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.