On May 17, the U.S. Treasury Department's Office of Foreign
Assets Control (OFAC) announced it will be issuing a revised set of
sanctions regulations against South Sudan. South Sudan has been
sanctioned by OFAC since 2014, largely on the basis of widespread
violence and human rights abuses. The proposed new regulations
would amend the original regulations issued in 2014, to impose a
more comprehensive regulatory program, provide additional
interpretive and definitional guidance, and issue certain general
licenses.
Unlike Iran, Cuba, Syria, North Korea, Crimea, Donetsk and
Luhansk, South Sudan is not embargoed. U.S. persons are generally
permitted to engage in transactions in, through, or with persons
and entities in or from South Sudan, unless the counterparty or
another interested party is on OFAC's Specially Designated
Nationals and Blocked Persons List (the "SDN List," and
each such person or entity an "SDN"). In addition to a
ban on commercial activity by U.S.
