On 6 October, the Trump administration announced that it would permanently revoke economic sanctions against Sudan, effective 12 October 2017. The State Department published this decision in the Federal Register, 82 Fed. Reg. 47287, on 11 October 2017. This decision means that US companies can invest in Sudan and export their products and services to Sudan, subject to compliance with US export controls under International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), which are not affected by the revocation of the sanctions. Further, effective 12 October 2017, all blocked assets are permanently unblocked; however, in many instances, officials will need some time to determine who has the rightful claim to the unblocked assets. The Darfur and South Sudan sanctions remain in effect. Thus, US persons are prohibited from engaging with any specially designated nationals designated under these programmes.

Our analysis on the removal of the sanctions is available here.