On January 31, 2024, the US Department of the Treasury’s Office of Foreign Assets Control designated three entities that are allegedly controlled by the Sudanese Armed Forces (“SAF”) or the Rapid Support Forces (“RSF”), the two factions responsible for the ongoing conflict in Sudan. The designations were imposed to disrupt a key source of funding for the groups. OFAC reported that it designated Alkhaleej Bank Co Ltd and holding company Al-Fakher Advanced Works Co. Ltd., two companies controlled by the RSA that have allegedly been used to finance RSF operations and purchase weapons used in the conflict. OFAC also designated Zadna International Co for Development Ltd, a company under the control of the SAF, that is considered to be a vehicle for military money-laundering that was reportedly moved under the SAF’s control in order to shield it from civilian oversight.
The companies were designated pursuant to Executive Order 14098, which sanctions individuals and entities engaged in destabilizing Sudan or undermining its democratic transition. As a result of these designations, all property and interests in property of the designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.