U.S. Government Revokes the Sudanese Sanctions Regulations, But Restrictions and Risks Remain

On October 6, 2017, the U.S. Government announced its decision to revoke, effective October 12, 2017, the economic sanctions imposed upon Sudan since November 1997 through the Sudanese Sanctions Regulations (“SSR”). (82 Fed. Reg. 47287 (October 6, 2017)). Beginning a process begun by the Obama Administration in January 2017, the Trump Administration explained that the decision follows “sustained positive actions” by the government of Sudan over the last nine months to maintain a cessation of hostilities in Sudan, improve access to humanitarian aid throughout Sudan, and maintain cooperation with the United States on counter-terrorism efforts. Contemporaneous with the announcement, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published new Sudan Frequently Asked Questions (“FAQs”) and issued new General License A to authorize certain exports and reexports pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”).

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