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ARTICLE · 19 JANUARY 2017

With Trump's Approval, Obama Administration To Terminate Sudan Sanctions Program

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As explained below, this new rule does not remove any existing license requirements for exports or reexports to Sudan.

United StatesInternational Law
Shiva Aminian
Shiva Aminian
Mahmoud Baki Fadlallah
Mahmoud Baki Fadlallah
Thomas McCarthy
Thomas McCarthy
Jonathan Poling
Jonathan Poling
Tatman Savio
Tatman Savio
Christian Davis
Christian Davis
Johann Strauss
Johann Strauss
Wynn Segall
Wynn Segall
Alexis G. Guinan
Alexis G. Guinan
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Key Points

  • Effective today, a new general license reverses two decades of U.S. policy by authorizing all transactions otherwise prohibited by the Sudanese Sanctions Regulations (SSR), including all transactions with Sudan or the Government of Sudan. In a parallel action, the Bureau of Industry and Security announced today that the agency has changed its review policy for applications for licenses to export or reexport certain items to Sudan from a policy of denial to a policy of approval.
  • President Obama issued an executive order effective July 12, 2017, revoking prior executive orders underlying the SSR and effectively abolishing the Sudan sanctions program, provided that the incoming Secretary of State issues a finding regarding Sudan's cooperation. This requirement corroborates press reports suggesting that these actions were taken with the approval of President-elect Trump's incoming administration.

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