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Financial Services Law Insights and Observations

OFAC amends FAQs on Sudan sanctions

Financial Crimes Department of Treasury OFAC Sanctions OFAC Designations Of Interest to Non-US Persons Sudan

Financial Crimes

On April 12, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published amended frequently asked questions related to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) and the Sudan Program and Darfur Sanctions. FAQs 97 and 98 clarify TSRA licensing application options and steps, which require that applicants provide all relevant information for parties, including financial institutions and purchasing agents, that may be involved in the proposed transactions. FAQ 500 explains that persons are no longer required to obtain specific licenses from OFAC to export or reexport agricultural commodities, medicines, or medical devices to Sudan. Finally, FAQ 836 states that U.S. persons are no longer prohibited from engaging in transactions with respect to Sudan or the Government of Sudan that were previously prohibited by the Sudanese Sanctions Regulations, 31 C.F.R. part 538.

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