On July 20, 2026, the US State Department published Public Notice 13072 imposing additional sanctions on Sudan under Section 307(b) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “Act”). The action follows the State Department’s April 24, 2025, determination under Section 306(a) of the Act, that the Government of Sudan used chemical weapons in violation of international law. Section 307(b) of the Act calls for additional sanctions unless the President certifies to Congress, within three months, that Sudan has met specified conditions. Because Sudan did not meet those conditions, on June 23, 2026, the Under Secretary for Arms Control and International Security imposed further sanctions under Section 307(b). That determination was published on June 27, 2025, under Public Notice 12749.
These additional measures include two principal sanctions. First, the US will oppose any loan or financial or technical assistance to Sudan through international financial institutions under Section 701 of the International Financial Institutions Act. This will bar the provision of assistance to Sudan through international financial institutions for basic human needs. Second, under Section 6 of the Export Administration Act of 1979, the US will prohibit the export of essentially all other goods and technology (excluding food and agricultural products) to Sudan and/or Sudanese nationals.
Several waivers to these additional sanctions will apply. The export control restrictions are waived for items not on the Commerce Control List (“CCL”). The export control restrictions will also be partially waived to allow CCL exports under certain License Exceptions (CCD, GOV, ENC, BAG, TMP, RPL, TSU, ACE per 15 CFR part 740). The notice also states that export licenses may be granted to authorize certain exports necessary for the safety of fixed wing passenger aviation, deemed exports that were authorized before the publication of the notice, exports and re-exports of goods and technology on the CCL for US wholly-owned subsidiaries and foreign subsidiaries in Sudan, each issued consistent with licensing policy in effect prior to the notice. Licenses for all other exports, reexports, or transfers (in-country) of items on the CCL to Sudan will be reviewed under a “presumption of denial.” National security-sensitive goods and technology exports to Sudan remain subject to the sanctions under Section 307(a)(5) of the Act as described in Public Notice 12749. Consistent with the above, all other licenses for the export, reexport, and transfer (in-country) of national security-sensitive goods and technology will likewise be reviewed under a “presumption of denial.”
Additionally, the Department of Transportation will take all steps necessary to suspend the authority of foreign air carriers owned or controlled by the Government of Sudan to engage in foreign air transportation to or from the United States.
The measures will remain in place for at least one year and until further notice.
Companies with any business involving exports, reexports, in-country transfers, financing, or subsidiary operations to or in Sudan should reassess their exposure.
The authors acknowledge the assistance of Tamara Kissoon in the preparation of this post.
