On 2 June, OFAC updated its Frequently Asked Questions (FAQ) to address issues regarding payments to or transactions with non-designated individuals or entities in South Sudan. The FAQ makes clear that an entity, such as a militia or other armed group, is not itself subject to sanctions merely because such an entity is commanded or controlled by an individual designated under the South Sudan-related sanctions. Thus, payments to or other transactions with militias controlled or commanded by designated individuals do not, on their own, constitute prohibited activity. However, OFAC encourages US persons to employ due diligence in such transactions to ensure that a designated person is not profiting from the transaction.

OFAC FAQ # 368