Trade Law

On January 13, 2017, President Obama issued Executive Order 13761 to be effective on July 12, 2017, which would revoke prior executive orders underlying the Sudanese Sanctions Regulations and effectively terminate the Sudan sanctions program, provided that the incoming Secretary of State (Rex Tillerson) issues a finding regarding Sudan’s cooperation in five key areas of engagement: countering terrorist groups, ending the threat of the Lord’s Resistance Army, ending the government’s offensive internal military operations, ending Sudan’s destabilizing role in South Sudan, and improving humanitarian access. See our prior alert on that executive order for more information.

Introduction

On January 13, 2017, the Obama administration announced that it would lift sanctions imposed on Sudan issued under the Sudanese Sanctions Regulations (SSR), which are administered by the Treasury Department’s Office of Foreign Assets Control (OFAC). The action reverses nearly 20 years of U.S. policy toward Sudan, a country that had been the target of a comprehensive trade embargo due to human rights abuses and support for international terrorism. The United States has stated that its decision comes after months of bilateral engagement with Sudan, which has revealed that country’s support for key U.S. foreign policy goals, such as ceasing hostilities in conflict areas, including Darfur, and enhancing counterterrorism cooperation.