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Apple revises its guidance on Sudan

November 10, 2020 (WASHINGTON) - The California-based tech giant Apple Inc. has updated its legal guidance related to dealing with Sudan.

The Global Trade Compliance page on Apple’s website removed Sudan’s name from the list of nations it says are under "complete embargo" which was on their website as recently as this summer.

Apple also added clarification with regard to Sudan sanctions based on the U.S. Treasury’s Office of Foreign Asset Control (OFAC) guidance.

"OFAC lifted sanctions against Sudan in 2017 due to improvements in cooperation between the U.S. and Sudanese governments. Today, Sudan is not subject to any economic sanctions administered by OFAC," Apple stated.

But Apple went to say that Sudan remains subject to "export licensing requirements" for U.S. exports of most items, software and technology"

"License exception Consumer Communication Devices (CCD) authorizes sales of certain categories of items to Sudan, which include some Apple goods and software".

The export licensing requirements are imposed due to Sudan’s inclusion on the U.S. list of states that sponsor terrorism (SST) since 1993.

Late last month US President Donald Trump notified Congress of his decision to remove Sudan from SST list.

The rescission however will only take effect on December 11th which is 45 days from the notification date. It would also need to be followed by technical updates to implement it through amending the Export Administration Regulations (EAR) handled by the Bureau of Industry and Security (BIS).

Most US companies have been wary of dealing with Sudan despite the lifting of comprehensive economic sanctions in 2007 for fear of legal exposure and hefty fines.

The US administration has attempted to reach out to some of these companies to explain that Sudan is no longer subject to an economic embargo.