On September 6, the Treasury Department issued a press release announcing multiple actions taken in response to the “continued deterioration of the humanitarian situation in South Sudan.” Under Secretary for Terrorism and Financial Intelligence, Sigal Mandelker, stated, “These actions send a clear message to those enriching themselves at the expense of the South Sudanese people that we will not let them exploit the U.S. financial system to move and hide the proceeds of their corruption and malign behavior.”

Financial Crimes Enforcement Network (FinCEN). FinCEN issued an advisory (FIN-2017-A004) to financial institutions to address concerns that certain South Sudanese senior political figures may potentially move assets using the U.S. financial system. FinCEN projects that since 2013—when a new political conflict began in Sudan—certain senior political officials from both the government and opposition parties have “engaged in and profited from corrupt practices.” The advisory provides due diligence guidance for U.S. financial institutions, issues a reminder regarding suspicious activity report filing obligations, and warns financial institutions to “assess the risk for laundering of the proceeds of public corruption associated with specific particular customers and transactions.”

Office of Foreign Assets Control (OFAC). Pursuant to Executive Order 13664, which blocks the property of certain persons with respect to South Sudan and authorizes sanctions against persons who threaten the peace, security, or stability of South Sudan, OFAC issued sanctions against three government officials and three entities owned by one of the sanctioned individuals. The identified individuals’ actions include, among other things, (i) “actions or policies that threaten the peace, security, and stability of South Sudan”; (ii) “actions or policies that have the purpose or effect of expanding or extending the conflict in South Sudan or obstructing reconciliation or peace talks or processes”; and (iii) “obstruction of the activities of international peacekeeping, diplomatic, or humanitarian missions in South Sudan, or of the delivery or distribution of, or access to, humanitarian assistance.” The sanctions prohibit any U.S. individual from dealing with the designated entities and individuals, and further states that “all of these individuals’ and entities’ assets within U.S. jurisdiction are blocked.” Additionally, individuals designated under Executive Order 13664 are banned from entry into the U.S.