2025-11896Notice

U.S. Slaps Sudan with Sanctions Over Chemical Weapons—With Caveats

Published Date: 6/27/2025

Notice

Summary

The U.S. has officially found that Sudan used chemical weapons, breaking international rules. Because of this, some sanctions will be put in place, but certain important U.S. security and trade actions will be partly allowed to continue. This affects Sudan, U.S. foreign aid, and export controls, with changes starting now to protect national security while still punishing wrongdoing.

Analyzed Economic Effects

4 provisions identified: 3 benefits, 1 costs, 0 mixed.

U.S. finds Sudan used chemical weapons

The U.S. determined under section 306(a) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (22 U.S.C. 5604(a)) that the Government of Sudan used chemical weapons in violation of international law. Because of that finding, the notice says sanctions will be imposed pursuant to section 307(a) of the Act.

Partial waiver for U.S. foreign assistance

The Senior Official certified to Congress under section 307(d) of the Act (22 U.S.C. 5605(d)) that it is essential to U.S. national security to partially waive the sanctions required by section 307(a) with respect to foreign assistance. That means some U.S. foreign assistance may continue even after the chemical weapons finding, because of the national security waiver.

Waiver for U.S. Munitions List export licenses

The official also certified a partial waiver so that licenses and other authorizations for exports of items on the U.S. Munitions List (USML) may continue despite the sanctions called for by section 307(a). That means some export licenses for defense-related items on the USML can still be issued under the national security waiver.

Waiver for licensing national security-sensitive technology

The certification also partially waives the sanctions with respect to the licensing of national security-sensitive goods and technology. That allows some licensing of such sensitive goods and technologies to continue under the national security waiver even after the finding under the Act.

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Key Dates

Published Date
6/27/2025

Department and Agencies

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