On January 14, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that it has amended the Export Administration Regulations (“EAR”) to formally implement the rescission of Sudan’s designation as a State Sponsor of Terrorism (“SSOT”), which was rescinded by the Secretary of State on December 14, 2020.  BIS has amended the EAR accordingly by removing Sudan from Country Group E:1 (Terrorist supporting countries), which lists destinations subject to Anti-Terrorism (“AT”) controls.  Sudan is now under Country Group B.  As a result, most shipments destined for Sudan qualify for a general 25 percent de minimis level and shipments may now qualify for several additional license exceptions under the EAR.

Should you have any questions or concerns regarding to this change in Sudan’s status, please contact Cortney Morgan or Grant Leach of Husch Blackwell’s Export Controls & Economic Sanctions team.