On March 22, 2018, the US Department of Commerceās Bureau of Industry and Security (āBISā) issued a final rule (the āFinal Ruleā) adding, in relevant part, 15 South Sudanese entities to the Export Administration Regulationsā (āEARā) Entity List ā a step that increases the pressure on that country following the US Governmentās imposition of an arms embargo last month. All 15 entities are subject to a license requirement for all exports, reexports, or in-country transfers of items subject to the EAR, and new license applications for these entities are subject to a presumption of denial.
On 18 February 2015, the US Government issued final rules relaxing certain export and reexport restrictions imposed under US sanctions targeting Sudan. Ā Specifically, the US Treasury Departmentās Office of Foreign Assets Control (āOFACā) amended the Sudanese Sanctions Regulations, 31 C.F.R. Part 538 (āSUSRā), to include a new general license authorizing the export or reexport to Sudan of certain software, hardware, and services incident to personal communications.Ā In coordination with OFAC, the US Commerce Departmentās Bureau…