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OFFICE OF FOREIGN ASSETS CONTROL
SUDANESE SANCTIONS REGULATIONS
31 C.F.R., PART 538, SECTION 521
REGISTRATION OF NON-GOVERNMENTAL ORGANIZATIONS (“NGOs”)
Purpose of Registration. Registration numbers may be issued on a case-by-case basis to non-governmental organizations involved in humanitarian or religious activities in Sudan.
Application Information to be Supplied. Applications for registration numbers should be submitted online using the “Transactional” category in OFAC’s online licensing module located at http://www.treasury.gov/resource-center/sanctions/Pages/licensing.aspx , or by writing to the Licensing Division, Office of Foreign Assets Control, U.S. Department of the Treasury, 1500 Pennsylvania Avenue, NW, Annex, Washington, DC 20220, and must include:
[Names of individuals and organizations should be provided in English, in the language of origin (or transliterated when not possible), and should include any acronym or other names used to identify the individuals or organizations]
(a) Organization...
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1) The now-removed Sudanese Sanctions Regulations contained a provision that made “non-governmental organizations” involvement in humanitarian or religious activities in Sudan contingent on the receipt of a registration number, issued by OFAC upon receipt of the information requested in this document. The list of items requested remains notable as an example of the sort of material that OFAC might expect an NGO to present in connection with a specific license request made pursuant to a different sanctions program.
2) The term " non-governmental organization" is not a legally defined term in U.S. sanctions regulations (it may not be a legally defined term in any federal law), and there is a range of different definitions of the term. NGO-Humanitarian Guidance (2014) suggests that, at least as it concerns U.S. person NGOs, OFAC would only consider general licenses referencing NGOs to apply to...