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Sudan

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The UK has issued the Global Anti-Corruption Sanctions Regulations 2021 (the “Regulations“), which came into force on 26 April 2021. These Regulations are designed to ensure that sanctions relating to serious incidents of corruption are enforced. The Regulations will give the government the power to impose asset freezes on designated persons or those dealing with them, with the aim of preventing the UK from being used as a “haven for dirty money.” This is the first time…

On January 14, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to remove Sudan’s designation as a State Sponsor of Terrorism (SST) (the “Amendments”). The Amendments implement the rescission of Sudan as an SST as announced by the Trump Administration in December 2020 by removing Anti-Terrorism (AT) and related controls on Sudan, which had remained in force following the US Government’s revocation of comprehensive sanctions in October 2017. …

On December 14, 2020, the US Government announced Sudan’s removal from the list of State Sponsors of Terrorism (the “SST List”).  This rescission of Sudan as an SST follows an agreement in October for Sudan to be removed from the list and the lapse of a 45 day congressional notification period. The federal register notice regarding the rescission is available here. As detailed in our previous blog post here, the US Government revoked Sudan sanctions in October 2017, but Sudan’s…

On November 2, 2017, the Federal Register published Presidential Notice of October 31, 2017 – Continuation of the National Emergency With Respect to Sudan, which extends for an additional year the national emergency first declared in Executive Order (EO) 13067 (November 3, 2017) and took related steps to deal with the unusual and extraordinary threat to the national security and foreign policy of the United States posed by the actions and policies of the Government of Sudan.

On October 6, 2017, the US Government announced that it will revoke certain sanctions with respect to Sudan and the Government of Sudan, effective October 12, 2017.  As a result of the revocation, US Persons will no longer be prohibited from engaging in Sudan-related transactions that were previously prohibited under the Sudanese Sanctions Regulations (“SSR”), including dealings with the Government of Sudan, and the SSR will be removed from the US Code of Federal Regulations.

On January 17, 2017, Office of Foreign Assets Control (OFAC) published in the Federal Register a final rule amending the Sudanese Sanctions Regulations (31 C.F.R. Part 538) to authorize all prohibited transactions, including transactions involving property in which the Government of Sudan has an interest. OFAC is issuing this general license in connection with ongoing U.S.-Sudan bilateral engagement and in response to positive developments in the country over the past six months related to bilateral cooperation, the ending of internal hostilities, regional cooperation, and improvements to humanitarian access.

On January 17, 2017, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule [Docket No. 160901810–6810–01] that revises the policy of review for applications for licenses to export or reexport to Sudan certain items that are intended to ensure the safety of civil aviation or the safe operation of fixed-wing, commercial passenger aircraft. Such applications will now be reviewed under a general policy of approval rather than a general policy of denial.