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US Issues New Sudan Trade Controls, Exemptions in Response to Chemical Weapons Use

The State Department this week announced new export restrictions against Sudan after determining earlier this year that the Sudanese government used chemical weapons in 2024 and isn't in compliance with the Chemical Weapons Convention (see 2505230007). The agency’s notice, effective June 27, establishes new prohibitions but also waives some of the new export restrictions for Sudan under certain scenarios. The measures will be in place for at least one year “and until further notice.”

The notice terminates arms sales to Sudan under the Arms Export Control Act “of any defense articles, defense services, or design and construction services, and (b) licenses for the export to Sudan of any item on the United States Munitions List.” But the State Department also determined that it’s “essential to the national security interests” that those restrictions be partially waived to allow for the “case-by-case adjudication of licenses or other authorizations for defense articles and defense services for entities other than the Government of Sudan.”

The U.S. also is prohibiting exports to Sudan “of any goods or technology” on the Commerce Control List that are controlled for national security reasons, with certain exceptions:

Those exceptions are valid “provided that such licenses shall be issued consistent with [the] export licensing policy for Sudan prior to the date” of the State Department’s determination, the agency said.

The State Department is also ending certain foreign assistance to Sudan, except for certain “urgent” humanitarian aid, and is stopping all foreign military financing for Sudan under the Arms Export Control Act and financial assistance by the Export-Import Bank of the U.S. and other agencies.