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Web Alert: U.S. takes steps to revoke sanctions against Sudan

17 January 2017

On 13 January 2017, President Obama signed an Executive Order (E.O.) which will revoke sanctions against Sudan on 12 July 2017, if the Government of Sudan sustains positive actions it has taken over the last six months.

In conjunction with the new E.O., the US Treasury Department of Foreign Assets Control (OFAC) has issued a general licence authorising all transactions which were prohibited by the Sudanese Sanctions Regulations (SSR) (31 C.F.R. part 538-40). This will permit U.S. persons to process transactions involving persons in Sudan; to engage in imports and exports that were previously prohibited under the SSR; and to engage in transactions involving property in which the Government of Sudan has an interest. As a result of the amendments to the SSR:

  • All property and interests in property blocked pursuant to the SSR will be unblocked;
  • All trade between the United States and Sudan that was previously prohibited by the SSR will be authorized;
  • All transactions by U.S. persons relating to the petroleum or petrochemical industries in Sudan that were previously prohibited by the SSR will be authorized, including oilfield services and oil and gas pipelines; and
  • U.S. persons will no longer be prohibited from facilitating transactions between Sudan and third countries, to the extent previously prohibited by the SSR.

However, the revocation will only become effective if, prior to July 12, 2017, the US Secretary of State has published a notice in the Federal Register stating that the Government of Sudan has sustained the positive steps taken over the last six months.

The above regulatory changes will not impact Sudanese individuals or entities blocked pursuant to E.O. 13400 of April 27, 2006, “Blocking Property of Persons in Connection With the Conflict in Sudan’s Darfur Region,” or any OFAC sanctions authorities other than the SSR, E.O. 13067, and E.O. 13412. The property and interests in property of persons designated pursuant to E.O. 13400 and other E.O.s remain blocked. Additionally, this regulatory change will not eliminate the need to comply with other applicable provisions of law, including the Export Administration Regulations (15 C.F.R. parts 730 through 774) administered by the Bureau of Industry and Security of the Department of Commerce.

More information can be found on the right of this page. The US Treasury Department and the Department of State has issued FAQS and Freehill Hogan & Mahar LLP has produced a helpful client alert that is also available on the right.​