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Web Alert: USA revokes sanctions against Sudan

10 October 2017

As previously reported by the club, just before leaving public office, President Obama issued Executive Order (EO) 13761, which temporarily lifted US sanctions against Sudan. Temporary sanctions relief took effect with immediate effect and this was due to become permanent on 12 July 2017. However, on 11 July 2017, President Trump postponed making a decision on whether to permanently lift sanctions against Sudan for three months.

On 6 October 2017, the USA revoked sanctions against Sudan imposed under EOs 13067 and 13412, with effect from 12 October 2017, in recognition of its progress towards maintaining a cessation of hostilities in Sudanese conflict areas, improving humanitarian access throughout Sudan, and maintaining cooperation with the USA on addressing regional conflicts and the threat of terrorism.

As a result of the revocation of these provisions, US persons will no longer be prohibited from engaging in transactions that were previously prohibited under the Sudanese Sanctions Regulations, 31 C.F.R part 538 (SSR).

However, the lifting of sanctions does not affect the Darfur related sanctions which remain in effect, or designations to the US SDN List. Therefore, any US person engaging in trade with Sudan should still exercise due diligence to ensure that they are not transacting business with a designated person or entity on the US SDN List.

It should also be noted that other applicable regulations, such as the Export Administration Regulations administered by the US Bureau of Industry and Security and the Department of Commerce still remain in place. Any US persons engaging in trade with or relating to Sudan will still need to comply with these.

The US Treasury Department and the Department of State has issued FAQS and Freehill Hogan & Mahar LLP has produced a helpful client alert, both are available on the right of this page.​