US Amends Sudan Stabilization Sanctions Regulations with New Recordkeeping Rule

The United States has published a final rule amending the Sudan Stabilization Sanctions Regulations at §546.508(b). The change updates the reporting requirements attached to the general licence that authorises payment for legal services from funds originating outside the US, adding a recordkeeping obligation.

Under the revised requirement, recipients of payments made under the general licence must keep a record of the relevant transaction and the services provided for a period of 10 years from the date of payment. These records must be made available to the Office of Foreign Assets Control (OFAC) on request.

Beyond the recordkeeping change, the final rule carries out a broader administrative update. It refreshes website and contact information across 39 CFR parts, as well as in Appendix A to Chapter V — the explanatory appendix to the US Specially Designated Nationals and Blocked Persons list (SDN List).

While much of the rule is administrative housekeeping, the new 10-year retention obligation is a practical compliance point: parties relying on the legal services general licence in the Sudan context should ensure their document-retention policies are aligned with the extended timeframe and that records can be produced for OFAC if required.