On May 4, 2023, President Biden signed a new Executive Order, Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition, stating that the violence taking place in Sudan “is a tragedy” and “must end.”

Finding that the situation in Sudan constitutes an extraordinary threat to U.S. national security and foreign policy, President Biden through the executive order expanded the scope of the national emergency declared in Executive Order 13067 of November 3, 1997, Blocking Sudanese Government Property and Prohibiting Transactions With Sudan, and Executive Order 13400 of April 26, 2006, Blocking Property of Persons in Connection With the Conflict in Sudan’s Darfur Region. The executive order authorizes the imposition of new sanctions on foreign persons to address the situation in Sudan following the military’s seizure of power in October 2021 and the outbreak of inter-service fighting in April 2023 and to support Sudan’s transition to democracy and a civilian transitional government.

The new executive order blocks all property and interests in property of foreign persons determined to be responsible for certain listed actions that threaten the peace, security or stability of Sudan, obstruct Sudan’s transition to democracy, undermine democratic processes, engage in censorship, engage in corruption, commit serious human rights abuses, target civilians or obstruct the activities of United Nations missions in Sudan. Such property or interests may not be transferred, paid, exported, withdrawn or otherwise dealt in by any U.S. person. The Office of Foreign Assets Control (OFAC) also amended FAQ No. 836, adding the executive order as a new sanction authority in effect with respect to Sudan.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.