License Requirements

A license is required to export or reexport most items on the Commerce Control List (CCL) to Sudan. Certain items described in a limited number of export control classification numbers on the CCL may be reexported to Sudan without a license if they were exported from the United States without knowledge that they would be reexported directly or indirectly, in whole or in part to Sudan. These items are described in §742.10(a)(2).  In addition to these license requirements, a license may also be required for export or reexport of items on the CCL or for items designated EAR99 if destined for certain proscribed end-uses or end-users as set forth in Part 744 of the EAR.

License Exceptions

A license exception is an authorization to export or reexport under stated conditions certain items without a license that would otherwise require a license. Sudan is in Country Group E:1 (Supplement No. 1 to Part §740 of the EAR ), which limits the number and scope of available license exceptions. To determine the scope and eligibility requirements, you must review the individual license exceptions in Part740 of the EAR.

Licensing Policy

General Policy of Denial

Applications to export or reexport items to military end users or for military end use in Sudan will generally be denied. Also applications to export or reexport certain specified items will generally denied to all end-users in Sudan.  These items are described in §742.10(b)(1) and include all items controlled for chemical, biological, nuclear and missile proliferation reasons, and military-related items controlled for national security or regional stability reasons (CCL entries ending in the number "018"). Certain other items, such as aircraft, cryptologic items, and explosive device detectors, that are controlled for national security or anti-terrorism reasons are also subject to a general policy of denial pursuant to §742.10(b)(1).

Case-By-Case Review

Applications for export or reexport to Sudan will be reviewed under a case-by-case basis if the items are:

  • destined to non-military end-users and end-users and not otherwise subject to a policy of denial;
  • foreign produced commodities that the contain 20% or less by value of U.S. content;
  • medical items; and
  • telecommunications equipment and associated computers, software, and technology for civil end-use or for civil infrastructure.

General Policy of Approval

Items that are only controlled for anti-terrorism reasons and that are intended to ensure the safety of civil aviation or the safe operation of fixed winged commercial aircraft (parts and components) and railway related items will be reviewed under a general policy of approval.  However, if destined to a sensitive end user such as the Sudanese military, police or intelligence services, the application will be reviewed under a presumption of denial.


For questions specific to Sudan, contact the BIS Foreign Policy Division at 202-482-4252.



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