persons, entities, or government agencies.