OFAC Issues New General License for IT Exports to Sudan

OFAC this week issued a new general license expanding the range of informational technology (IT) related goods and services U.S. persons can now export to Sudan.  The amended general license, which went into effect on February 18, is incorporated into the Sudanese Sanctions Regulations, 31 CFR Part 538, and opens many windows for U.S. persons, as well as opportunities for people in Sudan to be better engaged with the outside world.

Notably, the new general license expands on a 2010 general license allowing U.S. persons to export certain types of personal communication software and services to Sudan, primarily those related to free, publicly available applications that was “EAR99,” i.e., not subject to U.S. export controls for potential dual use.  As OFAC itself states, the new general license follows the Iran General License D-1 model, whose precursor, General License D, was issued in May 2013 to allow Iranians to have more access to information and communication tools. General License D and D-1 authorizes U.S. persons to export of a host of computing hardware, software and services to Iran.

Here are some basic features of the new Sudan General License:

1. Software. The general license has been expanded to include certain fee-based software as well (formerly only some free applications and services were allowed), so long as they are “widely available to the public” and related to personal communications.  Interestingly, these have also been made available to the Government of Sudan. Certain non-U.S., non-EAR controlled software can also be exported to Sudan by U.S. persons if necessary to enable certain types of personal communications.

2. Hardware. A host of technologies are now exportable to Sudan under certain circumstances. These include certain internet communications technologies and tools, as well as items such as computers, modems, personal data assistants, harddrives, and mobile phones.

As can be seen, the general license is certainly not a blank check to deal in whatever types of IT goods, services, and technologies with Sudan. However, within the parameters set forth in the general license, this general license does open many doors for the exportation of a wide range of goods and services to Sudan, and may hopefully have a positive impact in empowering communications in and with that country.

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An international trade and regulatory lawyer.

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Copyright 2017 Farhad R. Alavi.
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