The US designated Sudan as an international terrorist sponsor in 1993, imposing various trade restrictions. Although relations improved during the early 2000s, the US, alongside the UN and the EU, imposed wide ranging trade restrictions and sanctions targeting the Sudanese government in 2005, in response to violence and human rights abuses committed as part of the civil war. UN, UK, SECO and EU sanctions remain in place targeting parties presenting a threat to the settlement of the civil war, although US programmes targeting the Sudanese government have been discontinued.
On 8th March 2023 the Sudan sanctions programme was extended until 12th September 2024.
Sanction Name
UN Security Council Regulations Against Sudan
First Imposed
Last updated
Targets
Arms Embargo, Travel Ban and Asset Freeze:
• Entities deemed to present a threat to stability and security in Darfur and the wider region or those committing human rights abuses. An embargo on the supply of arms to entities operating in Darfur and all signatories of the N’djamena Ceasefire Agreement.
Exemptions
1. The Sudanese Government can move military equipment and supplies into the Darfur region following approval from the UN Sanctions Committee.
2. There is also an exemption on frozen assets with regards to judicial, administrative or arbitral liens or judgments.
3. Travel ban exemptions can be granted on a case-by-case basis on humanitarian grounds.
Links 1
On 22nd January 2024 the European Council designated six entities for supporting activities undermining the stability and political transition of Sudan including two companies involved in the manufacture of weapons and vehicles for the Sudanese Armed Forces (“SAF”) (Defense Industries System and SMT Engineering), SAF-controlled Zadna International COmpany for Investment Limited, and three companies involved in procuring military equipment for the Rapid Support Forces (Al Junaid Multi Activities Co Ltd, Tradive General Trading andGSK Advance Company Ltd).
Sanction Name
Restrictive Measures In View Of The Situation In Sudan
SANCTIONS
First Imposed
Last updated
Targets
Arms Embargo, Travel Ban and Asset Freeze:
• Individuals or groups threatening the peace process following the country’s civil war and the secession of South Sudan, threatening the stability of Darfur or participating in human rights abuses. The programme includes a ban on all exports of materiel or related equipment or services into Sudan.
Exemptions
1. Exemptions can be granted on a case-by-case basis where they would further peace and stability in Sudan and the wider region.
2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.
Sanction Name
Regulation on Measures Against Sudan
SANCTIONS
First Imposed
Last updated
Targets
Arms Embargo, Travel Ban, Trade Restrictions and Asset Freeze:
• Sanctions were introduced in response to the genocide in Darfur and targeting those found to be impeding the peace process, constituting a threat to stability in Darfur and the region, committing violations of international humanitarian or human rights law or other atrocities, or responsible for offensive military overflights.
Exemptions
1. Arms supplied for use by the UN or non-lethal equipment intended solely for humanitarian or protective use is exempt from sanctions, as is the temporary export of protective clothing and related equipment for media, humanitarian, UN and Swiss personnel.
2. Asset freeze exemptions can be granted to prevent cases of rigor or to protect Swiss interests. Travel ban exemptions can be granted to protect Swiss interests.
On 31st January 2024 OFAC sanctioned three entities for their role in undermining the peace, security, and stability of Sudan as part of the US’ attempt to identify and isolate funding sources for both the Sudanese Armed Forces (“SAF”) and the Rapid Support Forces (“RSF”), the two main belligerent parties responsible for the conflict in Sudan. Designations included RSF-controlled Alkhaleej Bank Co Ltd, which finances RSF’s operations; RSF-controlled Al-Fakher Advanced Works Co Ltd, a holding company for conducting RSF’s gold export business; and SAF-controlled, Zadna International Co for Development Ltd, allegedly a vehicle for military money-laundering and revenue generation for the SAF.
On 1st March 2024, OFAC amended the heading of the Darfur Sanctions Regime to the Sudan Stabliziation Sanctions Regulations.
Sanction Name
US Sanctions against Sudan
SANCTIONS
First Imposed
Last updated
Targets
Arms Embargo, Travel Ban and Asset Freeze:
• Entities deemed to present a threat to stability and security in Darfur and the wider region or those committing human rights abuses.
• Export controls remain in place, including on arms and dual-use goods. A licence is required to export certain commodities, software, and technology on the Commerce Control List.
Exemptions
1. Effective from October 2017 US persons are no longer prohibited from financial transactions in Sudan, including with the Government of Sudan, as detailed in the Sudanese Sanctions Regulations.
2. An OFAC General License permits the export agricultural commodities, medicine or medical devices to the Government of Sudan.
3. Exemptions can be granted for certain transactions relating to humanitarian exceptions.
4. Exemptions apply to the wind down of transactions involving paramilitary group Rapid Support Forces-associated entities Defence Industries System or Al Junaid Multi Activities Co Ltd.
Links 1
Sanction Name
Sudan (Sanctions) (EU Exit) Regulations 2020
SANCTIONS
First Imposed
Last updated
Targets
Arms Embargo, Travel Ban and Asset Freeze:
• Individuals or groups threatening the peace process following the country’s civil war and the secession of South Sudan, threatening the stability of Darfur or participating in human rights abuses. The programme includes a ban on all exports of materiel or related equipment or services into Sudan.
Exemptions
1. Exemptions can be granted on a case-by-case basis where they would further peace and stability in Sudan and the wider region.
2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.
