The U.S. Department of State announced that Sudan’s designation as a “State Sponsor of Terrorism” has been officially rescinded effective December 14, 2020. In October, the President notified Congress that Sudan’s designation would be rescinded and certified that Sudan had not provided support for acts of terrorism within the last six months, and that Sudan has provided assurances it will not support terrorism in the future. Until the Export Administration Regulations (“EAR”) are amended, however, items controlled under Export Control Classification Numbers (“ECCNs”) that are subject to anti-terrorism (“AT”) controls will still require a license for export or reexport to Sudan pursuant to the AT controls under Section 742.10 of the EAR. Once the Department of Commerce adopts those amendments to the EAR, it will be permissible to export or reexport AT-controlled ECCN items to Sudan without a license.

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