Sudan General License Number 1 - Official Business of Certain International Organizations and Entities (June 1, 2023)

Date issued: Jun. 01 2023

Last substantive commentary amendment:
Feb. 16 2024

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TURBOFAC Commentary (656 words)

Notes:

[*3-5-24 update - this web GL was implemented at 546.511 of the Sudan Stabilization Sanctions Regulations.]

1) Compare 546.510 (Darfur), and see general discussion of the “official business” licenses and exemptions at General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees, Contractors, or Grantees Thereof.

This provision is standard; there is no reason to believe that it is or will be interpreted differently than its analogues in other sanctions programs, except insofar as (i) the non-UN entities listed in the GL may be program specific or otherwise rare (IGAD), and (ii) there is a subsection (b) stating that "[t]his section does not authorize funds transfers initiated or processed with knowledge or reason to know that the intended beneficiary of...