United States sanctions on Sudan and staged relief (1997-2020)

United States relief for Sudan occurred in separate legal stages, not through one delisting event. Washington revoked broad trade and government sanctions in 2017 and rescinded Sudan's state-sponsor-of-terrorism designation in 2020. Neither action removed every Darfur, human-rights, conflict or person-specific sanction.

Layered authorities

The United States designated Sudan as a state sponsor of terrorism in 1993 under a separate statutory and administrative framework. Executive Order 13067 of November 1997 then blocked property of the Government of Sudan and generally prohibited specified trade and financial transactions. The order cited national-security and foreign-policy concerns, including the United States government's allegations concerning terrorism and human rights. Those propositions are attributed to the issuing authority.

The sanctions architecture later divided. Executive Order 13400 of April 2006 created targeted authority connected to the conflict in Darfur. Executive Order 13412 of October 2006 continued core restrictions on the Government of Sudan while modifying territorial and sectoral treatment, including for Southern Sudan and specified areas. Country restrictions, Darfur designations and the terrorism-list consequences therefore had different legal bases.

Staged relief

Executive Order 13761 in January 2017 established a process for revoking specified provisions if the government maintained progress across stated tracks. Executive Order 13804 extended the review. On 12 October 2017 the relevant revocations took effect: sections 1 and 2 of Executive Order 13067 and all of Executive Order 13412 ceased to operate. OFAC later removed the Sudanese Sanctions Regulations. United States persons were no longer broadly prohibited from dealings with Sudan or its government solely under those revoked rules.

The 2017 action did not remove Sudan from the terrorism list. That occurred on 14 December 2020 after a separate diplomatic process. Bilateral compensation arrangements, legislation affecting claims and Sudan's steps towards normalisation with Israel formed part of the wider negotiation, but they were distinct from the formal rescission decision and should not be collapsed into one legal exchange.

Nor did 2020 end all sanctions. OFAC's current programme page states that Executive Order 13400 remains in effect for Darfur-related designations. Executive Order 14098, issued in 2023 after renewed conflict, created additional authority concerning Sudan. Other counterterrorism, human-rights and person-specific authorities can also apply independently.

Statecraft assessment

The case demonstrates relief as a sequenced instrument. Separate steps allowed Washington to reward specified conduct while retaining leverage over different policy concerns. That modularity improved legal precision but complicated commercial interpretation. Banks could continue to avoid Sudan because of conflict risk, debt, compliance costs and fear of residual sanctions even after broad prohibitions ended.

Effects should therefore be divided between legal prohibition and market behaviour. Sanctions constrained finance and trade, but correspondent-bank de-risking, civil conflict, governance and macroeconomic weakness also shaped outcomes. The clearest result was institutional: relief could be staged by programme and condition rather than delivered as an all-or-nothing settlement.

See also

Comprehensive versus targeted sanctions · OFAC-style targeted sanctions · JCPOA sanctions relief and snapback (2015-2018) · Over-compliance (de-risking) · Humanitarian cost of sanctions

Sources

1. President of the United States, Executive Order 13067, 3 November 1997.
2. President of the United States, Executive Order 13412, 13 October 2006.
3. President of the United States, Executive Order 13761, 13 January 2017.
4. President of the United States, Executive Order 13804, 11 July 2017.
5. Office of Foreign Assets Control, Sudan and Darfur sanctions, checked 29 July 2026.
6. United States Department of State, Rescission of Sudan's designation as a state sponsor of terrorism, 14 December 2020.