Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions

This executive order conditionally revokes certain U.S. sanctions against Sudan effective July 12, 2017, contingent on Sudan sustaining positive actions including reduced military activity, improved humanitarian access, and counterterrorism cooperation. It also assigns reporting and certification functions to the Secretaries of State and Treasury, and requires annual reviews of Sudan's continued compliance.

Federal Register Open PDF 82 FR 5331

Impact dates

Jul 12, 2018
First annual updated report and Federal Register notice due
Jul 12, 2017
Conditional effective date for sanctions revocation (sections 1, 4, 5, 6, 7); Secretary of State report due; Federal Register notice due
Jan 13, 2017
EO effective for sections 2, 3, 8, 9, 10, 11, 12

Key directives

Revoke sections 1 and 2 of EO 13067 and all of EO 13412 effective July 12, 2017, contingent on Sudan sustaining positive actions
Waive TSRA section 908(a)(1) application to Sudan
Waive CPSA sections 6(a) and 6(b)
Assign CPSA section 6(c)(1) function to Treasury Secretary
Assign CPSA section 6(c)(2) and denial of entry function to State and DHS respectively
Assign DPAA section 8 function to Secretary of State
Authorize Treasury and Commerce to issue regulations implementing TSRA section 906
Secretary of State to submit compliance report by July 12, 2017
Annual updated reports and Federal Register notices required thereafter

Who is ordered

Timeline

Immediate

EO takes effect January 13, 2017 for non-sanctions provisions
Annual reporting requirement established

Near term (90d)

Secretary of State must prepare Sudan compliance report by July 12, 2017
Federal Register notice required by July 12, 2017

Long term

Conditional sanctions revocation takes effect July 12, 2017 if criteria met
Annual compliance reports and Federal Register notices continue indefinitely
National emergency declared in EO 13067 remains in place indefinitely

Risks & tensions

Conditionality creates uncertainty: sanctions relief may be delayed or reversed if Sudan backslides before July 12, 2017
Annual review mechanism preserves U.S. leverage but creates persistent compliance burden and potential for policy whiplash
Maintaining national emergency while revoking sanctions creates legal tension—emergency basis remains but some responsive measures lifted
Multi-agency consultation requirement (State, Treasury, DNI, USAID) may slow decision-making or produce conflicting assessments
Vague 'positive actions' standard provides flexibility but lacks objective benchmarks, risking inconsistent application across administrations