Despite the lifting of the embargo, items on the Commerce Control List (the U.S. list of dual use items) will still require a license to be exported or reexported to Sudan. As noted in a new General License issued by the Office of Foreign Assets Control, certain restrictions apply to the sale of agricultural commodities, medicine, and medical devices to Sudan.

In January, President Obama announced the interim lifting of U.S. sanctions on Sudan. At that time the Office of Foreign Assets Control (OFAC), the agency primarily responsible for implementing U.S. sanctions, issued a general license (or exemption) allowing most transactions involving Sudan, Sudanese companies, and Sudanese residents. In order to make the relief permanent, President Obama’s Executive Order required various U.S. agencies to certify by July 12, 2017 that Sudan was making progress on certain goals important to the United States, like humanitarian assistance, reducing military conflict, and cooperating with anti-terrorism efforts.

Today’s Executive Order delays the report deadline until October 12, 2017. The existing general license authorizing most transactions with Sudan remains in effect, but companies looking for greater certainty regarding the future of U.S. sanctions on Sudan will have to wait a little longer.