On December 14, 2020, the State Department announced that the United States was rescinding Sudan’s designation as a State Sponsor of Terrorism. The brief statement indicated that this removal “represents a fundamental change in our bilateral relationship toward greater collaboration and support for Sudan’s historic democratic transition. This achievement was made possible by the efforts of Sudan’s civilian-led transitional government to chart a bold new course away from the legacy of the Bashir regime.”
From a U.S. export control and sanctions perspective, this announcement should set the stage for the removal of Sudan from the anti-terrorism (AT) list under the Export Administration Regulations (EAR) and remove the Department of Commerce’s Bureau of Industry and Security’s (BIS) general policy of denial for issuing any export licenses for U.S. exporters seeking to do business in Sudan. While the Treasury Department’s Office of Foreign Assets Control (OFAC) relaxed its sanctions program toward Syria in 2017 (see OFAC – Sudan Sanctions), this action should also lead to further changes to OFAC’s Sudanese sanctions regulations.