OFAC issued guidance reminding U.S. persons that dealings involving Sudan remain subject to a number of restrictions, notwithstanding the easing of many Sudan-related sanctions beginning in 2017, and the removal of the Sudanese Sanctions Regulations from the Code of Federal Regulations in 2018.
In particular, OFAC noted that the national emergency declaration in Executive Order 13067 (Blocking Sudanese Government Property and Prohibiting Transactions With Sudan) "as expanded upon in scope by subsequent Executive Orders" (e.g., Executive Order 13400 Blocking Property of Persons in Connection With the Conflict in Sudan's Darfur Region), remains in effect and provides a basis for sanctions in connection with the conflict in Darfur. Sudan also remains on the State Sponsors of Terrorism List, resulting in various prohibitions, export restrictions, and license requirements.
Primary Sources
- OFAC Guidance: Sudan Program and Darfur Sanctions Guidance as of August 11, 2020
- OFAC FAQ: Sudan, Darfur, and South Sudan-related Sanctions
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