On June 1, 2023, the Office of Foreign Assets Control (OFAC) issued four new Sudan-related General Licenses authorizing certain transactions that would otherwise be prohibited by Executive Order (EO) 14098 dated May 4, 2023 (See Update of May 4, 2023):

  • General License No. 1 authorizes transactions for the conduct of the official business of certain international organizations and entities, including but not limited to the International Centre for Settlement of Investment Disputes (ICSID) and the Multilateral Investment Guarantee Agency (MIGA); the Intergovernmental Authority on Development (IGAD); and the International Federation of Red Cross and Red Crescent Societies.
  • General License No. 2 authorizes certain transactions that are ordinarily incident and necessary to the certain described activities by nongovernmental organizations (NGOs), provided that the nongovernmental organization is not a person whose property or interests in property are blocked pursuant to EO 14098.  Covered activities must be non-commercial in nature and designed to directly benefit the civilian population, including:  (i) humanitarian projects, (ii) democracy building, and (iii) educational support.
  • General License No. 3 authorizes transactions related to the provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates, and the extraction, processing, transport, sale, or distribution of water in Sudan; and
  • General License No. 4 authorizes the wind down of transactions through July 31, 2023 involving Defense Industries System or Al Junaid Multi Activities Co. Ltd., or any entity owned or controlled by these by a 50 percent or greater interest.  Note:  these two Sudanese entities were separately placed on OFAC’s Specially Designated Nationals (SDN) List on June 1, 2023. 

Certain transactions remain unauthorized under these general licenses and therefore require close analysis.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.