On April 12, 2021, the Department of the Treasury’s Office of Foreign Assets Control amended frequently asked questions related to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) and the Sudan Program and Darfur Sanctions. The TSRA Program provides guidance to persons and entities that are interested in the exportation or re-exportation of agricultural commodities, medicine and medical devices to Iran or any other country that has been determined by the US Secretary of State to support acts of international terrorism.
FAQs 97, 98, and 500 clarify the process for obtaining a TSRA license. FAQ 97 confirms that applicants are only permitted to submit TSRA license applications in two formats, via online or in hard copy; however, OFAC recommends the use of its online application portal. FAQ 98 provides that applicants should submit all pertinent information for TSRA licenses applications in a table format that includes the full names and addresses of all parties involved and their respective roles in the proposed transaction, and the commodity classification numbers associated with the proposed items to be exported. In FAQ 500, OFAC confirms that as of December 14, 2020, persons interested in exporting agricultural commodities, medicine or medical devices to Sudan are no longer required to obtain a specific license from OFAC.
FAQ 836 provides a general overview of US sanctions that currently apply to Sudan and the Government of Sudan. OFAC confirms that the Sudanese Sanctions Regulations (SSR), 31 CFR part 538, were revoked pursuant to Executive Order 13761 of January 13, 2017, as amended by EO 13804 of July 11, 2017, resulting in the SSR’s removal from the Code of Federal Regulations in June of 2018. OFAC also confirmed that Sudan’s designation as a State Sponsor of Terrorism was rescinded in December 2020, and, as a result, Sudan is no longer subject to prohibitions under the Terrorism List of Governments Sanctions Regulations or the Trade Sanctions Reform and Export Enhancement Act of 2000. However, targeted US sanctions remain in effect upon individuals and entities linked to the conflict in Darfur under EO 13400 and potentially under other sanctions programs.