Last week, the Department of State’s Directorate of Defense Trade Controls (DDTC) announced that it has added South Sudan to its list of prohibited countries under the U.S. International Traffic in Arms Regulations (ITAR). This designation means that with certain limited exceptions, export licenses for ITAR-controlled munitions items and related services are now subject to a policy of denial, and most ITAR exemptions no longer can be used for South Sudan.
Additionally, no proposals or presentations related to ITAR-controlled items, regardless of whether or not such proposals or presentations contain ITAR technical data, may be made to South Sudan or to any person acting on its behalf without first obtaining a license or written approval from DDTC. Exporters also have a duty to immediately notify DDTC if they know or have reason to know of a proposed, final, or actual sale, export, transfer, reexport, or retransfer of ITAR-controlled items to South Sudan or another Section 126.1 ITAR-prohibited country. At present, the other ITAR-prohibited countries include: Afghanistan, Belarus, Burma (Myanmar), the Central African Republic, China, Cuba, Cyprus, Democratic Republic of the Congo (DRC), Eritrea, Haiti, Iran, Iraq, Lebanon, Libya, North Korea, Somalia, the Republic of the Sudan, Syria, Venezuela, and Zimbabwe.