The United States changed two parts of its Sudan rules on January 17, 2017. The Office of Foreign Assets Control, or OFAC, authorized transactions prohibited by its Sudanese Sanctions Regulations and two named executive orders. The Bureau of Industry and Security, or BIS, separately revised its policy for reviewing certain aviation and railway export applications. [2017-00844][2017-00836]

OFAC's authorization included transactions involving Sudanese government property and the steps needed to unblock property previously blocked under section 538.201. Returning or processing funds fell within that permission. Other applicable sanctions and laws continued to apply, including Commerce and State Department export controls. Earlier violations did not become immune from enforcement because the authorization changed. [2017-00844][2017-00836]

BIS moved eligible applications from a general policy of denial to one of approval. Eligibility remained narrow: items controlled only for anti-terrorism reasons, specified civil aviation or railway purposes, and non-sensitive end users. Complete aircraft were excluded from this favorable treatment. Applications substantially benefiting sensitive users, including military, police and intelligence services, would generally be denied. [2017-00844][2017-00836]

A further OFAC condition required covered agricultural and medical exports or reexports to ship within twelve months after the contract was signed. The general license itself remained effective unless revoked. These coordinated documents therefore establish a transaction authorization and a distinct licensing-policy change. Neither establishes actual trade growth, completed deliveries or a universal exemption for exports to Sudan. [2017-00844][2017-00836]

Source documents

  1. Sudanese Sanctions Regulationshttps://www.govinfo.gov/content/pkg/FR-2017-01-17/html/2017-00844.htm
  2. Revisions to Sudan Licensing Policyhttps://www.govinfo.gov/content/pkg/FR-2017-01-17/html/2017-00836.htm