On January 13, 2017, President Obama signed Executive Order 13761 (“E.O. 13761”), “Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions.” Effective July 12, 2017, E.O. 13761 provides for the permanent revocation of sanctions imposed by E.O. 13067 and E.O. 13412, provided the Government of Sudan sustains certain recent “positive actions.” E.O. 13761 would effectively end the United States’ comprehensive embargo against Sudan in July of this year.

In addition, effective January 17, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), has issued a general license authorizing all transactions prohibited by the Sudanese Sanctions Regulations (“SSR”), including those transactions involving property in which the Government of Sudan has an interest. Transactions with any party listed as a Specially Designated Nationals (“SDNs”) under E.O. 13400 or the South Sudan sanctions, however, remain prohibited. SDNs listed under E.O. 13400 were listed as a result of their involvement in the conflict in Sudan’s Darfur region.