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US Issues Sudan Sanctions, General Licenses

The U.S. this week issued its first set of Sudan sanctions since a May executive order expanded U.S. sanctions authority against the country (see 2305040037), designating four companies, including its largest defense firm, earning revenue or contributing to Sudan’s ongoing military conflict. The designations, announced June 1 by the Office of Foreign Assets Control, include four new general licenses to authorize certain essential transactions, including for humanitarian aid.

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The designations target Defense Industries System, Sudan’s “largest defense enterprise,” which makes small arms, conventional weapons, ammunition and military vehicles for the Sudanese Armed Forces (SAF), earning billions of dollars through hundreds of subsidiaries across Sudan’s economy. OFAC also sanctioned Al Junaid Multi Activities Co Ltd., a Sudanese holding company controlled by officials with the paramilitary Rapid Support Forces (RSF); Tradive General Trading L.L.C., a United Arab Emirates-based front company that operates as a procurement firm and is also controlled by an RSF official; and Sudan Master Technology, an arms company that produces weapons and vehicles for the SAF.

The four new general licenses authorize certain activities of international organizations, nongovernmental organizations and other transactions relating to trade in food, medicine and the delivery of humanitarian aid to Sudan.

  • Sudan GL1 authorizes certain transactions for the “official business” of certain international groups, including the International Centre for Settlement of Investment Disputes, the African Union, the International Committee of the Red Cross and others.
  • Sudan GL 2 authorizes certain transactions by NGOs, including for activities that support humanitarian projects to “meet basic human needs,” distribute medicine, help displaced people and more.
  • Sudan GL 3 authorizes certain transactions involving agricultural goods, medicine, medical devices, replacement parts and components, software updates, the distribution of water and more.
  • Sudan GL 4 authorizes the wind-down of certain transactions with Defense Industries System, Al Junaid Multi Activities Co. or any entity they own by 50% or more. Those transactions are authorized through 12:01 a.m. EST on July 31 as long as any payment to a sanctioned person is made into a blocked account and reported to OFAC.

National Security Adviser Jake Sullivan said the violence in Sudan is “hindering the delivery of humanitarian assistance” to the country. The sanctions “are intended to hold accountable those responsible for undermining the peace, security, and stability of Sudan,” he said. “And working with our partners, we will continue to hold the belligerent parties accountable for their unconscionable violence and defiance of the will of the people.”