Council Regulation (EU) 2023/2147 of 9 October 2023 concerning restrictive measures in view of activities undermining the stability and political transition of Sudan

Current text a fecha 2024-06-24

Article 1

For the purposes of this Regulation, the following definitions apply:

(a) ‘claim’ means any claim, whether asserted by legal proceedings or not, made before or after the date of entry into force of this Regulation, under or in connection with a contract or transaction, and in particular: (i) a claim for the performance of any obligation arising under or in connection with a contract or transaction; (ii) a claim for extension or payment of a bond, financial guarantee or indemnity of whatever form; (iii) a claim for compensation in respect of a contract or transaction; (iv) a counterclaim; (v) a claim for the recognition or enforcement, including by the procedure of exequatur, of a judgment, an arbitration award or an equivalent decision, wherever made or given;

(b) ‘contract or transaction’ means any transaction of whatever form and whatever the applicable law, whether comprising one or more contracts or similar obligations made between the same or different parties; for this purpose ‘contract’ includes a bond, guarantee or indemnity, particularly a financial guarantee or financial indemnity, and credit, whether legally independent or not, as well as any related provision arising under, or in connection with, the transaction;

(c) ‘competent authorities’ refers to the competent authorities of the Member States as identified on the websites listed in Annex II;

(d) ‘economic resources’ means assets of every kind, whether tangible or intangible, movable or immovable, which are not funds, but which may be used to obtain funds, goods or services;

(e) ‘freezing of economic resources’ means preventing the use of economic resources to obtain funds, goods or services in any way, including, but not limited to, by selling, hiring or mortgaging them;

(f) ‘freezing of funds’ means preventing any move, transfer, alteration, use of, access to, or dealing with funds in any way that would result in any change in their volume, amount, location, ownership, possession, character, destination or other change that would enable the funds to be used, including portfolio management;

(g) ‘funds’ means financial assets and benefits of every kind, including, but not limited to: (i) cash, cheques, claims on money, drafts, money orders and other payment instruments; (ii) deposits with financial institutions or other entities, balances on accounts, debts and debt obligations; (iii) publicly and privately-traded securities and debt instruments, including stocks and shares, certificates representing securities, bonds, notes, warrants, debentures and derivatives contracts; (iv) interest, dividends or other income on or value accruing from or generated by assets; (v) credit, right of set-off, guarantees, performance bonds or other financial commitments; (vi) letters of credit, bills of lading, bills of sale; (vii) documents showing evidence of an interest in funds or financial resources;

(h) ‘territory of the Union’ means the territories of the Member States to which the Treaty is applicable, under the conditions laid down in the Treaty, including their airspace.

Article 2

Annex I shall include natural or legal persons, entities or bodies:

(a) responsible for, or having directly or indirectly engaged in, providing support to, or benefitting from, actions or policies that threaten the peace, stability or security of Sudan;

(b) obstructing or undermining efforts to resume the political transition in Sudan;

(c) obstructing the delivery of, access to, or distribution of humanitarian assistance in Sudan, including attacks on health and humanitarian workers and the seizure and destruction of humanitarian or health infrastructure and assets;

(d) involved in planning, directing or committing acts in Sudan that constitute serious human rights violations or abuses or violations of international humanitarian law, including killings and maimings, rape and other serious forms of sexual and gender-based violence, abduction and forced displacement;

(e) associated with the natural or legal persons, entities or bodies covered by points (a) to (d).

Article 3

By way of derogation from Article 2, the competent authorities may authorise the release of certain frozen funds or economic resources, or the making available of certain funds or economic resources, under such conditions as they deem appropriate, after having determined that the funds or economic resources concerned are:

(a) necessary to satisfy the basic needs of natural or legal persons, entities or bodies listed in Annex I, and dependent family members of such natural persons, including payments for food, rent or mortgage, medicines and medical treatment, taxes, insurance premiums, and public utility charges;

(b) intended exclusively for the payment of reasonable professional fees or the reimbursement of incurred expenses associated with the provision of legal services;

(c) intended exclusively for the payment of fees or service charges for the routine holding or maintenance of frozen funds or economic resources;

(d) necessary for extraordinary expenses, provided that the relevant competent authority has notified the competent authorities of the other Member States and the Commission of the grounds on which it considers that a specific authorisation should be granted, at least two weeks prior to the authorisation; or

(e) to be paid into or from an account of a diplomatic or consular mission or an international organisation enjoying immunities in accordance with international law, insofar as such payments are intended to be used for official purposes of the diplomatic or consular mission or international organisation.

Article 4

Article 2 (1) and (2) shall not apply to the making available of funds or economic resources necessary to ensure the timely delivery of humanitarian assistance or to support other activities that support basic human needs where such assistance and other activities are carried out by:

(a) the United Nations, including its programmes, funds and other entities and bodies, as well as its specialised agencies and related organisations;

(b) international organisations;

(c) humanitarian organisations having observer status with the United National General Assembly and members of those humanitarian organisations;

(d) bilaterally or multilaterally funded non-governmental organisations participating in the United Nations Humanitarian Response Plans, Refugee Response Plans, other United Nations appeals or humanitarian clusters coordinated by the United Nations Office for the Coordination of Humanitarian Affairs (OCHA);

(e) organisations and agencies to which the Union has granted the Humanitarian Partnership Certificate or which are certified or recognised by a Member State in accordance with national procedures;

(f) Member States’ specialised agencies; or

(g) the employees, grantees, subsidiaries, or implementing partners of the entities mentioned in points (a) to (f) while and to the extent that they are acting in those capacities.

The Member State concerned shall inform the other Member States and the Commission of any authorisation granted under this Article within four weeks of such authorisation.

Article 5

By way of derogation from Article 2(1), competent authorities may authorise the release of certain frozen funds or economic resources, if the following conditions are met:

(a) the funds or economic resources are the subject of an arbitral decision rendered prior to the date on which the natural or legal person, entity or body referred to in Article 2 was listed in Annex I, or of a judicial or administrative decision rendered in the Union, or a judicial decision enforceable in the Member State concerned, prior to or after that date;

(b) the funds or economic resources will be used exclusively to satisfy claims secured by such a decision or recognised as valid in such a decision, within the limits set by applicable laws and regulations governing the rights of persons having such claims;

(d) recognition of the decision is not contrary to public policy in the Member State concerned.

Article 6

By way of derogation from Article 2(1) and provided that a payment by a natural or legal person, entity or body listed in Annex I is due under a contract or agreement that was concluded by, or an obligation that arose for, the natural or legal person, entity or body concerned, before the date on which that natural or legal person, entity or body was included in Annex I, the competent authorities may authorise, under such conditions as they deem appropriate, the release of certain frozen funds or economic resources, provided that the competent authority concerned has determined that:

(a) the funds or economic resources will be used for a payment by a natural or legal person, entity or body listed in Annex I; and

(b) the payment is not in breach of Article 2(2).

Article 7

Article 2 (2) shall not apply to the addition to frozen accounts of:

(a) interest or other earnings on those accounts;

(b) payments due under contracts, agreements or obligations that were concluded or arose before the date on which the natural or legal person, entity or body referred to in Article 2 was included in Annex I; or

(c) payments due under judicial, administrative or arbitral decisions rendered in a Member State or enforceable in the Member State concerned;

provided that any such interest, other earnings and payments are frozen in accordance with Article 2(1).

Article 8

Natural and legal persons, entities and bodies shall:

(a) supply immediately any information which would facilitate compliance with this Regulation, such as information on accounts and the amounts frozen in accordance with Article 3(1), to the competent authority of the Member State where they are established or located, and transmit such information, directly or through the Member State, to the Commission; and

(b) cooperate with the competent authority in any verification of the information referred to in point (a).

Article 9

Natural or legal persons, entities or bodies listed in Annex I, shall:

(a) report within six weeks of the date of their listing in Annex I funds or economic resources within the jurisdiction of a Member State belonging to, owned, held or controlled by them to the competent authority of the Member State where those funds or economic resources are located; and

(b) cooperate with that competent authority in the verification of such information.

Article 10

Article 11

No claims in connection with any contract or transaction the performance of which has been affected, directly or indirectly, in whole or in part, by the measures imposed under this Regulation, including claims for indemnity or any other claim of this type, such as a claim for compensation or a claim under a guarantee, notably a claim for extension or payment of a bond, guarantee or indemnity, particularly a financial guarantee or financial indemnity, of whatever form, shall be satisfied, if they are made by:

(a) natural or legal persons, entities or bodies listed in Annex I;

(b) any natural or legal person, entity or body acting through or on behalf of one of the natural or legal persons, entities or bodies referred to in point (a).

Article 12

The Commission and Member States shall inform each other of the measures taken under this Regulation and share any other relevant information at their disposal in connection with this Regulation, in particular information in respect of:

(a) funds frozen under Article 2 and authorisations granted under Articles 3, 4(2), 5 and 6;

(b) violation and enforcement problems and judgments handed down by national courts.

Article 13

Article 14

Article 15

Article 16

The Council, the Commission and the High Representative of the Union for Foreign Affairs and Security Policy (the ‘High Representative’) may process personal data in order to carry out their tasks under this Regulation. These tasks shall include:

(a) as regards the Council, preparing and making amendments to Annex I;

(b) as regards the High Representative, preparing amendments to Annex I;

(c) as regards the Commission: (i) adding the contents of Annex I to the electronic, consolidated list of persons, groups and entities subject to Union financial sanctions and to the interactive sanctions map, both of which are publicly available; (ii) processing information on the impact of the measures provided for in this Regulation, such as the value of frozen funds and information on authorisations granted by the competent authorities.

Article 17

Article 18

Any information provided to or received by the Commission pursuant to this Regulation shall be used by the Commission only for the purposes for which it was provided or received.

Article 19

This Regulation shall apply:

(a) within the territory of the Union, including its airspace;

(b) on board any aircraft or vessel under the jurisdiction of a Member State;

(d) to any legal person, entity or body, inside or outside the territory of the Union, which is incorporated or constituted under the law of a Member State;

(e) to any legal person, entity or body in respect of any business done in whole or in part within the Union.

Article 20

This Regulation shall enter into force on the day following that of its publication in the Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

ANNEX I

List of natural and legal persons, entities or bodies referred to in Article 2

A. Natural Persons

	Name	Identifying information	Reasons	Date of listing
1.	Mirghani Idriss SULEIMAN	Nationality: Sudanese Gender: male Function: Lieutenant General in the SAF; Director General of Defence Industries System; Head of Sudanese Army Production Agency Associated individuals: General Abdelfattah Al-Burhan, Commander-in-Chief of the SAF Associated entities: Defense Industry System, SMT Engineering; SAF	Lieutenant General Mirghani Idriss Suleiman is an officer of the SAF and Director General of Defense Industry System (DIS), a company sanctioned by the European Union for providing support to actions and policies that threaten the peace, stability and security of Sudan. DIS is described as Sudan’s largest defence enterprise, generating an estimated USD 2 billion in revenue through hundreds of subsidiaries across various sectors of Sudan’s economy. DIS manufactures a range of small arms, conventional weapons, ammunition and military vehicles for the SAF. As the Director General of DIS, Mirghani Idriss Suleiman has travelled extensively with General Abdelfattah Al-Burhan, Commander-in-Chief of the SAF, since the beginning of the war, allegedly, to enhance the SAF’s capabilities to fight the RSF on several fronts in Khartoum, Darfur and Kordofan. Therefore, Mirghani Idriss Suleiman provides support to actions or policies that threaten the peace, stability or security of Sudan.	24.6.2024
2.	EL TAHIR Mohamed EL AWAD EL AMIN a.k.a. EL TAHIR Mohamed EL AWAD EL AMIN AL-TAHER; Mohammed AL-AWAD AL-AMIN	Nationality: Sudanese Gender: male Function: Lieutenant General, Commander of the Sudanese Air Force since 1 September 2022; Former Dean of the Sudanese Air Force College; Former Commander of the Khartoum Air Base Associated individuals: General Abdelfattah Al-Burhan, Supreme Commander of the SAF; Lieutenant General Yasir al-Atta, Assistant Commander-in-Chief of the SAF; General Mohamed Osman al-Hussein, Chief of Staff of SAF Land Forces Associated entities: SAF	El Tahir Mohamed El Awad El Amin is a Lieutenant General in the SAF and Commander of the Sudanese Air Force since 1 September 2022. He is therefore in charge of the operations carried out by the Air Force of the SAF since the outbreak of the conflict between the SAF, the RSF and their allied militias on 15 April 2023, as underscored by his participation in publicly disclosed high-level meetings of senior commanders of the SAF headed by the Commander-in-Chief Abdelfattah Al-Burhan in the General Command of the SAF in Khartoum in May and July 2023. El Tahir Mohamed El Awad El Amin therefore holds a direct command responsibility in the indiscriminate aerial bombing carried out by the Air Force of the SAF in densely populated residential areas, notably in Khartoum, Omdurman, Nyala (South Darfur) and in North Kordofan, documented by the United Nations Integrated Transition Assistance Mission in Sudan (UNITAMS) in its 31 August 2023 and 13 November 2023 reports to the Secretary-General, by the United Nations High Commissioner for Human Rights in its 22 February 2024 report and by the United Nations Panel of Experts on Sudan in its 15 January 2024 report. El Tahir Mohamed El Awad El Amin has thus been engaged directly in the continuation of the Sudanese conflict, which threatens the peace, stability and security of Sudan, and has been involved in planning, directing and committing aerial operations which have resulted in serious human rights violations and violations of international humanitarian law by causing high numbers of civilian casualties, leading to displacement of the civilian population and to the destruction of critical infrastructures, including medical facilities such as the East Nile Hospital in Khartoum in May 2023 and the Babiker Nahar Paediatric Hospital in El-Fasher in May 2024.	24.6.2024
3.	Ali Ahmed KARTI MOHAMED	DOB: 11.3.1953 POB: Hagar Elassal — Sudan Nationality: Sudanese Gender: male Function: Stalwart of the National Congress Party; Secretary-General of the Sudanese Islamist Movement; Former Sudanese Minister of Foreign Affairs ID number: 11822483949 Associated entities: Sudanese Foreign Ministry; Sudanese Islamic Movement	Ali Ahmed Karti Mohamed was the Sudanese Minister of Foreign Affairs under the Government of Omar al-Bashir. Following the fall of the al-Bashir regime, Ali Ahmed Karti Mohamed was selected as one of the leaders of the Sudanese Islamist Movement (SIM) and led efforts to derail Sudan’s progress towards a full democratic transition, by undermining the former civilian-led transitional government and the Framework Political Agreement process. This contributed to the conflict between the SAF and RSF, which began on 15 April 2023. He and other hardline Sudanese Islamists are actively obstructing efforts to reach a ceasefire to end the conflict and they are opposing civilian efforts to restore Sudan’s democratic transition. Ali Ahmed Karti Mohamed is a stalwart of the National Congress Party (NCP), founded by Omar Al-Bashir in 1998. The NCP is the successor organisation to the Brotherhood-affiliated National Islamic Front. Ali Ahmed Karti Mohamed is currently the Secretary-General of the SIM, a broad alliance of Islamist groups, and is considered to be the man behind the NCP’s resurgence. The Islamist movement has a strong influence on the SAF, police and intelligence services. Therefore, Ali Ahmed Karti Mohamed engages directly or indirectly in, provides support to, or benefits from, actions or policies that threaten the peace, stability or security of Sudan.	24.6.2024
4.	Abdulrahman JUMA BARAKALLAH a.k.a.: Major-General Abdulrahman GOMAA; Abdul Rahman JUMA BARAKALLAH	POB: AlDaein- Abu Matareq, East Darfur, Sudan Nationality: Sudanese Gender: male Function: RSF Major General and RSF Commander of West Darfur Associated entities: RSF	Abdulrahman Juma Barakallah is a prominent General among the RSF, who commands the RSF’s military force in West Darfur. He is responsible for committing atrocities and other abuses, inducing ethnically motivated killings, targeted attacks on human rights activists and defenders, conflict-related sexual violence, and for the looting and burning of communities. He is also responsible for kidnapping and assassinating the Governor of West Darfur, Khamis Abbakar, and his brother. Khamis Abbakar was killed hours after he accused the RSF and allied militias of attacking local communities in Al Geneina, capital of West Darfur, in an interview with the Saudi-owned television station, Al Hadath and Emirati television Al Arabiya. Abdulrahman Juma Barakallah has also been accused by international Non-Governmental Organisations of being responsible for the genocide of the Masalit community. Therefore, Abdulrahman Juma Barakallah is responsible for planning, directing or committing acts in West Darfur that constitute serious human rights violations or abuses or violations of international humanitarian law, including killings and maimings, rape and other serious forms of sexual and gender-based violence, abduction and forced displacement. As a General of the RSF in West Darfur, he also engages directly or indirectly in actions or policies that threaten the peace, stability or security of Sudan.	24.6.2024
5.	Mustafa Ibrahim ABDEL NABI MOHAMED	Nationality: Sudanese Gender: male Function: Director of al-Khaleej Bank; majority shareholder of Shield Protective Solutions Co. Ltd. (Sudan); financial adviser to the leader of the RSF Passport number: B CH 4930920 Associated individuals: Musa Hamdan Dagalo Musa, brother of RSF leader Mohamed Hamdan Dagalo Associated entities: Al-Khaleej Bank; Shield Protective Solutions Co. Ltd. (Sudan)	Mustafa Ibrahim Abdel Nabi Mohamed is a former senior official of the Sudanese Central Bank who became the RSF’s financial adviser, helping it to manage a web of proxy companies and entities. A UN Panel of Experts Report on sanctions in Darfur recently referred to a former senior official of the Sudanese Central Bank who is based in Dubai and has become the RSF’s financial adviser without naming him. The report also explains that al Khaleej Bank became instrumental to the RSF’s financing in 2019 when its majority ownership was acquired by individuals and entities associated with the RSF. Media reports and think-tanks have identified him as Mustafa Ibrahim Abdel Nabi Mohamed. He is a Director of Al Khaleej Bank, a Sudanese bank. Over 60 % of the shares of Al Khaleej Bank are held by companies associated with the family of Mohammad Hamdan Dagalo (Hemedti), the head of the RSF. Mustafa Ibrahim Abdel Nabi Mohamed is also the majority shareholder of Shield Protective Solutions Co. Ltd. The other shareholder in this company is one of the brothers of Hemedti, namely Musa Hamdan Dagalo Musa, and this company holds over 14 % of the shareholding in al Khaleej Bank. As a financial adviser to the RSF and the Dagalo family, Mustafa Ibrahim Abdel Nabi Mohamed is engaging directly or indirectly in providing support to, or benefitting from, actions or policies that threaten the peace, stability or security of Sudan.	24.6.2024
6.	Masar Abdurahman ASEEL a.k.a. Massar Abdelrahman ASSIL Masar Abdelrahman ESEIL Massar ASSEL Masar ASIL	Gender: male Function: Amir of the Mahamid clan in West Darfur; Member of the Native Administration in West Darfur	Masar Abdurahman Aseel is a prominent tribal leader of the Mahamid clan in West Darfur. The Mahamid clan belongs to the Rizeigat tribe which gathers Arab communities inhabiting Darfur and Chad. He holds the title of Amir and is a member of the Native Administration in West Darfur. Masar Abdurahman Aseel has facilitated the attacks led by the Rapid Support Forces (RSF) and their allied militias against local communities living in El Geneina (West Darfur), especially the Massalit people, since April 2023. In particular, he directly contributed to the recruitment and arming of militias by the RSF and to the coordination between these forces, as is reported by the 15th final report of the United Nations Panel of Experts on Sudan published in January 2024, to carry out their ethnically targeted attacks, notably against the Massalit communities, in West Darfur between late April and early November 2023. Propaganda videos featuring Masar Abdurahman Aseel were published by the RSF in March and in April 2024, demonstrating his warmongering support to the RSF and his role in rallying the troops behind the RSF to join their fight against the SAF since 15 April 2023. Masar Abdurahman Aseel has therefore engaged directly in, provided support to and benefitted from actions and policies that threaten the peace, stability and security of Sudan. By supporting the seizing of West Darfur by the RSF, Masar Abdurahman Aseel has strengthened his position and influence within the Native Administration of West Darfur, at the expense of other community leaders, notably belonging to the Massalit community, which have been targeted by the RSF and their allied militias.	24.6.2024

B. Entities

	Name	Identifying information	Reasons	Date of listing
1.	Defense Industries System a.k.a.: Military Industry Corporation; Defense Industries Corporation	Address: Khartoum North, Khartoum 10783 Type of entity: Public entity Date of registration: 1993	Defense Industries System (DIS), previously known as the Military Industrial Corporation (MIC), is a large Sudanese Armed Forces (SAF)-owned conglomerate which manages a network of military-controlled companies. DIS generates substantial annual revenues, estimated at USD 2 billion in 2020. DIS manufactures and provides the SAF with a range of military equipment, including weapons, ammunition, aircraft and military vehicles, which are used by the armed forces in the conflict in Sudan. DIS controls together with SMT Engineering (SMT), through a network of direct and indirect shareholdings, numerous companies of the SAF-controlled GIAD conglomerate, which is also involved in the production of weapons and vehicles for the armed forces, as well as in the provision of services to the SAF, in particular through a partnership between GIAD for Automotive Services and the Corps of Engineers. The Director General of DIS has accompanied Commander Al-Burhan during his official visits abroad since April 2023. Therefore, DIS provides support to SAF actions and policies that threaten the peace, stability and security of Sudan. In addition, DIS is associated with SMT which also provides support to the SAF’s actions and policies that threaten the peace, stability and security of Sudan.	22.1.2024
2.	SMT Engineering a.k.a.: Sudan Master Technology; SMT	Address: SMT Building Madani Road, KM 50 Khartoum, Giad Industrial Complex, Gamhuria Street Khartoum Type of entity: State Controlled Company	SMT Engineering (SMT) is a Sudan-based company which owns or controls, together with DIS, numerous companies of the SAF-controlled GIAD conglomerate, through a network of direct and indirect shareholdings. SMT is the main shareholder of three GIAD companies in which DIS owns the rest of the shares (GIAD for the automotive and truck industry, GIAD complex for heavy mechanism industries and GIAD metal industries complex). SMT also owns or controls, directly or indirectly, many other companies that are part of the GIAD conglomerate and in which DIS also holds stakes, such as GIAD for Automotive Services. The GIAD conglomerate is involved in the production of weapons and vehicles for the armed forces, as well as in the provision of services to the SAF, in particular through a partnership between GIAD for Automotive Services and the Corps of Engineers. DIS is a large SAF-owned conglomerate which provides support for SAF actions and policies that threaten the peace, stability and security of Sudan, in particular through the manufacture and provision of a range of military equipment, including weapons, ammunition, aircraft and military vehicles, which are used by the armed forces in the conflict in Sudan. Therefore, SMT Engineering provides support for SAF actions and policies that threaten the peace, stability and security of Sudan. It is also associated with DIS, which also provides support for SAF actions and policies that threaten the peace, stability and security of Sudan.	22.1.2024
3.	Zadna International Company for Investment Limited	Address: Doha Street Property 436, Manshia Doha Street, Khartoum, Sudan, 11429 Type of entity: State Controlled Company Date of registration: 1997	Zadna International Company for Investment Limited (Zadna) is a holding company in agriculture and construction, which is 99 % owned by the SAF controlled Special Fund for the Social Security of the Armed Forces (SFSSAF), formerly known as the Charity Organisation for the Support of the Armed Forces. The leader of the SAF, Commander Al-Burhan, appointed in October 2021 General El Mirghani Idris Suleiman as Chairman of Zadna, who is one of his friends and Director of DIS. In May 2023, he also appointed Dr. Taha Hussein Yousef as Director-General of Zadna. The SFSSAF and Zadna are part of the vast network of companies and organisations owned or controlled by the SAF, which are used to sustain the power of the armed forces over the Sudanese economy. Zadna is a leading company engaged in high-profile international business deals and is one of the top revenue earners in the army’s network of companies. Therefore, it generates substantial revenues for the benefit of the SAF, which enables the armed forces to finance and continue the conflict in Sudan. Therefore, Zadna International Company for Investment Limited provides support for SAF actions and policies that threaten the peace, stability and security of Sudan.	22.1.2024
4.	Al Junaid Multi Activities Co Ltd a.k.a. Ajmac multi activities company; Al Gunade	Address: Street 3 Khartoum Block 17 Alryad, Sudan Industrial Area 13, Sharjah, UAE P.O. Box 61401, Sharjah Type of entity: Limited Company Date of registration: 2009	Al Junaid Multi Activities Co Ltd (Al Junaid) is a Sudanese holding company controlled by Rapid Support Forces’ (RSF) Commander Mohamed Hamdan Dagalo (Hemedti) and his brother, RSF Deputy Commander Abdul Rahim Dagalo. The company is owned by Abdul Rahim Dagalo and his two sons. Hemedti himself is on its board of directors. Based in Khartoum, Al Junaid operates subsidiaries across multiple economic sectors, including gold mining and trade, and covers a large part of Sudan’s gold industry. The company has mining concessions in Darfur, in particular in the vicinity of Jebel Amer (North Darfur) and in the Singo area (South Darfur), and it also operates beyond that region. The gold mines of Darfur are under the control of the RSF, including the Jebel Amer site since 2017. Gold mining and trade through Al Junaid generates a substantial source of revenue for the Dagalo family and the RSF, which enables them to finance and continue the conflict in Sudan. The RSF is also using Al Junaid’s gold production and exports to secure military support from the United Arab Emirates (UAE), to which most of Sudan’s gold production is smuggled, and from the Wagner Group, including the provision of weapons used by the RSF in the conflict in Sudan. Therefore, Al Junaid Multi Activities Co Ltd provides support for RSF actions that threaten the peace, stability and security of Sudan.	22.1.2024
5.	Tradive General Trading Co	Address: P.O. Box 86436, Dubai (UAE) Type of entity: Limited Company Date of registration: 2018	Tradive General Trading Co (Tradive) is a company based in the UAE whose director and ultimate beneficial owner is RSF Major Algoney Hamdan Dagalo, the youngest brother of Mohammed Hamdan Dagalo (Hemedti). Tradive is part of the RSF’s commercial network which generates stable revenue for the RSF enabling them to finance and continue the conflict in Sudan. It is used as an RSF front company, channelling substantial sums into and out of the RSF, and enabling the purchase of material to support RSF operations. For instance, Tradive has purchased vehicles for the RSF, including Toyota Hilux and Land Cruiser pick-up trucks, which are often converted into highly mobile ‘technicals’, which are armed desert vehicles. In the first half of 2019, more than one thousand such vehicles were imported into Sudan from the UAE. These converted vehicles have been used by the RSF for a long time and continue to be used by it in the conflict in Sudan, in particular to patrol the areas under RSF control. Therefore, Tradive General Trading Co provides support for RSF actions that threaten the peace, stability and security of Sudan.	22.1.2024
6.	GSK ADVANCE COMPANY LTD	Address: Ahmed Khair Street, Khartoum 11111, Sudan Type of entity: Limited Company	GSK is a Sudan-based information technology and security company, which is 60 % owned by RSF Major Algoney Hamdan Dagalo, the youngest brother of Mohamed Hamdan Dagalo (Hemedti). GSK is part of the RSF’s commercial network which generates stable revenue for the RSF enabling them to finance and continue the conflict in Sudan. It is used by the RSF as a front company, facilitating cash flows into the RSF and being involved in the RSF’s procurement processes. In addition, since at least 2019, GSK has been working with Aviatrade LLC, a Russia-based military supply company, on the purchase and supply of material and equipment for the benefit of the RSF, including the corresponding training, and on the purchase and supply of unmanned aerial vehicles, monitoring equipment and spare parts. Reconnaissance and weaponised drones are used by the RSF in the conflict in Sudan. Therefore, GSK Advance Company LTD provides support for RSF actions that threaten the peace, stability and security of Sudan.	22.1.2024

ANNEX II

BELGIUM

https://diplomatie.belgium.be/en/policy/policy_areas/peace_and_security/sanctions

BULGARIA

https://www.mfa.bg/en/EU-sanctions

CZECHIA

https://fau.gov.cz/en/international-sanctions

DENMARK

http://um.dk/da/Udenrigspolitik/folkeretten/sanktioner/

GERMANY

https://www.bmwi.de/Redaktion/DE/Artikel/Aussenwirtschaft/embargos-aussenwirtschaftsrecht.html

ESTONIA

https://vm.ee/sanktsioonid-ekspordi-ja-relvastuskontroll/rahvusvahelised-sanktsioonid

IRELAND

https://www.dfa.ie/our-role-policies/ireland-in-the-eu/eu-restrictive-measures/

GREECE

http://www.mfa.gr/en/foreign-policy/global-issues/international-sanctions.html

SPAIN

https://www.exteriores.gob.es/es/PoliticaExterior/Paginas/SancionesInternacionales.aspx

FRANCE

http://www.diplomatie.gouv.fr/fr/autorites-sanctions/

CROATIA

https://mvep.gov.hr/vanjska-politika/medjunarodne-mjere-ogranicavanja/22955

ITALY

https://www.esteri.it/it/politica-estera-e-cooperazione-allo-sviluppo/politica_europea/misure_deroghe/

CYPRUS

https://mfa.gov.cy/themes/

LATVIA

http://www.mfa.gov.lv/en/security/4539

LITHUANIA

http://www.urm.lt/sanctions

LUXEMBOURG

https://maee.gouvernement.lu/fr/directions-du-ministere/affaires-europeennes/organisations-economiques-int/mesures-restrictives.html

HUNGARY

https://kormany.hu/kulgazdasagi-es-kulugyminiszterium/ensz-eu-szankcios-tajekoztato

MALTA

https://foreignandeu.gov.mt/en/Government/SMB/Pages/SMB-Home.aspx

NETHERLANDS

https://www.rijksoverheid.nl/onderwerpen/internationale-sancties

AUSTRIA

https://www.bmeia.gv.at/themen/aussenpolitik/europa/eu-sanktionen-nationale-behoerden/

POLAND

https://www.gov.pl/web/dyplomacja/sankcje-miedzynarodowe

https://www.gov.pl/web/diplomacy/international-sanctions

PORTUGAL

https://portaldiplomatico.mne.gov.pt/politica-externa/medidas-restritivas

ROMANIA

http://www.mae.ro/node/1548

SLOVENIA

http://www.mzz.gov.si/si/omejevalni_ukrepi

SLOVAKIA

https://www.mzv.sk/europske_zalezitosti/europske_politiky-sankcie_eu

FINLAND

https://um.fi/pakotteet

SWEDEN

https://www.regeringen.se/sanktioner

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