Sudan General License Number 2 - Certain Transactions in Support of Nongovernmental Organizations’ Activities (June 1, 2023)

Date issued: Jun. 01 2023

Last substantive commentary amendment:
Feb. 16 2024

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TURBOFAC Commentary (579 words)

Notes:

[3-5-24 update - this GL was implemented into the CFR at 546.512]

1) For comments on the aspects of NGO-related GLs such as this that are conducive to cross-programmatic comment, refer to General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations (NGOs) (System Ed. Note).

2) Compare Ethiopia GL 2. Here there is a qualifier starting that "the nongovernmental organization is not a person whose property or interests in property are blocked pursuant to E.O. 14098," and there is "activities designed to directly benefit the civilian population" language that may or may not actually limit the scope of the GL vis-a-vis GLs such as Ethiopia GL 2. In other words, it is not clear whether "activities designed to directly benefit the...