On Tuesday, 17 January 2017, the Treasury Department’s Office of Foreign Assets Control (OFAC) published in the Federal Register a far-reaching amendment to its Sudanese Sanctions Regulations (SSR), 31 CFR Part 538. While styled as a “general license,” the amendment will have the practical effect of terminating the embargo of Sudan that the US imposed in 1997. All of the prohibitions contained in OFAC’s SSR, 31 CFR Part 538, will be rescinded on 17 January, even though the relevant Executive Orders will not be officially revoked until July 2017 (unless, of course, the incoming Trump administration reverses the outgoing Obama administration’s decision to lift sanctions). Read here our analysis on the practical impacts of lifting the embargo and the additional constraints.
