On 12th April 2021, OFAC published an amended version of the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), and four frequently asked questions (FAQs) relating to the TSRA and the Sudan and Darfur sanctions regime. The FAQs provide relevant guidance on how individuals and entities can submit licence applications pursuant to the TRSA.  It also clarifies that a licence is no longer required for the export of agricultural commodities, medicine, or medical devices to Sudan. See Notice and FAQs  97, 98, 500, and 836. The published information is intended to serve as guidance to persons (individuals or entities) seeking to export or reexport agricultural commodities, medicine, and medical devices to Iran and Sudan pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA).

Why is this important for your organisation?

Breaching OFAC sanctions regulations may result in civil, criminal and regulatory liability, resulting in substantial fines and reputational damage. Organisations should assess their business’s nature, the types of product and services they offer, their supply chains and the jurisdictions they operate to devise an appropriate compliance framework. 

It is therefore important to Implement a robust due diligence and sanctions screening system sensitive to the level of risk to which your organisation is exposed.