Deemed Exports FAQs - What steps can Sudanese academic and training organizations (training institutes, test preparation centers, secondary schools, and universities) take to acquire and use hardware, software, web-based applications and teaching products?
Exporters and reexporters of items subject to the Export Administration Regulations may export or reexport hardware and software to Sudanese academic and training organizations without a BIS license if the transaction meets all the requirements of License Exception CCD. If such items also meet the requirements of the OFAC general license pertaining to certain software, hardware, and services incident to personal communications (31 CFR Section 538.533), an OFAC specific license would not be required for their export or reexport. (For definitive guidance on OFAC requirements, please consult with that agency.) Please note that not all Sudanese academic and training organizations would be authorized to receive these items under the license exception. Apart from certain specified consumer software that is distributed free of charge, License Exception CCD only applies to items destined for organizations or entities that are not part of the Sudanese Government (including owned, operated, or controlled by the government). Also, not all of the hardware and software described in this question will meet the requirements of License Exception CCD. In those cases, persons must apply for a BIS license and OFAC license to engage in the transaction. Sudanese academic and training organizations should contact the manufacturers and providers of these items directly to seek the classification number of the item they wish to import to Sudan and to learn whether they may receive the items and, if so, under what circumstances.