Yesterday, President Trump issued an Executive Order that maintains the status quo on Sudan by extending temporary sanctions relief for another three months, until October 12, 2017. This extension will give the U.S. government more time to review whether Sudan has maintained the progress that led to the temporary relief in the first place. Let’s take a quick stroll down (recent) memory lane to see how we got there.

In one of his last sanctions-related actions prior to leaving office, President Obama ordered a significant but temporary easing of sanctions on Sudan on January 13, 2017. This step came after intense and lengthy negotiations between the U.S. and Sudan and was a recognition of positive actions by the Government of Sudan in key areas, including improved humanitarian access and a pledge to maintain a cessation of hostilities in conflict areas in Sudan.

Consistent with this new direction, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued a general license authorizing most transactions with Sudan that were previously prohibited. The Bureau of Industry and Security at the Department of Commerce made policy changes to allow for licensing of certain exports and re-exports to Sudan. A more detailed analysis of these changes, which became effective on January 17, can be found here.

To incentivize the Government of Sudan to continue its positive trajectory, President Obama chose not to terminate the sanctions program altogether. Rather, under Executive Order 13761, he left that decision to President Trump with a review period that lasted until July 12. As noted above, President Trump has now extended the temporary relief and review period until October 12. An OFAC FAQ on this action can be found here.

Bear in mind that Sudan remains designated as a state sponsor of terrorism. There are statutory requirements that would need to be satisfied before the Trump Administration could terminate that designation regardless of whether President Trump opts to lift economic sanctions in October. Human rights groups and some members of Congress have been vocal opponents of any further easing of sanctions or removal of the state sponsor designation, arguing that the government of Sudan’s actions do not warrant further relief, and will likely continue to be active in this space.