To clarify the issue, our November report was based on a phone interview I had with the General Counsel at OFAC. Although he would not put anything in writing and he asked that we not use his name in our report, he told us, unambiguously, that OFAC is not interested in travel-related expenditures in Sudan. This particular sanctions program prohibits investing in Sudan, he told us. He then went on to say that everything related to a hunting trip is covered by the travel exemptions and that operating a tour company (i.e., a booking agency) that sends travelers to Sudan was not considered investing in the country. Imports from Sudan, however, are prohibited, and bringing back your trophy will require getting a license from OFAC, as we explained in our previous report. Obviously these restrictions apply only to Americans.
As interesting as the prospects are in Sudan, all of the above should not be taken as a green light from us to hunt there. The US State Department has a Travel Warning in effect for Sudan (http://travel.state.gov/travel/cis_pa_tw/tw/tw_934.html), and, as general policy, we do not recommend ignoring Travel Warnings. We reiterate that policy for legal reasons.