On March 22, 2018, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) adding, in relevant part, 15 South Sudanese entities to the Export Administration Regulations’ (“EAR”) Entity List — a step that increases the pressure on that country following the US Government’s 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. Specifically, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended the Sudanese Sanctions Regulations, 31 C.F.R. Part 538 (“SUSR”), to include a new general license authorizing the export or reexport to Sudan of certain software, hardware, and services incident to personal communications. In coordination with OFAC, the US Commerce Department’s Bureau…