OFAC earlier this week announced the issuance of a new general license (General License No. 1) of the Sudanese Sanctions Regulations, 31 CFR Part 538 (the SSR) authorizing certain educational exchange activities between accredited US institutions and their Sudanese counterparts. This action by the Office paves the way for increased academic interaction between the two countries.
Specifically, the general license allows US persons to engage in the following activities, inter alia:
- Teaching humanities, social sciences, environmental sciences, agriculture, public works, public health, law, and business at Sudanese academic institutions (notice the absence of technical fields);
- Administering certain standardized tests in Sudan like the TOEFL and GMAT;
- Engaging in for-credit coursework in each other’s countries; and
- Process certain payments from Sudan and the Sudanese government to provide academic services in the United States to individuals ordinarily resident in Sudan.
Certain limitations do remain, and the General License reminds readers that certain, even temporary exports of Commerce Control List (CCL) items continue to require specific authorization from the US Department of Commerce’s Bureau of Industry and Security (BIS).
The SSR remain a very complex body of regulations, with very intricate intra-country geographic limitations that have likely been drafted keeping the civil strife in that country in mind.
An international trade and regulatory lawyer.
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