Sudan Sanctions Revocation Formalized, But Compliance Challenges Remain

On October 12, 2017, the Treasury Department’s Office of Foreign Assets Control (OFAC) revoked certain parts of its economic sanctions regime with respect to Sudan and the Government of Sudan.  OFAC issued a General License on January 17 authorizing transactions formerly banned under the Sudanese Sanctions Regulations (SSR), and that General License will no longer be needed after October 12 to engage in such previously prohibited transactions. While the decision reflects progress towards the normalization of bilateral relations between the U.S. and Sudan, U.S. companies and multi-national exporters should remain wary of the sanctions regimes and trade restrictions that remain in force through authorities in the U.S., the European Union, and the United Nations.  Comprehensive due diligence remains a necessity for doing business in the region, particularly for the defense industry.  Notably, OFAC can and will investigate business activities that violated the SSR before the issuance of the January 2017  General License.  For more information on the revocation of the SSR and recent enforcement action, see our Sudan Sanctions 2017 update in Global Trade Magazine.