Sanctions Top-5 for the week ending 23 October 2020

Here are five things that happened this week in the world of economic sanctions that I think you should know about.

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  1. The White House formally notified Congress that Sudan would be removed from the State Department’s list of State Sponsors of Terrorism. As mentioned last week, the US Office of Foreign Assets Control (OFAC) lifted its comprehensive sanctions on Sudan in October 2017. (More on this below.)


Sudan is one country that has benefited from some relative continuity in the approaches taken by the Obama and Trump administrations since 2017. Barack Obama issued Executive Order 13761 on 13 January 2017, a few days before Donald Trump’s inauguration. That order would have allowed OFAC’s Sudan-related sanctions to terminate automatically on 12 July 2017. The Trump administration extended the deadline under Executive Order 13804, and OFAC’s comprehensive sanctions expired accordingly on 12 October 2017. Since then, Sudan has been subject to heightened export controls under the Export Administration Regulations (EAR) owing to its inclusion on the State Department’s list of State Sponsors of Terrorism. Those will also be lifted in due course. (NB: Any breaches of the sanctions that took place before 12 October 2017 are still fair game for an OFAC enforcement action.)

The decision accompanied the announcement that Sudan and Israel would normalize their relations. According to a White House press statement, Sudan also agreed to transfer USD 335 million into an escrow account for US victims of terrorism and their families who have outstanding claims against the Sudanese government. What might other sanctioned countries learn from all this? Deal making plus regional politics equals sanctions relief.

The next edition of the Sanctions Top-5 should be out on 3 November 2020 — Election Day! Happy voting to everyone in the United States.

Did I miss something? Send me a message or comment on LinkedIn.

(The views expressed are my own and do not constitute legal advice. Photo from Vladislav Reshetnyak.)



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Nicholas Turner

US attorney in Hong Kong specializing in economic sanctions, financial crimes. Sign up for emails: LinkedIn at: