On July 12, the State Department announced that President Trump is issuing an Executive Order extending the previously announced deadline under Executive Order 13761 to complete a review of the Government of Sudan’s conduct and determine whether to permanently terminate U.S. sanctions against Sudan (see our previous update here). In the meantime, the OFAC general license suspending sanctions against the government and territory of Sudan (31 C.F.R. § 538.540) remains in effect. The general license authorizes all transactions with the Government of Sudan and its controlled entities, the territory of Sudan, and any Specially Designated National (SDN) in Sudan currently designated with the tag [SUDAN]. It also unblocks all property previously blocked under the Sudanese sanctions. The license does not, however, affect other sanctions programs, and other SDNs located in Sudan but designated under different programs (including those relating to Darfur, South Sudan, and terrorism) will remain sanctioned. Comprehensive restrictions on U.S. exports to Sudan also remain in place (see the Bureau of Industry and Security’s Sudan page).
Sudanese sanctions will now be re-evaluated by October 12, 2017. The new Executive Order leaves in place the previous structure pursuant to which Sudanese sanctions will be permanently terminated if the Secretary of State makes a determination that the Government of Sudan has sustained the positive actions leading to the suspension of sanctions.