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July 13, 2017 

Sudan sanctions suspended for three more months

On July 11, 2017 the Trump administration decided to maintain, for three more months, the current suspension of most US economic sanctions against Sudan.

President Obama had issued an executive order in January 2017, shortly before President Trump took office, to terminate almost all US sanctions against Sudan, effective yesterday, July 12, if the Trump Administration first determined that Sudan had continued to cooperate with the United States in several areas. Specifically, Sudan needed to maintain “the cessation of hostilities in conflict areas in Sudan”, improvement of “humanitarian access throughout Sudan”, and cooperation with the United States on regional conflicts and terrorism.

This week the Trump Administration decided to postpone, for three months, the decision as to whether Sudan has cooperated on these issues sufficiently to warrant the lifting of sanctions. On Tuesday, July 11, President Trump issued a new executive order, setting a new decision date of October 12, 2017, and eliminating the provision for future annual reports relating to Sudan’s progress in the areas noted above.

As a result, the status quo in place since January of this year is expected to remain until mid-October:
-  Under a general license issued in January 2017 by the Office of Foreign Assets Control (OFAC), almost all sanctions on Sudan remain suspended. Sanctions remain on a small number of companies and individuals designated in relation to the Darfur region of Sudan, or in relation to the independent country of South Sudan.
-  A broad range of investments, services transactions and imports from Sudan therefore have been authorized since January. Although many Sudanese entities remain on the SDN list (the primary OFAC sanctions list), almost all of them are no longer subject to blocking (asset freeze) since January 2017.

-  Transactions relating to Sudan and involving US persons are subject to a standard OFAC five year record-keeping requirement.
-  Some US exports to Sudan are possible. For example, the export of agricultural commodities, medicine or medical devices cannot have a term longer than one year.
-  However, broad US export controls remain on Sudan, administered by the Bureau of Industry and Security in the US Department of Commerce (BIS). These export controls cover a broad range of goods and technologies from the US or containing US content. It is possible to apply to BIS for a license (authorization) to export certain items for certain end-uses in Sudan


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