U.S. persons are no longer prohibited from engaging in transactions with respect to Sudan or the Government of Sudan that were previously prohibited by the Sudanese Sanctions Regulations, 31 C.F.R. part 538 (SSR). Effective October 12, 2017, sections 1 and 2 of Executive Order (E.O.) 13067 of November 3, 1997 and all of E.O. 13412 of October 13, 2006 were revoked, pursuant to E.O. 13761 of January 13, 2017, as amended by E.O. 13804 of July 11, 2017. To reflect this revocation of authorities, OFAC removed the SSR from the Code of Federal Regulations (C.F.R.) on June 29, 2018.
In addition, because the determination regarding Sudan as a State Sponsor of Terrorism was rescinded on December 14, 2020, Sudan is no longer subject to prohibitions under the Terrorism List Governments Sanctions Regulations, 31 C.F.R. part 596 (TLGSR), or section 906(a)(1) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (22 U.S.C. 7205).
However, the national emergency declared with respect to the Government of Sudan in E.O. 13067 remains in effect, as expanded upon in scope by subsequent E.O.s to include the violence in Sudan’s Darfur region. This national emergency provides the basis for OFAC’s sanctions on individuals and entities in connection with the conflict in Darfur, which were imposed pursuant to E.O. 13400 of April 26, 2006 and in part implement sanctions with respect to the conflict in Darfur adopted by the United Nations Security Council.
Additionally, while persons designated pursuant to the blocking authorities of E.O. 13067 or E.O. 13412 were removed from OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) due to the revocation of those sanctions authorities on October 12, 2017, Sudanese persons may still be designated or blocked pursuant to other sanctions authorities.
Note that the revocation of certain sanctions with respect to Sudan and the Government of Sudan does not affect past, present, or future OFAC enforcement investigations or actions associated with any apparent violations of the SSR that occurred prior to October 12, 2017 or of the TLGSR prior to December 14, 2020.