Reed Smith Client Alerts

Following a 16-month diplomatic effort, on October 6, 2017, the U.S. government announced that it will terminate the vast majority of economic sanctions against Sudan. The revocation, which will be effective on October 12, 2017, recognizes Sudan’s positive steps to cease hostilities in South Sudan, its efforts to increase access to humanitarian aid, and its cooperation in addressing threats of terrorism. We previously addressed the United States’ decision to temporarily lift the majority of the Sudanese sanctions in our client alert dated January 19, 2017.1

Authors: Leigh T. Hansson

OFAC Sanctions

Because of Sudan’s role in international terrorism and support for Osama bin Laden, since 1997, the United States has maintained a comprehensive embargo against Sudan which prohibited virtually all trade between the United States and Sudan. These sanctions are contained in the Sudanese Sanctions Regulations, 31 C.F.R. Part 538 (the SSR), and executive orders (E.O.) 13067 and 13412.

On January 13, 2017, just prior to leaving office, President Obama issued E.O. 13761 and a general license that temporarily suspended a number of sanctions against Sudan including prohibitions on transactions with certain designated persons and entities (the 2017 Sudan Rule). The temporary revocation of these sanctions was to become permanent on July 12, 2017 if Sudan had carried out certain actions to cease hostilities within Sudan, improve access to humanitarian aid, and cooperate with the United States to address regional conflicts and the threat of terrorism. On July 11, 2017, President Trump extended the review period to October 12, 2017 to allow his administration time to assess the actions taken by the Sudanese government.