Frequently Asked Questions

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Sudan, Darfur, and South Sudan-related Sanctions

57. Are Non-Governmental Organizations (NGOs) involved in humanitarian or religious activities in Sudan still required to obtain an NGO registration number?

No. The general license at 31 C.F.R. § 538.540 authorizes all transactions prohibited under the Sudanese Sanctions Regulations, 31 C.F.R. part 538, effective January 17, 2017. As a result, NGOs are no longer required to obtain an NGO registration number to operate in or transact with Sudan.

368. Are humanitarian aid groups prohibited from making payments to or otherwise transacting with non-designated individuals or entities in South Sudan, including militias and armed groups under the command or control of a designated individual?

An entity in South Sudan that is commanded or controlled by an individual designated under Executive Order 13664 is not considered blocked by operation of law. Payments, including “taxes” or “access payments,” made to non-designated individuals or entities under the command or control of an individual designated under E.O. 13664 do not, in and of themselves, constitute prohibited activity. U.S. persons should employ due diligence, however, to ensure that an SDN is not, for example, profiting from such transactions.

506. Did OFAC make any changes to sanctions with respect to Sudan and the Government of Sudan on July 11, 2017?

No. The President issued an executive order on July 11, 2017, extending the review period established by E.O. 13761 of January 13, 2017, which set forth criteria for the revocation of certain sanctions on Sudan and the Government of Sudan (GOS). The new E.O. extends until October 12, 2017 the period of review of the GOS’ actions. OFAC’s sanctions remain in place, as does the general license broadly authorizing most prohibited transactions with respect to Sudan (the “2017 Sudan Rule”), as described below.

836. What sanctions remain applicable to Sudan and the Government of Sudan?

For information pertaining to the status of OFAC’s Sudan and Darfur-related sanctions programs, including licensing requirements, please review the Sudan Program and Darfur Sanctions Guidance.​