U.S. Department of the Treasury

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.

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.

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.

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.​