INTERNATIONAL TRADE UPDATE - DECEMBER 12, 2011

OFAC Issues General Licenses Authorizing Petroleum-Sector Activities in South Sudan and Transshipment of Goods through Sudan to or from South Sudan

On December 8, 2011, the Office of Foreign Assets Control (“OFAC”) at the U.S. Treasury Department issued two general licenses authorizing all activities and transactions relating to the petroleum or petrochemical industry in the Republic of South Sudan (and related financial transactions) and the transshipment of goods, technology and services through Sudan to or from the Republic of South Sudan (and related financial transactions).

 

Specifically, all activities and transactions relating to the petroleum and petrochemical industries in South Sudan are now authorized, including exploration; development; production; field auditing services; oilfield services; activities related to oil and gas pipelines; investment; payment to the Government of Sudan or to entities owned or controlled by the Government of Sudan of pipeline, port and other fees; and downstream activities such as refining, sale and transport of petroleum from South Sudan (except for the refining in Sudan of petroleum from South Sudan).

 

At the same time, OFAC also issued a general license authorizing transit or transshipment of goods, technology and services through Sudan to or from the Republic of South Sudan.

 

Also authorized are all financial transactions ordinarily incident to the above-described activities with banks owned or controlled by the Government of Sudan, including financial transactions with a depository institution owned or controlled by the Government of Sudan or located in Sudan, provided that any transaction between a U.S. depository institution and a depository institution owned or controlled by the Government of Sudan must first transit through a depository institution that is not owned or controlled by the Government of Sudan.

 

It is important to note that all activities and transactions relating to the petroleum and petrochemical industries in Sudan continue to be prohibited unless otherwise authorized.

 

In addition, the licenses do not authorize transactions or other dealings with parties on the Specially Designated Nationals and Blocked Persons List or other U.S. government restricted lists.

 

 

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