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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On June 1, 2023, the Office of Foreign Assets Control (OFAC) issued four new Sudan-related General Licenses authorizing certain transactions that would otherwise be prohibited by Executive Order (EO) 14098 dated May 4, 2023 (See Update of <a href="https://www.thompsonhinesmartrade.com/2023/05/president-biden-introduces-new-sudan-related-sanctions/">May 4, 2023</a>):
<ul class="wp-block-list">
<li>General License <a href="https://ofac.treasury.gov/media/931821/download?inline">No. 1</a> <a>authorizes </a>transactions for the conduct of the official business of certain international organizations and entities, including but not limited to the International Centre for Settlement of Investment Disputes (ICSID) and the Multilateral Investment Guarantee Agency (MIGA); the Intergovernmental Authority on Development (IGAD); and the International Federation of Red Cross and Red Crescent Societies.</li>
<li>General License <a href="https://ofac.treasury.gov/media/931826/download?inline">No. 2</a> authorizes certain transactions that are ordinarily incident and necessary to the certain described activities by nongovernmental organizations (NGOs), provided that the nongovernmental organization is not a person whose property or interests in property are blocked pursuant to EO 14098. &nbsp;Covered activities must be non-commercial in nature and designed to directly benefit the civilian population, including:&nbsp; (i) humanitarian projects, (ii) democracy building, and (iii) educational support.</li>
<li>General License <a href="https://ofac.treasury.gov/media/931831/download?inline">No. 3</a> authorizes transactions related to the provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates, and the extraction, processing, transport, sale, or distribution of water in Sudan; and</li>
<li>General License <a href="https://ofac.treasury.gov/media/931836/download?inline">No. 4</a> authorizes the wind down of transactions through July 31, 2023 involving Defense Industries System or Al Junaid Multi Activities Co. Ltd., or any entity owned or controlled by these by a 50 percent or greater interest.&nbsp; Note:&nbsp; these two Sudanese entities were separately placed on OFAC&rsquo;s <a href="https://ofac.treasury.gov/recent-actions/20230601">Specially Designated Nationals (SDN) List</a> on June 1, 2023.&nbsp;</li>
</ul>
Certain transactions remain unauthorized under these general licenses and therefore require close analysis.

OFAC Issues New General Licenses Under Sudan-Related Sanctions

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