The United States Department of Treasury Office of Foreign Assets Control (“OFAC”) has authorized the expansion of the scope of an existing authorization of certain imports for diplomatic or official personnel to include the provision of goods or services in the United States to the diplomatic missions of the Government of Sudan to the United States and the United Nations, and to the employees of such missions, subject to certain conditions.

This expansion also permits the importation of goods or services into the United States by the regional Government of Southern Sudan and its employees that involve the transit or transshipment of goods through areas of Sudan other than the Specified Areas of Sudan. This authorization is also subject to certain conditions.

I will not delve too much into this topic as Clif Burns over at www.exportlawblog.com has already written a good analysis on the topic. I advise everyone to read his post.

The only thing I really have to add is that the fact that it took OFAC this long to realize that it would probably be a good idea to authorize this sort importation–so that, as Mr. Burns points out, they could have such basic utilities like water and electricity–only goes to further a point I always raise in this blog: the sanctions regulations are confusing and individuals who might be at risk of violating those sanctions need to obtain legal counsel so that they don’t run afoul of the regulations.

Now obviously here OFAC had slipped up and forgotten to put in an exemption for the importation of these goods and services in the Sudense Sanctions Regulations. However, technically OFAC could have been penalizing U.S. persons providing such goods and services this whole time. In short, find legal counsel that is mindful of OFAC and what the regulations say.

In other news, I was quoted in a Computer World article addressing the topic of how U.S. sanctions programs will effect Web 2.0 social media platforms like Facebook and Twitter.

A few days ago I wrote on OFAC vs. the Future of the Web and I really do believe that these companies need to sit down with OFAC and figure out a way they can carry on business while complying with OFAC’s regulations. I think this will be an important topic in years to come.