Sudan sanctions

Additionally, BIS has not announced any relaxation of the export controls it administers relating to Sudan. As a result, although it will be permissible to export and reexport to Sudan items subject to the EAR and classified as EAR99 (as well as items that qualify for export or reexport under an EAR license exception, such as certain personal communications equipment and software), a BIS authorization still will be required to export or reexport to Sudan any item subject to the EAR (including U.S.-origin items and non-U.S.-origin items that incorporate more than 10% controlled U.S.-origin content by value) that is on the U.S. Commerce Control List (“CCL”). This includes items controlled on the CCL only for anti-terrorism reasons. The U.S. government has not made any announcement indicating an intention to remove Sudan from the State Sponsors of Terrorism List. End-use and end-user controls in the EAR also continue to apply, and could restrict the export/reexport to Sudan of … [Read more...] about United States suspends Sudan sanctions

Impact on Non-U.S. PersonsWhile non-U.S. Persons are not subject to the SSR, they were effectively unable to order EAR99 items from the United States or a U.S. Person specifically or predominantly for Sudan due to the prior prohibition applicable to U.S. Persons.  That prohibition is no longer is in effect, which will open up possibilities for non-U.S. Persons to order and procure EAR99 items from the United States and U.S. Persons for the Sudan market and in support of Sudanese operations.  Note that non-EAR99 items (e.g., items described on the CCL) are still restricted and, due to the extraterritorial application of the EAR, non-U.S. Persons shipping those items to Sudan without BIS authorization would be a direct breach of the EAR. … [Read more...] about Obama Administration Announces Relief of Sudan Sanctions Measures

What Does This Mean in Practice?Exports. US companies can now export their products and services to customers in Sudan without any license or authorization from the Treasury Department’s Office of Foreign Assets Control (OFAC). Depending upon the product, customer and end use, they may have to obtain an export license under the Export Administration Regulations (EAR), but OFAC’s blanket ban on exports, temporarily suspended in January 2017, will be permanently revoked on October 12. Licensing policy under the EAR has been amended to create a presumption of favorable consideration of applications to export to Sudan parts to ensure the safety of civil aviation and items to inspect, operate, improve, maintain, repair and overhaul railroads. Further, for exports and re-exports of certain telecommunications equipment and associated computers, software and technology (including items that are useful for the … [Read more...] about Trump Administration Permanently Lifts Sudan Sanctions

On 6 October, the Trump administration announced that it would permanently revoke economic sanctions against Sudan, effective 12 October 2017. The State Department published this decision in the Federal Register, 82 Fed. Reg. 47287, on 11 October 2017. This decision means that US companies can invest in Sudan and export their products and services to Sudan, subject to compliance with US export controls under International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), which are not affected by the revocation of the sanctions. Further, effective 12 October 2017, all blocked assets are permanently unblocked; however, in many instances, officials will need some time to determine who has the rightful claim to the unblocked assets. The Darfur and South Sudan sanctions remain in effect. Thus, US persons are prohibited from engaging with any specially designated nationals designated under … [Read more...] about Trump Administration Permanently Lifts Sudan Sanctions: November 2017 Update

The declaration is clear that the EU remains ready to impose sanctions against any individual responsible for undermining the peace process in South Sudan. The EU declaration further notes that the EU has long maintained an arms embargo on South Sudan, and supports the UN Security Council’s willingness to consider additional measures, including an arms embargo, should obstruction of the UN’s mission in South Sudan continue. … [Read more...] about European Union Issues Declaration on South Sudan Sanctions