Unpacking the Recent Sanctions on Sudan: Challenges and Opportunities

13 December 2023

Recent developments have thrust Sudan into the global spotlight, as the United States has imposed sanctions on three former Sudanese officials for their alleged role in undermining peace, security, and stability in the nation. This move, executed under a U.S. executive order targeting those destabilizing Sudan and undermining democracy, reflects a complex situation involving political dynamics, human rights concerns, and historical tensions. In this blog article, we will delve into the details of the recent sanctions, examining their effects on Sudan’s leaders, the challenges they pose, and the potential opportunities for the nation’s future.

Targeted Officials and Their Actions: On 4 December 2023, three former Sudanese officials were subjected to sanctionsby the US Department of the Treasury.[1] The sanctioned officials, Mr. Taha Osman Ahmed al-Hussein, Salah Abdallah Mohamed Salah, and Mohamed Etta Elmoula Abbas are accused of engaging in activities that undermine the peace, security, and stability of Sudan. Specifically, Elmoula and Salah, both former security officials, are alleged to have worked towards reinstating former regime elements to power and disrupting efforts to establish a civilian government. Taha, on the other hand, is accused of facilitating the delivery of military support to the Rapid Support Forces (RSF).[2]In September 2023, the Department of the Treasury also sanctioned Mr. Abdelrahim Hamdan Dagalo (Abdelrahim), the brother of the Commander of the RSF, General Mohamed Hamdan “Hemedti” Dagalo for his leadership of RSF, an entity whose members have allegedly engaged in acts of violence and human rights abuses, including the massacre of civilians, ethnic killings, and use of sexual violence.[3] In same month, the US Department of State imposed visa restrictions on RSF General and West Darfur Sector Commander, Abdul Rahman Juma, for his involvement in a gross violation of human rights.

Escalating Internal Conflict: The recent sanctions coincide with a surge in internal conflict in Sudan, marked by a clash between the Sudanese army and the paramilitary Rapid Support Forces. The conflict erupted amidst disagreements over a plan to integrate forces as part of the transition from military rule to civilian democracy. This volatile situation has prompted the U.S. to take action, imposing sanctions to address the escalating tensions and promote accountability for atrocities committed during the conflict.

Implications of the sanctions on the three individuals: All property and interests in property of the designated person described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to the Office of the Foreign Assets Control (OFAC). In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.[4]

Lessons from Sanctions on Sudan in the past: To fully grasp the implications of these sanctions, it is essential to consider historical contexts and past experiences, particularly about sanctions placed on Sudan in the past. For example, in 2004, the US government determined there was a genocide occurring in Darfur. It provided over $5 billion in assistance and sanctioned 160 persons and entities for this atrocity crime. The impact of these bold moves by the US government can be a template for further action.

Previous instances of targeted sanctions in Sudan reveal a nuanced picture. While sanctions aim to pressure individuals and entities to comply with peace agreements, there are concerns about unintended consequences and potential negative impacts on broader communities.

Challenges and Risks

Impact on Civilians: Sanctions have the potential to harm the civilian population, impeding the delivery of aid and essential services. Careful consideration is required to ensure that the measures do not exacerbate the existing humanitarian crisis.
Deteriorating Diplomacy: Sanctions may strain diplomatic relations and hinder dialogue between Sudan and the international community. Balancing the need for accountability with diplomatic efforts to resolve the conflict is crucial.
Historical and Cultural Dynamics: The historical context and cultural dynamics of Sudan need to be acknowledged. Sanctions that disregard these factors risk exacerbating internal divisions and fostering resentment, hindering the path to sustainable peace.

Opportunities for Resolution

Inclusive Peacebuilding: Rather than relying solely on sanctions, international actors should explore inclusive peacebuilding efforts that involve diverse stakeholders, including religious and community leaders, to foster a more comprehensive and sustainable resolution.
Humanitarian Support: A focus on humanitarian support is essential to address the immediate needs of the affected population. International organizations should work collaboratively to ensure the delivery of aid and promote stability on the ground.
Creative Diplomacy: The international community must engage in creative diplomacy and mediation efforts. Targeted sanctions alone may fall short of achieving lasting peace, requiring a more nuanced and adaptive approach.

The recent sanctions on Sudan’s leaders underscore the complexity of the situation, with a delicate balance needed between accountability and the risk of unintended consequences. As Sudan navigates these challenges, the international community must remain vigilant in crafting strategies that promote peace, protect civilians, and address the root causes of the conflict. Ultimately, a multifaceted approach that combines targeted measures with diplomacy, inclusivity, and humanitarian support offers the best chance for a positive outcome in Sudan’s tumultuous journey toward stability and democracy.

Christine Kirabo

Legal Program Officer, ACJPS

[1] US Department of treasury, Treasury Targets Sudanese Actors for Undermining Peace, Security, and Stability in Sudan, 4 December 2023, https://home.treasury.gov/news/press-releases/jy1947