US Authorizes the Imposition of Sanctions Against Those Responsible for Continued Violence in South Sudan

On April 3, 2014, President Barack Obama signed an Executive Order sanctioning those responsible for the conflict in South Sudan. The Executive Order blocks the property and entry of designated entities and individuals. South Sudan continues NOT to be subject to a country-wide embargo: these sanctions will only be against designated entities and individuals.

“The Executive Order blocks the property and entry of designated entities and individuals. South Sudan continues NOT to be subject to a country-wide embargo…”

“Those who threaten the peace, security or stability of South Sudan, obstruct the peace process, target U.N. peacekeepers or are responsible for human rights abuses and atrocities will not have a friend in the United States and run the risk of sanctions,” said the White House in a statement.

The Executive Order permits the US to impose sanctions against any individual or entity that:

• Threatens the peace, stability, or security of South Sudan;

• Commits human rights abuses against persons in South Sudan;

• Expands or extends the conflict in South Sudan or obstructs reconciliation or peace talks or processes; or

• Undermines democratic processes or international peacekeeping, diplomatic, or humanitarian missions or UN missions in South Sudan.

The Executive Order authorizes the US Treasury Department to designate persons and entities — including leaders in such designated entities, persons providing material assistance to such designated entities/persons, and entities owned or controlled by designated entities/persons — as subject to these sanctions. The sanctions include the blocking of assets of the designated entities/persons, making donations or contributions to such designated entities/persons, and visa (immigrant/non-immigrant) sanctions. The Treasury Department’s Office of Foreign Assets Control (OFAC) has yet to designate any individuals under this Executive Order.

Arent Fox has significant experience in helping companies navigate and comply with US sanctions laws and export controls. If you have any questions regarding the above, please contact Kay C. Georgi and Tina Termei with Arent Fox’s International Trade Group, or the Arent Fox professional who regularly handles your matters.