On May 4, 2023, the President Biden issued Executive Order 14098 (“EO 14098“) establishing a sanctions authority that authorizes the US Government to imposes sanctions on persons or entities in Sudan in connection with “the military’s seizure of power in October 2021 and the outbreak of inter-service fighting in April 2023.”

While no sanctions have been imposed under EO 14098 to date, this new Sudan sanctions authority authorizes the US Government to issue asset blocking sanctions against persons or entities who engage in certain conduct in Sudan, including in particular by engaging in:

  • actions or policies that threaten the peace, security, or stability of Sudan;
  • actions or policies that undermine the formation or operation of a civilian transitional government, Sudan’s transition to democracy, or a future democratically elected government;
  • censorship that limits access to free and independent news or information in or with respect to Sudan, and acts of corruption including bribery and misappropriation of state assets;
  • the targeting of women, children, or any other civilians through acts of violence, abduction, forced displacement, or through conduct that would constitute a serious abuse or violation of human rights or international humanitarian law; and
  • the obstruction of and/or attacks on United Nations missions and the delivery of humanitarian assistance.

EO 14098 also authorizes asset blocking sanctions of individuals in certain leadership positions (i.e., a leader, official, senior executive officer, or member of the board of directors) of any entities that have engaged in the above-mentioned activities.  Further, EO 14098 authorizes asset blocking sanctions of non-US Persons that materially assist or support the above-mentioned activities, or that materially assist or support any person or entity designated under EO 14098.  

In addition, OFAC updated a Sudan-related FAQ 836 to reflect the issuance of EO 14098.  Please also see our blog posts on the prior revocation of certain Sudan sanctions here, and on Sudan’s prior removal from the State Sponsor of Terrorism list here.


Terry Gilroy is a partner in the New York office of Baker McKenzie and a member of the Investigations Compliance and Ethics Practice Group. Prior to joining the Firm in 2018, Terry served as Americas Head of the Financial Crime Legal function at Barclays. Terry advises businesses and individuals on white collar and financial crime issues and has significant experience conducting investigations relating to compliance with the US Foreign Corrupt Practices Act (FCPA) and related bribery and corruption statutes, economic sanctions regulations as administered by the US Department of the Treasury's Office of Foreign Assets Control (OFAC), and the Bank Secrecy Act and related anti-money laundering (AML) regulations and statutes. Terry spent six years on active duty in the United States Army as a Field Artillery officer.


Eunkyung advices clients on various regulatory compliance and trade issues, concentrating on the US export controls such as the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR), economic and trade sanctions, US customs and import laws, the US Foreign Corrupt Practices Act (FCPA), and foreign anti-bribery laws.


Daniel’s practice focuses on US economic and trade sanctions, including those targeting Iran, Russia, Cuba, Syria, and North Korea, export controls, and anti-boycott laws. He represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), and has experience in federal court litigation and congressional investigations. His pro bono practice includes providing sanctions and export control advice to a global humanitarian NGO.