On Tuesday, July 12, 2017, President Trump issued an Executive Order in order to amend Executive Order 13761, which was issued by the Obama Administration in January of 2017. Today’s amendments to EO 13761 allow the State Department additional time to prepare its report on whether the Government of Sudan has sustained the positive activities that the Obama Administration recognized when it originally issued EO 13761.  EO 13761 originally required the report to be delivered by July 12, 2017, but President Trump’s new order pushes that deadline back to October 12, 2017.

These sanctions were put in place by President Clinton in 1997 in response to Sudan’s human rights violations and alleged state-sponsorship of terrorism. President Trump was widely expected to lift several of the sanctions this week, however, in light of the three-month delay, the Administration will continue to assess whether Sudan has made any progress on counterterrorism and human rights. The State Department issued a press release stating that “the Administration is also committed to intensifying engagement with the GOS on a broader range of vital issues, including our ongoing dialogue on improving Sudan’s human rights and religious freedom practices, and ensuring that Sudan is committed to the full implementation of UN Security Council resolutions on North Korea.”  This recent statement implies that a partial reason for the delay may be due to the threat of North Korea.  It is also worth noting that Sudan remains one of six countries named in the Trump Administration’s travel ban.

In connection with EO 13761, OFAC also issued a general license which temporarily lifted some of the sanctions against Sudan and allowed U.S. persons to process transactions involving persons in Sudan; engage in imports and exports; and engage in transactions involving property in which the Government of Sudan has an interest. That general license remains in effect following today’s Executive Order and additional information concerning its temporary lifting of certain sanctions is available here.

We will continue to report further developments and action taken by the Administration. As the situation for trade between the U.S. and Sudan is still fluid, financial institutions and prospective exporters should continue to carefully monitor the Sudanese Sanctions Regulations.  For guidance on navigating any of the U.S. sanctions programs and ensuring your business is in compliance with U.S. export regulations, contact Cortney Morgan, Linda Tiller, or Grant Leach.