On March 6, 2020, the UK National Economic Crime Centre, together with the UK Foreign and Commonwealth Office and the Department for International Development, published an Amber Alert to warn companies based in the UK to be wary of corrupt South Sudanese senior public officials attempting to use the UK financial system to move or conceal proceeds of corruption.
The Alert calls on the private sector to use enhanced due diligence whilst enabling the flow of licit investment into South Sudan, in light of the country’s history of violence fueled by corruption among the military and political elites. Its message is aimed in particular at financial institutions, real estate agencies, accountants, lawyers, notaries, company and trust formation agents, boarding schools, and luxury goods dealers, and asks them to identify suspicious activity. The Alert cites examples of senior public officials using offshore leasing companies to sell Sudanese oil for their personal enrichment through the use of shell companies, overpriced procurement contracts, or other channels, and advises companies to heed Financial Action Task Force guidance regarding red flags related to corrupt foreign politically exposed persons and their enablers.