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South Sudanese Officials Face Sanctions as US Warns of Further Designations

The United States has sanctioned six South Sudanese individuals, according to a statement from the Office of Foreign Assets Control (OFAC). The move comes as the UN Security Council continues to impose sanctions on those responsible for or complicit in actions that threaten peace and stability in the region.

Executive Order 13664

Under Executive Order 13664, US financial institutions are prohibited from engaging in transactions with designated individuals and entities without a license or exemption. Property and interests in property within the United States or under US control are also blocked, making it illegal to transfer, pay, export, withdraw, or deal in them.

UN Sanctions Target South Sudanese Officials

The UN Security Council Resolution 2206 established a global regime of targeted sanctions on individuals and entities responsible for or complicit in actions that threaten the peace, security, or stability of South Sudan. The resolution has been renewed annually, with the most recent extension coming in May 2017.

US Financial Institutions Warned to Take Precautions

The OFAC designations increase the likelihood that other high-ranking officials and opposition leaders may seek to protect their assets from potential future blocking measures. As a result, US financial institutions are being warned to take extra precautions when dealing with these individuals or entities.

Due Diligence Requirements Highlighted

Financial institutions are reminded of their general due diligence obligations under 31 CFR § 1010.610(a) and the Bank Secrecy Act (BSA). They must ensure that their anti-money laundering programs, including correspondent account due diligence, include risk-based policies and procedures to detect and report known or suspected money laundering activity.

Suspicious Activity Reporting

Financial institutions are required to file a Suspicious Activity Report (SAR) if they know, suspect, or have reason to suspect a transaction involves funds derived from illegal activity. In April 2008, FinCEN issued guidance on reporting suspicious activity related to proceeds of foreign corruption.

Additional Guidance Provided

When filing a SAR, financial institutions should provide all pertinent information and select field 35(l) for suspected public/private corruption (foreign). They are also encouraged to reference this advisory by including the key term “SOUTH SUDAN” in the SAR narrative and field 35(z) Other Suspicious Activity-Other.

Contact Information

For further questions or comments regarding this advisory, financial institutions should contact the FinCEN Resource Center at FRC@fincen.gov. Financial institutions wanting to report suspicious transactions that may potentially relate to terrorist activity can call the Financial Institutions Toll-Free Hotline at (866) 556-3974.