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OFAC Revises FAQs on TSRA License Applications, Sudan Sanctions

The Office of Foreign Assets Control on April 12 issued revised guidance for submitting certain license applications and for the agency’s Sudan sanctions program. In frequently asked questions 97 and 98, OFAC provided guidance for how exporters can submit license…

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applications under the Trade Sanctions Reform and Export Enhancement Act of 2000 and what information should be included in those applications. In FAQ 500, OFAC clarified that exporters of humanitarian goods, including agricultural commodities and medicine, don’t need an OFAC license to ship to Sudan. In FAQ 836, the agency detailed which Sudanese sanctions were lifted as a result of the December 2020 U.S. decision to rescind Sudan’s designation as a state sponsor of terrorism (see 2012170015 and 2101140018). OFAC stressed that the revocation of the sanctions doesn’t affect agency enforcement investigations into violations that took place before the sanctions were revoked.