General Note on the Darfur Sanctions Regulations/Sudan Stabilization Sanctions Regulations and Underlying Authorities; EO 14098, and Their Relationship with the Sudanese Sanctions Regulations (System Ed. Note)

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TURBOFAC Commentary (1297 words)

General Note on the Darfur Sanctions Regulations/Sudan Stabilization Sanctions Regulations and Underlying Authorities; EO 14098, and Their Relationship with the Sudanese Sanctions Regulations (System Ed. Note)

Note: on 3-5-24, OFAC incorporated EO 14098 into 31 CFR Part 546, and renamed the Darfur Sanctions Regulations the "Sudan Stabilization Sanctions Regulations". The below has not yet been updated to reflect this fact, but see the various provisions of part 546, and comments thereto, for more detail.

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1) TECHNICAL BACKGROUND

The Darfur Sanctions Regulations (DSR) are irregular in a number of ways, in particular as they relate to the authorities forming the basis for the regulations.

Executive Order 13067 of November 3, 1997 is the primary EO responsible for the now-terminated comprehensive embargo against Sudan. The emergency declared pursuant to...