OFAC FAQ (Current) # 98 - Questions Regarding Licenses Authorizing Exports Pursuant to TSRA

Date issued: Apr. 12 2021

TURBOFAC Commentary (190 words)

Notes:

1) FAQ amended on Aug. 11, 2020 "to reflect that Sudan has not been a comprehensively sanctioned country since October 12, 2017" (by adding the reference to § 596.506) (see https://web.archive.org/web/20221207223105/https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20200811). Addition of "we highly recommend the use of OFAC’s online application portal."

2) FAQ amended on 4/12/2020 to remove the following statement: "As of January 17, 2017, a specific license from OFAC is not required to export or reexport agricultural commodities, medicines, or medical devices to Sudan, as such transactions are authorized by a general license now set forth in 31 C.F.R. § 596.506."

596.506 was no longer effect as of the Dec. 14, 2020 removal of Sudan from the State Sponsors of Terrorism list. See comments to 596.506.

3) See General Comment on the Relationship Between "Brokering Services" and Authorities Permitting or Exempting Transactions "Ordinarily Incident" to Other Transactions (System Ed. Note), noting the significance of this FAQ assuming that an Iranian broker, other than the purchaser, may be involved in a given sale.