The Department of the Treasury’s Office of Foreign Asset Controls has published a general license in the Federal Register that essentially eliminates U.S. sanctions against Sudan. OFAC has issued the general license “in connection with ongoing U.S.-Sudan bilateral engagement and in response to positive developments in the country over the past six months related to bilateral cooperation, the ending of internal hostilities, regional cooperation, and improvements to humanitarian access.”
The new general license, at 31 C.F.R. § 538.540, authorizes all transactions previously prohibited under Sudanese Sanctions Regulations (SSR), including transactions involving the Government of Sudan. The types of transactions authorized include the processing of transactions involving persons in Sudan; the importation of goods and services from Sudan; the exportation of goods, technology, and services to Sudan; and, transactions involving property in which the Government of Sudan has an interest. The new General License does not impact sanctions against specific parties identified as Specially Designated Nationals, and transactions with such parties remain prohibited at this time.
Because certain statutory restrictions continue to apply under the Trade Sanctions Reform and Export Enhancement Act (TSRA), with respect to the export of agricultural commodities (e.g., food), medicine, and medical devices to Sudan, sales of these goods must continue to be limited to one year contracts unless and until the TSRA is modified.
If you have any questions about this alert, please do not hesitate to contact the authors or your usual Drinker Biddle contact.