Yes. The terms of License Exception CCD do not require that items be exported or reexported directly to the end user. Consequently, exports and reexports to Sudan to commercial entities for resale to eligible end users would qualify for License Exception CCD. Eligible end users include individuals and independent non-governmental organizations operating in Sudan. Apart from certain specified consumer software that is distributed free of charge, the Government of Sudan may not be the end-user. An independent non-governmental organization that is owned, operated, or controlled by the Government of Sudan is not eligible to receive items under License Exception CCD. Persons wishing to use License Exception CCD are responsible for determining that the criteria of the license exception will be met. Please be advised nothing in License Exception CCD excuses a U.S. person from the need to comply with the Sudanese Sanctions Regulations.

   
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