Overview
UN Sanctions
In 2004, under UN Resolution 1556, the Security Council imposed an arms embargo on all non-governmental entities and individuals operating in Darfur, in response to acts of violence and violations of human rights by various parties, in particular the Janjaweed.
In 2005, due to the failure to comply fully with the demands of the UN, as well as condemning the continued violations of the N’Djamena Ceasefire Agreement and the Abuja Protocols, and the failure of the Government of Sudan to disarm Janjaweed militiamen, the UN expanded the scope of the arms embargo to apply to all parties to the Agreement and any other belligerents in Darfur, including the Sudanese Government.
At the same time, the Council also imposed a travel ban and assets freeze on individuals (subsequently extended to entities), to be designated by its Sanctions Committee under UN Resolution 1591.
EU Sanctions
The EU first imposed sanctions in relation to Sudan in 1994 in response to the civil war in the southern part of the country. In 2005, the EU implemented the UN sanctions on Sudan by merging them with the existing EU arms embargo on Sudan. Current EU sanctions are contained in Council Regulation (EU) No 747/2014 and Council Decision 2014/450/CFSP, which implement UN sanctions and autonomous sanctions, which consist of an arms embargo, assets freeze, and travel bans.
UK Sanctions
The UK implements UN sanctions and an autonomous regime under the Sudan (Sanctions) (EU Exit) Regulations 2020, consisting of an arms embargo, assets freeze, and travel bans.
US Sanctions
In response to the Government of Sudan’s alleged support for international terrorism, US President Bill Clinton declared a national emergency with respect to Sudan in 1997 by EO 13067, which prohibited imports to and exports from Sudan, and empowered the US Treasury to impose assets freeze and travel bans.
The listing of Sudan as a State Sponsor of Terrorism was rescinded in 2020 and therefore Sudan is no longer subject to prohibitions under the Terrorism List Governments Sanctions Regulations, 31 CFR part 596 (TLGSR), or section 906(a)(1) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (22 U.S.C. 7205). Sections 1 and 2 of E.O. 13067 and all of E.O. 13412 were revoked in 2017.
However, EO 14098 and EO 13400 are still in effect which authorise assets freeze, travel bans, and implement UN sanctions, including the arms embargo.
Current UN Sanctions
In 2004, under UN Resolution 1556, the Security Council imposed an arms embargo on all non-governmental entities and individuals operating in Darfur, in response to acts of violence and violations of human rights by various parties, in particular the Janjaweed.
In 2005, due to the failure to comply fully with the demands of the UN, as well as condemning the continued violations of the N’Djamena Ceasefire Agreement and the Abuja Protocols, and the failure of the Government of Sudan to disarm Janjaweed militiamen, the UN expanded the scope of the arms embargo to apply to all parties to the Agreement and any other belligerents in Darfur, including the Sudanese Government.
At the same time, the Council also imposed a travel ban and assets freeze on individuals (subsequently extended to entities), to be designated by its Sanctions Committee under UN Resolution 1591.
- Resolutions
UN Resolution 1591 (2005), creates the Sanctions Committee and expands arms embargo.
UN Resolution 1556 (2004), imposes arms embargo.
- Sanctions List
- Guidance
Current EU Sanctions
The EU first imposed sanctions in relation to Sudan in 1994 in response to the civil war in the southern part of the country. In 2005, the EU implemented the UN sanctions on Sudan by merging them with the existing EU arms embargo on Sudan. Current EU sanctions are contained in Council Regulation (EU) No 747/2014 and Council Decision 2014/450/CFSP, which implement UN sanctions and autonomous sanctions, which consist of an arms embargo, assets freeze, and travel bans.
Current UK Sanctions
The UK implements UN sanctions and an autonomous regime under the Sudan (Sanctions) (EU Exit) Regulations 2020, consisting of an arms embargo, assets freeze, and travel bans.
Current US Sanctions
In response to the Government of Sudan’s alleged support for international terrorism, US President Bill Clinton declared a national emergency with respect to Sudan in 1997 by EO 13067, which prohibited imports to and exports from Sudan, and empowered the US Treasury to impose assets freeze and travel bans.
The listing of Sudan as a State Sponsor of Terrorism was rescinded in 2020 and therefore Sudan is no longer subject to prohibitions under the Terrorism List Governments Sanctions Regulations, 31 CFR part 596 (TLGSR), or section 906(a)(1) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (22 U.S.C. 7205). Sections 1 and 2 of E.O. 13067 and all of E.O. 13412 were revoked in 2017.
However, EO 14098 and EO 13400 are still in effect which authorise assets freeze, travel bans, and implement UN sanctions, including the arms embargo.
- Legislation
Darfur Peace and Accountability Act of 2006
Trade Sanctions Reform and Export Enhancement Act of 2000
EO 14098 – Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition (May 4, 2023)
EO 13804 – Allowing Additional Time for Recognizing Positive Actions by the Government of Sudan and Amending Executive Order 13671 (July 11, 2017)
EO 13761 – Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions (January 13, 2017)
EO 13412 (fully repealed) – Blocking Property and Prohibiting Transactions With the Government of Sudan (October 13, 2006)
EO 13400 – Blocking Property of Persons in Connection With the Conflict in Sudan’s Darfur Region (Effective Date – April 27, 2006)
EO 13067 (sections 1 and 2 repealed) – Blocking Sudanese Government Property and Prohibiting Transactions With Sudan (Effective Date – November 4, 1997)
- Sanctions List
Search “Sudan” on the OFAC SDN List
- Guidance
- US General Licences
Sudan General License Number 1 – Official Business of Certain International Organizations and Entities (June 1, 2023)
Sudan General License Number 2 – Certain Transactions in Support of Nongovernmental Organizations’ Activities (June 1, 2023)
Sudan General License Number 3 – Transactions Related to the Provision of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, and the Extraction, Processing, Transport, Sale, or Distribution of Water in Sudan (June 1, 2023)
Sudan General License Number 4 – Authorizing the Wind Down of Transactions Involving Defense Industries System or Al Junaid Multi Activities Co Ltd. (June 1, 2023)
