It was announced on 6 October 2017 that the temporary lifting of US sanctions against Sudan described in our News Items of 17 January and 24 July 2017 has been made permanent. Specifically, Sections 1 and 2 of Executive Order 13067 and all of Executive Order 13412 have been revoked, allowing US persons to engage in a range of previously prohibited trades with Sudan including permitting banks to process payments in US Dollars. Details on the impact of this revocation are set out in a helpful Client Alert from the Club’s US attorneys Freehill Hogan & Mahar, which can be found here.
It should be noted however that the US still maintains the South Sudan Sanctions Regulations and the Darfur Regulations under which certain parties remain on the SDN list and it continues to be prohibited for US persons to deal with those entities. US Members are therefore advised to continue to undertake due diligence when fixing for Sudan to make sure that no remaining SDNs are involved in the intended trade.
No changes have been made in the EU sanctions against Sudan, but these are limited. Only four entities currently appear on the EU SDN list for Sudan.
Any Member with questions concerning the impact of these measures and any other sanctions matters should contact the Managers.