Guidance Regarding the Application of the Sudanese Sanctions Regulations to the New State to be Formed by the Secession of Southern Sudan

Date issued: Apr. 12 2011

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TURBOFAC Commentary (717 words)

Notes:

1) See comment to FAQ 490 re: the removal of the Sudanese Sanctions Regulations, along with it the repeal of 538.540, and the transfer of the Sudan TSRA provisions to 596.506.

[12-14-2020 UPDATE - 596.506 appears to be obsolete, following the Dec. 14, 2020 removal of Sudan from the State Sponsors of Terrorism list. See comments to 596.506.]

2) The background of this guidance was the secession of Southern Sudan from Sudan, which at the time of the secession was still embargoed. OFAC wished to facilitate commerce with Southern Sudan, but was statutorily barred from easing sanctions on Sudan in a way that would have accommodated all desirable commerce with Southern Sudan, in particular as it related to oil that would have transited through a pipeline located in the still-restricted areas of Sudan. ...