Please enable JavaScript, then refresh this page. JavaScript is required on this site.

Publications

United States Revokes Sanctions on Sudan; Some Restrictions Remain in Place

October 2017

On October 6, 2017, the United States announced that, effective October 12, 2017, it will substantially revoke sanctions on Sudan and the Government of Sudan in recognition of the Government of Sudan's sustained positive actions in connection with certain key policy concerns. This announcement completes a U.S. government review started in January 2017 (on which we reported here and here). Following revocation of the sanctions, U.S. persons will be permitted to engage in most transactions previously prohibited by the Sudanese Sanctions Regulations (31 C.F.R. Part 538) without requiring authorization from the U.S. Department of the Treasury, Office of Foreign Assets Control ("OFAC").

Although the comprehensive sanctions program targeting Sudan has been lifted, certain list-based sanctions and trade restrictions remain in place. Specifically:

  • The national emergency declared with respect to Sudan pursuant to Executive Order 13067 has not been terminated;
  • U.S. sanctions related to the conflict in Darfur, imposed pursuant to the Darfur Sanctions Regulations (31 C.F.R. Part 546), remain unaffected;
  • The status of Sudanese persons designated under remaining sanctions authorities remains unchanged; and
  • Sudan remains on the list of state sponsors of terrorism, which will continue to impose restrictions on certain dealings involving Sudan, including licensing requirements for exports or reexports of: (i) non-EAR99 items to Sudan; (ii) any items subject to U.S. export controls that implicate certain end-use or end-user restrictions; and (iii) certain agricultural commodities, medicine, and medical devices (unless authorized, subject to certain requirements, by a general license issued by OFAC that also will be effective on October 12, 2017).

In light of these continuing restrictions, U.S. and non-U.S. companies engaging in business with or involving Sudan should continue to carefully monitor any such business to ensure they remain in compliance with applicable U.S. law.

Lawyer Contacts

For further information, please contact your principal Firm representative or one of the lawyers listed below. General email messages may be sent using our "Contact Us" form, which can be found at www.jonesday.com/contactus/.

Laura Fraedrich
Washington
+1.202.879.3646
lfraedrich@jonesday.com

Sean T. Boyce
Dubai
+971.4.709.8416
sboyce@jonesday.com

Chase D. Kaniecki
Washington
+1.202.879.3734
ckaniecki@jonesday.com

Lindsey M. Nelson
Washington
+1.202.879.3735
lmnelson@jonesday.com

Michael P. Gurdak
Washington
+1.202.879.5470
mpgurdak@jonesday.com

Fahad A. Habib
San Francisco
+1.415.875.5761
fahabib@jonesday.com

D. Grayson Yeargin
Washington
+1.202.879.3634
gyeargin@jonesday.com

Chad O. Dorr
Washington
+1.202.879.3795
cdorr@jonesday.com

Jones Day publications should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information purposes only and may not be quoted or referred to in any other publication or proceeding without the prior written consent of the Firm, to be given or withheld at our discretion. To request reprint permission for any of our publications, please use our "Contact Us" form, which can be found on our website at www.jonesday.com. The mailing of this publication is not intended to create, and receipt of it does not constitute, an attorney-client relationship. The views set forth herein are the personal views of the authors and do not necessarily reflect those of the Firm.