On June 1, 2023, the US Department of the Treasury’s Office of Foreign Assets Control designated four companies that are contributing to the conflict in Sudan and are affiliated with the paramilitary Rapid Support Forces (“RSF”) or the Sudanese Armed Forces (“SAF”) – two factions that are fueling the ongoing conflict in Sudan. OFAC sanctioned Sudanese holding company Al Junaid Multi Activities Co Ltd and a front company based in the United Arab Emirates, both of which are controlled by members of the RSF. OFAC also designated Sudan’s largest defense enterprise, Defense Industries System, which manufactures a variety of weapons, ammunition and military vehicles for the SAF and Sudan Master Technology, an arms company, that is also a shareholder in multiple Defense Industries System companies. The designations were imposed pursuant to Executive Order 14098 for engaging in actions that threaten the peace, security, or stability of Sudan. As a result of these designations, all property and interests in property of the designated individuals and entities 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 the designated persons.
OFAC also issued four new general licenses pursuant to EO 14098, three of which support the provision of humanitarian aid to Sudan and one that authorizes wind down transactions with two of the new designees. The humanitarian general licenses authorize official business of certain named international organizations and entities (GL 1); transactions that support certain nongovernmental organizations’ activities (GL 2); and transactions involving certain agricultural and medical commodities intended for use in Sudan and the extraction, sale or distribution of water in Sudan (GL 3). General License 4 authorizes wind down transactions, until July 31, 2023, for transactions involving Defense Industries System, Al Junaid Multi Activities Co Ltd, or any entity in which these companies own a 50 percent or great interest, provided that any payments to blocked persons are made into blocked accounts and reported to OFAC pursuant to 31 CFR § 501.603.