Deemed Exports FAQs - Due to the sanctions, do export/reexport transactions of items covered under License Exception CCD also require separate authorization from the Department of the Treasury’s Office of Foreign Assets Control (OFAC)?
Because OFAC and BIS share jurisdiction over certain exports and reexports to Sudan, these changes have been made in coordination with OFAC, which simultaneously has issued parallel amendments to the Sudanese Sanctions Regulations, 31 CFR part 538. Please see OFAC FAQs for further information pertaining to the Department of Treasury changes. [Most items that qualify for export or reexport to Sudan under revised License Exception CCD also qualify for export and reexport to Sudan under OFAC's new general license, as set forth in 31 CFR 538.533, published contemporaneously with the new BIS rule. Therefore, in most cases, you do not need a specific license from OFAC for the export or reexport of items described in License Exception CCD.] Exporters should review both 31 CFR 538.533 and License Exception CCD to ensure compliance with applicable export license requirements.