US Imposes Additional Sanctions on Iran's Industry

On January 10, 2020 the U.S. President issued an Executive Order(1) establishing additional sanctions on Iran. The new sanctions target the construction, mining, manufacturing, and textile sectors of the Iranian economy.

“We are also designating Iran’s largest metals manufacturers, and imposing sanctions on new sectors of the Iranian economy including construction, manufacturing, and mining”(2), said Secretary Steven T. Mnuchin.

The Executive Order blocks the property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any US person of the following:

• The 13 largest steel and iron manufacturers and the top aluminum and copper companies in Iran including Mobarakeh Steel Company, Saba Steel, Hormozgan Steel Company, Esfahan Steel Company, Oxin Steel Company, Khorasan Steel Company, South Kaveh Steel Company, Iran Allow Steel Company, Golgohar Mining and Industrial Company, Chadormalu Mining and Industrial Company, Arfa Iron and Steel Company, Khouzestan Steel Company and Iranian Ghadir Iron & Steel Company, Iran Aluminum Company, Al-Mahdi Aluminum Corporation, Khalagh Tadbir Pars Co, and the National Iranian Copper Industries.

• China entities Pamchel Trading Beijing Co Ltd, Hongyuan Marine Co Ltd and Seychelles-based (Power Anchor Limited a front company for Pamchel Trading Beijing Co, Ltd) entities; and a vessel (Hong Xun) involved with Iranian metals products.

• Oman-based Reputable Trading Source LLC, which is owned or controlled by Khouzestan Steel Company.

• Senior Iranian officials involved in recent ballistic missile strikes.

In addition, the Secretary of the Treasury is authorized to sanction foreign financial institutions that knowingly conduct or facilitate any significant financial transaction in contradiction to the Executive Order. See the Executive Order for additional restrictions and details.

Contact the professionals at GCSG for more information on this development.

References

1. Executive Order on Imposing Sanctions with Respect to Additional Sectors of Iran - January 10, 2020

2. US Department of the Treasury Press Release: “Treasury Targets Iran’s Billion Dollar Metals Industry and Senior Regime Officials” - January 10, 2020

US DOJ Revises Export Control and Sanctions Enforcement Policy

On December 13, 2019 the US Department of Justice (“DOJ”) re-issued a revised Voluntary Self-Disclosure Policy(1) (“VSD Policy”) for export control and sanctions violations. The revised VSD Policy is effective December 13, 2019 and it supersedes prior guidance issued by the US DOJ’s National Security Division in October 2016. The updated VSD Policy will be incorporated into the Justice Manual(2). Three changes from the prior guidance include(3):

• Provides more clarity on the benefits available to companies that voluntarily self-disclose violations, fully cooperate with the DOJ, and timely and properly re-mediate the issues;

• Clarifies that disclosures of willful conduct to regulatory agencies and not to DOJ will not qualify for the benefits provided under the VSD Policy; and

• The definitions(1) of “Voluntary Self-Disclosure”, “Full Cooperation”, and “Timely and Appropriate Remediation” were modified to more closely align with the Departments FCPA Corporate Enforcement Policy.

References

1. US DOJ - “Export Control and Sanctions Enforcement Policy for Business Organizations” - December 13, 2019

2. US DOJ - “Justice Manual”

3. US DOJ Press Release - “Department of Justice Revises and Re-Issues Export Control and Sanctions Enforcement Policy for Business Organizations” - December 13, 2019

OFAC Publishes a Framework for Compliance

On May 2, 2019 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)(1) published “A Framework for OFAC Compliance Commitments”(2). The publication is intended to provide OFAC’s perspective, to entities subject to US jurisdiction, on what are essential components of an effective sanctions compliance program.

“OFAC developed this framework in our continuing effort to strengthen sanctions compliance practices across the board…This underlines our commitment to engage with the private sector to further promote understanding of, and compliance with, sanction requirements.” - Andrea M. Gacki, Director of the Office of Foreign Assets Control (3)

Summary

• OFAC continues to emphasize and “strongly encourage” entities subject to U.S. jurisdiction to take a risk-based approach to sanctions compliance by “developing, implementing, and routinely updating a sanctions compliance program (“SCP”).

• Regardless of company size, sophistication, products/services, geographic locations, etc…each SCP should incorporate at least these five (5) components: management commitment, risk assessment, internal controls, testing and auditing, and training.

• In enforcement cases, OFAC will evaluate an entities SCP against the Economic Sanctions Enforcement Guidelines (the “Guidelines”)(4) and when applying the Guidelines will favorably consider an entity that had an effective SCP in place at the time a violation occurred.

A Few Key Points

• Management Commitment

  • Effective senior management commitment, among others, includes providing adequate resources for compliance and support for the authority of compliance personnel within the organization.

  • Adequate resources includes ensuring there are enough personnel with sufficient expertise dedicated to compliance, and adequate information technology, and other resources, as appropriate.

• Risk Assessment(5)

  • OFAC recommends a risk-based approach to implementation of a SCP and one of the integral components of this approach is to conduct periodic risk assessments.

  • The assessment should include, among others, a review of customers, vendors, products, services, third-party intermediaries, and geographic locations.

• Internal Controls

  • An effective SCP should include policies and procedures. These policies and procedures should be enforced and updated when weaknesses are detected or requirements change.

  • Sufficient personnel should be appointed to ensure proper integration of the company’s policies and procedures into the daily operation of the company.

  • The organization should clearly communicate their policies and procedures to all relevant staff.

• Testing and Auditing

  • An effective SCP include’s a comprehensive and objective testing or audit function that identifies program weaknesses and deficiencies.

  • Any deficiencies identified, including software systems, should be addressed.

• Training

  • An effective training program is considered an integral component of a successful SCP. The training should be provided to all appropriate employees and personnel on a periodic basis (at a minimum, annually).

• Root Causes of OFAC Compliance Program Breakdowns - OFAC has identified the following common areas where deficiencies resulted in sanctions compliance failures:

  • Lack of a formal OFAC sanctions compliance program;

  • Misinterpreting, or failing to understand the applicability of, OFAC’s regulations;

  • Facilitating transactions by non-US persons (including through or by overseas subsidiaries or affiliates);

  • Exporting or re-exporting US-origin goods, technology, or services to OFAC sanctioned persons or countries;

  • Utilizing the US financial system, or processing payments to or through US financial institutions, for commercial transactions involving OFAC-sanctioned persons or countries;

  • Sanctions screening software or filter failures;

  • Improper due diligence on customers/clients;

  • De-centralized compliance functions and inconsistent application of their SCP; and

  • Utilizing non-standard payment or commercial practices.

Contact us to learn more about OFAC’s guidance and to find out how GCSG’s Advisory and Audit teams can guide and partner with you to reduce your sanctions compliance risk and protect your company’s bottom line and reputation.

References

• (1) OFAC - administers and enforces U.S. economic and trade sanctions programs against targeted foreign governments, individuals, groups, and entities.

• (2) OFAC: "A Framework for OFAC Compliance Commitments” - 05/02/2019.

• (3) US Department of the Treasury Press Releases: “OFAC Issues a Framework for Compliance Commitments” - 05/02/2019.

• (4) 74 FR 57593-57608: “31 CFR 501 - Economic Sanctions Enforcement Guidelines” - 11/9/2009.

• (5) Risks in sanctions compliance are potential threats or vulnerabilities that, if ignored or not properly handled, can lead to violations of OFAC’s regulations and negatively affect an organization’s reputation and business.(2)

New US Sanctions on Iran's Iron, Steel, Aluminum, and Copper Sectors

On May 8, 2019, the Trump administration issued an Executive Order (EO)(1) establishing new sanctions on Iran’s iron, steel, aluminum, and copper sectors. A few key points from the EO include, but are not limited to, the following:

• “All property and interests in property that are in the United States, that hereafter come within the United States, or that are or hereafter come within the possession or control of any United States person(2) of the following persons are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in: any person determined by the Secretary of the Treasury, in consultation with the Secretary of State”:

  • to be operating in the iron, steel, aluminum, or copper sector of Iran, or to be a person that owns, controls, or operates an entity that is part of the iron, steel, aluminum, or copper sector of Iran;

  • to have knowingly engaged, on or after the date of this order, in a significant transaction for the sale, supply, or transfer to Iran of significant goods or services used in connection with the iron, steel, aluminum, or copper sectors of Iran;

  • to have knowingly engaged, on or after the date of this order, in a significant transaction for the purchase, acquisition, sale, transport, or marketing of iron, iron products, aluminum, aluminum products, steel, steel products, copper, or copper products from Iran;….

In addition to the above, there are additional prohibitions on financial institutions and financial transactions (occurring with the noted sectors). The prohibitions included in the EO include:

• the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked; and

• the receipt of any contribution or provision of funds, goods, or services from any such person.

Contact your GCSG Trade Compliance professionals for assistance in understanding how to reduce your risk and how this EO may affect your business.

References

(1) Executive Order (EO) on “Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran” - May 8, 2019

(2) United States person - means any United States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States.(1)

(3) Knowingly - with respect to conduct, a circumstance, or a result, means that a person has actual knowledge, or should have known, of the conduct, the circumstance, or the result.(1)

(4) Entity - means a partnership, association, trust, joint venture, corporation, group, subgroup, or other organization.(1)

Network of Iranian front companies disrupted by OFAC

On March 26, 2019 the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced(1) it had taken action against a network of 25 individuals and entities that had transferred over a billion dollars to the Islamic Revolutionary Guard Corps (IRGC) and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL).

The evasion scheme included a layered network of front companies and agents based in Iran, UAE, and Turkey that were set up to evade international sanctions and to gain access to the international financial system. The network exchanged devalued Iranian rials for dollars and euros.

“We are targeting a vast network of front companies and individuals located in Iran, Turkey, and the UAE to disrupt a scheme the Iranian regime has used to illicitly move more than a billion dollars in funds…Central to this network and sanctioned today pursuant to our counter terrorism authority is Iran's IRGC-controlled Ansar Bank and its currency exchange arm, Ansar Exchange, both of which used layers of intermediary entities to exchange devalued Iranian rial ultimately for dollars and euros to line the pockets of the IRGC and MODAFL…” (1)

Five front companies- UAE-based Sakan General Trading, Lebra Moon General Trading, and Naria General Trading, and Turkey-based Atlas Doviz, and the Iran-based Hital Exchange provided $800 million in funds to Ansar exchange.

Now more than ever, it is vitally important that global companies implement third-party due diligence and engagement policies. These policies are often risk-based but should be comprehensive and include at a minimum background investigation diligence and ongoing monitoring of distribution networks and contract agents.

Contact our Due Diligence compliance professionals at GCSG today to learn how we can help you mitigate your third-party risk with our due diligence reports, risk-ranking tool, policy development and implementation support, and international boots-on-the-ground third-party Audits.

References

(1) U.S. Department of the Treasury Press Releases - “United States Disrupts Large Scale Front Company Network Transferring Hundreds of Millions of Dollars and Euros to the IRGC and Iran’s Ministry of Defense.” - March 26, 2019

Freight forwarding and logistics firms to withdraw from business with Iran

According to Lloyd's Loading List, some logistics service providers have decided to halt business in Iran as a result of the re-imposition of US sanctions.  Others are taking a wait and see approach.  In addition, several major container lines such as CMA, CGM, Maersk, and MSC have withdrawn from Iran.(2)  

"Thomas Cullen, a senior analyst at logistics consulting firm Transport Intelligence, said the re-imposition of US sanctions “seems likely to be at least as brutal as the sanctions pursued for the decade prior to the JCPOA, with the US now pressing for Iran to be excluded from the SWIFT banking transaction system”."(1)

Cullen noted: “With the announcement last week that Renault was ceasing operations, something that Peugeot-Citroen decided last month, the CKD related container traffic will fall heavily. Possibly the Chinese VMs may increase inputs to compensate, but they are much weaker in this market.”(1)

Cullen added: “The leading western container lines have effectively withdrawn from services into Iran, presumably leaving shippers to arrange their own feeder services from Dubai. Once again, the Chinese carriers may be the only option.”(1)

References:

• (1) Lloyd's Loading List: "US sanctions squeeze freight firms from Iran" - 08/10/2018
• (2) Lloyd's Loading List: "CMA CGM confirms Iran exit over fears of US sanctions" - 07/11/2018     

OFAC Issues Global Magnitsky Sanctions Regulations

On June 29, 2018 the Department of the Treasury's Office of Foreign Assets Control (OFAC) published a final rule (83 FR 30541-30548) that implements the Global Magnitsky Human Rights Accountability Act (the "Act") and Presidential Executive Order 13818 (the "EO").  

The Act authorizes the US President to impose sanctions on any foreign person determined to be responsible for extrajudicial killings, torture, or other gross violations of human rights, or a government official that is responsible for, complicit in, ordering, controlling, or otherwise directing acts of significant corruption.  The EO declared a national emergency to deal with the threat of serious human rights abuse and corruption around the world.  

The published regulations prohibit all transactions previously prohibited under the EO.

The rule is effective as of June 29, 2018.

Contact the experts at GCSG for more information.

E info@globalcompliancesg.com

References:

• Executive Order 13818
• Global Magnitsky Sanctions Regulations - 83 FR 30541-30548 and 31 CFR 583
• Office of Foreign Assets Control
• US Department of the Treasury

U.S. Sanctions NK and Chinese entities supporting Kim Regime

On January 24, 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) sanctioned an additional nine entities, 16 individuals, and six vessels related to North Korea's violations of UN Security Council Resolutions (UNSCRs).  

The actions target actors located in North Korea, China, Russia, and Georgia.

"Treasury continues to systematically target individuals and entities financing the Kim regime and its weapons programs, including officials complicit in North Korean sanctions evasion schemes," - Secretary of the Treasury Steven T. Mnuchin (1)

Summary of OFAC Actions Taken

• Designated 10 representatives of the Korea Ryonbong General Corporation (Ryonbong) and one Workers' Party of Korea official - Pursuant to Executive Order (EO) 13687
• Designated 5 additional North Koreans with links to North Korean financial networks - Pursuant to EO 13810 or 13687
• Designated Beijing Chengxing Trading Co. Ltd., Dandong Jinxiang Trade Co., Ltd., and Hana Electronics JVC - Pursuant to EO 13810
• Designated five North Korean shipping companies (Gooryong Shipping Co Ltd, Hwasong Shipping Co Ltd, Korea Kumunsan Shipping Co, Korea Marine & Industrial Trdg, and CK International Ltd) and blocked six vessels (Goo Ryong, Hwa Song, Kum Un San, Un Ryul, Ever Glory, and UL JI Bong 6) as property of these five companies - pursuant to EO 13810
• Sanctioned the North Korean Ministry of Crude Oil Industry

Key Link(s):

• (1) U.S. Department of the Treasury Press Release - "Treasury Sanctions North Korean Overseas Representatives, Shipping Companies, and Chinese Entities Supporting the Kim Regime" - 1/24/2018
• Executive Order 13687 - 1/6/2015
• Executive Order 13810 - 9/21/2017
• OFAC - Office of Foreign Assets Control
• OFAC Resource Center - North Korea Designations - 1/24/2018
• US Department of the Treasury

Monday Compliance News - Around the World

GCSG's Monday Compliance News (published Tuesday the week of Jan 22) is a compilation of some of the previous weeks interesting trade compliance, anti-bribery/corruption, fraud, and due diligence news bites, from around the world.

The Impact of Retroactive Transfer Pricing Adjustments on the EU Customs Valuation | KPMG Meijburg & Co

"With its judgment of December 20, 2017 in the Hamamatsu Photonics Deutschland case, the Court of Justice of the European Union finally provided some clarity about the impact of retroactive transfer pricing adjustments...." (Click here for the article) - European Union

UK companies will face huge new VAT burden after Brexit | The Guardian

"More than 130,000 UK firms will be forced to pay VAT upfront for the first time on all goods imported from the European Union after Brexit...." (Click here for the article) - UK, European Union

Ban Ki-Moon's Nephew Pleads Guilty in Bribery Case | The Wall Street Journal

"Joo Hyun Bahn, the nephew of former United Nations Secretary-General Ban Ki-Moon, pleaded guilty on Friday to U.S. charges connected to a scheme to bribe a foreign official...." (Click here for the article) - Vietnam, U.S., Global

Canada takes the U.S. to WTO in wide-ranging trade complaint | The Globe and Mail

"The Canadian government is taking the United States to the world's trade court in a wide-ranging complaint that accuses Washington of flouting the rules of commerce." (Click here for the article) - Canada, U.S.

Deferred prosecution agreements proposed to take companies task | The Straits Times

"A new legal framework that can grant companies amnesty for certain corporate offences is being proposed in Singapore." (Click here for the article) - Singapore

Cigarettes and Murky Joint Ventures Help North Korea Evade Crackdown  | The Wall Street Journal

"Global businesses faced a deadline last week to exit joint ventures operating in North Korea, but dozens of them are still there." (Click here for the article) - North Korea, U.S., South Korea, China, Global

US Company Settles Whistleblower Lawsuit, Pays for Importer's Customs Fraud  | Global Trade Magazine

"Federal prosecutors in New York recently announced the settlement of a remarkable lawsuit relating to a scheme to evade import duties." (Click here for the article) - U.S.

SFO opens investigation into Chemring Group PLC and its subsidiary  | U.K. Serious Fraud Office News Release

"The SFO confirms it has opened a criminal investigation into bribery, corruption and money laundering arising from the conduct of business by Chemring Group plc and CTSL..." (Click here for the article) - U.K.

Monday Compliance News - Around the World

GCSG's Monday Compliance News is a compilation of some of the previous weeks interesting trade compliance, anti-bribery/corruption, fraud, and due diligence news bites, from around the world.

With GDPR looming, key compliance questions still remain | DIGIDAY

"For better or worse, preparing for the General Data Protection Regulation is a do-it-yourself exercise for advertisers in the absence of stronger direction from regulators." (Click here for the article) - European Union

Turkish banker guilty of helping Iran dodge US sanctions  | Reuters TV

WATCH: US jury finds Turkish banker guilty of helping Iran dodge US sanctions (Click here for the video) - Iran, Turkey, United States

Firms can choose not to enter corruption-ridden markets | The Straits Times

"Many well-established multinationals have decent corporate cultures.  Their top managements have been known to decide that if a country operates by practices in keeping with the company ethos, they would not do business in that country." (Click here for the article) - Singapore

Drug Company Allegedly Bribed Doctors to Sell its Powerful Opioid Spray | Gizmodo

"The State of North Carolina is suing a pharmaceutical manufacturer for allegedly bribing doctors and defrauding insurers in order to sell more of its powerful fentanyl spray, fanning the flames of the opioid crisis that has millions addicted and is shortening lifespans." (Click here for the article) - United States

PWC faces negligence claim over $2bn fraud at Colonial Bank | The Times

"Auditors at PWC were negligent and missed a 'Red Flag' over a huge fraud that contributed to the collapse of a bank during the financial crisis, an American court has found." (Click here for the article) - Global

Japan Imposes Additional Unilateral Sanctions on North Korea

On Friday, December 15, 2017 Japan imposed additional unilateral sanctions against 19 North Korean entities.  This includes companies involved in the financial services, coal, and oil trading sectors.

With the additional 19 entities, the total number of North Korean entities under Japanese sanctions now stands at 56.

(1) "According to a Foreign Ministry official, all the companies are already subject to U.S. sanctions, starting from January last year." 

Key Link(s):

• BBC News - "Japan expands unilateral sanctions against North Korea"
• Ministry of Finance, Japan - "経済制裁措置及び対象者リスト, Economic Sanctions Measures and Target List"
• (1) Nikkei Asian Review - "Japan expands unilateral sanctions on North Korea"

UK Introduces Sanctions Bill

On October 18, 2017 the UK "Sanctions and Anti-Money Laundering Bill" (the "Bill") was introduced in the upper house of the Parliament of the UK.  The UK government news release stated the Bill "ensures that when the UK leaves the EU, we can continue to impose, update, and lift sanctions and AML regimes." (1)

Most of the sanctions regimes the UK is currently complying with had their powers established in the European Communities Act of 1972.  Once the UK fully withdraws from the European Union, the Bill will establish necessary legal authority in order to continue to work with their international partners and effectively enforce sanctions regimes and money laundering regulations. 

"This will enable us to impose sanctions as appropriate either alone or with partners in the EU and around the world, to take targeted action against countries, organizations and individuals who contravene international law, commit or finance terrorism or threaten international peace and security." (2) - Alan Duncan, Minister for Europe.

Key Link(s):

• (1) UK Gov - News Release
• (2) Reuters - UK sets out new powers to impose sanctions after Brexit
• UK Gov - Department for International Trade - Export Control Joint Unit
• UK Gov - HM Revenue & Customs
• UK Gov - Home Office - UK Visas and Immigration
• UK Gov - National Crime Agency
• UK Gov - Office of Financial Sanctions Implementation HM Treasury
• UK Gov - Public consultation on the United Kingdom's future legal framework for imposing and implementing sanctions
• UK Gov - Sanctions and Anti-Money Laundering Bill
• UK Gov - Sanctions and Anti-Money Laundering Bill - Explanatory Notes       
• UK Gov - Sanctions and Anti-Money Laundering Bill - Impact Assessment
• UK Gov - Sanctions and Anti-Money Laundering Bill - Track Progress of the Bill

Sudan Sanctions Revoked

     On January 13, 2017 the US President issued Executive Order (E.O.) 13761 (further amended by E.O. 13804 on July 11, 2017) providing for the revocation of certain Sudan-related sanctions.  The action was taken in recognition of the positive actions taken by the government of Sudan.  Following the initial E.O., on October 6, 2017, the US Government officially revoked economic sanctions on the Government of Sudan under E.O.'s 13067 and 13412. 

     The revocation of certain sanctions indicates the Government of Sudan has continued to make strides in reducing conflict areas in Sudan, improving humanitarian access, and in cooperating with the US Government with regional conflicts and terrorism.

What changed?

• Effective October 12, 2017 sections 1 and 2 of E.O. 13067 and all of E.O. 13412 were revoked.  Sections 1 and 2 blocked property of the government of Sudan and prohibited U.S. persons from engaging in transactions with Sudan and the government of Sudan.  The revocation of these provisions will allow U.S. persons to engage in transactions that were previously prohibited under the Sudanese Sanctions Regulations (SSR), 31 CFR 538.
• Effective October 12, 2017, General License A authorizes exports and re-exports of certain agricultural commodities, medicine, and medical devices still controlled as a result of Sudan remaining on the State Sponsors of Terrorism List (SST List) 

What hasn't changed? 

• The national emergency declared under E.O. 13067 remains in effect in regards to Sudan.
• The OFAC sanction related to the Darfur conflict imposed under E.O. 13400 remains in effect.
• OFAC designations of any Sudanese persons under E.O. 13067 and 13412 remain in effect. 
• Sudan remains on the SST List; and as a result some agricultural, medicinal, and medical device exports and re-exports to Sudan still require an OFAC license (see General License A comment above).   
• US persons and non-US persons will still need to obtain Department of Commerce Bureau of Industry and Security (BIS) licenses to export or re-export certain items such as commodities, software, and technology that are on the Commerce Control List (CCL), Supplement No. 1 to part 774 of the Export Administration Regulation (EAR), 15 CFR parts 730-774 or that require a license due to end-use or end-user concerns, 15 CFR 744. 

     Contact GCSG experts at info@globalcompliancesg.com with any questions or for more information on how we can assist you with your compliance program.  Visit our website at http://www.globalcompliancesg.com to learn more about our products and services. 

Key Link(s):

• Commerce Control List, Supplement No. 1 to part 744
• Executive Order 13067 - Blocking Sudanese Government Property and Prohibiting Transactions with Sudan (November 5, 1997)
• Executive Order 13400 - Blocking Property of Persons in Connection with the Conflict in Sudan's Darfur Region (April 26, 2006)
• Executive Order 13412 - Blocking Property and Prohibiting Transactions with the Government of Sudan (October 17, 2006)
• Executive Order 13761 - Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions (January 13, 2017)
• Executive Order 13804 - Allowing Additional Time for Recognizing Positive Actions by the Government of Sudan and Amending Executive Order 13761 (July 11, 2017) 
• Office of Foreign Assets Control FAQs Here and Here - Frequently Asked Questions regarding the revocation of certain sanction with respect to Sudan and the government of Sudan
• State Sponsors of Terrorism List
• Sudan General License A - Authorizing Certain Transactions Pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (October 6, 2017)
• The US Department of State: The Secretary's Report on Whether the Government of Sudan has Sustained the Positive Actions that Gave Rise to E.O. 13761 (2017)
• 15 CFR 744 - Control Policy: End-User and End-Use Based
• 31 CFR 538 - Sudanese Sanctions Regulations