STPT: Sudan Sanctions Bypass Business Networks, Fueling War

• A recent STPT report indicates that international sanctions on Sudan have been largely bypassed by warring factions through overseas business networks.
• The Sudanese Armed Forces (SAF) utilize entities like Zadna International Company for Investment, shifting operations to Egypt and Gulf states.
• The Rapid Support Forces (RSF) generate revenue via gold trading networks, moving gold through South Sudan to the UAE.
• The report criticizes current sanctions for failing to target subsidiaries and commercial partners, enabling continued circumvention.
• The STPT recommends coordinated designations, stronger enforcement, and regional engagement to disrupt networks sustaining the war economy.

This landscape demands that legal and compliance professionals anticipate increased international scrutiny on commercial activities linked to the region.

A recent analysis by the Sudan Transparency and Policy Tracker (STPT), detailed in its October 2026 "Bypassing Sanctions, Sustaining the War Economy" report, reveals that international sanctions imposed since the April 2023 conflict began have been largely circumvented. The report highlights that while some financial and procurement channels have experienced disruption, the broader commercial networks funding the Sudanese Armed Forces (SAF) and the paramilitary Rapid Support Forces (RSF) remain operational.

The STPT's findings indicate that both warring factions are actively employing overseas business networks, affiliated companies, and alternative arms suppliers to bypass international restrictions. For instance, the military-owned Zadna International Company for Investment, linked to the SAF, has reportedly redirected a significant portion of its operations towards Egypt and Gulf states, strategically positioning itself for potential post-war reconstruction efforts. Similarly, the RSF-affiliated Al Junaid conglomerate continues to generate revenue through extensive gold trading networks, with routes identified moving gold from Sudan, through South Sudan, and ultimately to the United Arab Emirates (UAE).

Furthermore, the report documents the SAF's efforts to secure new weapons suppliers, citing Pakistan as one example, and its push to develop domestic arms production capabilities. This domestic manufacturing relies on imported materials, which are inherently more challenging to track and regulate. However, the authors of the report caution that the mere existence of these alternative procurement routes does not definitively prove that sanctions were the direct cause of these strategic shifts.

The "Bypassing Sanctions, Sustaining the War Economy" report critically assesses the current framework of Sudan sanctions, arguing that the existing approach of targeting individual companies is insufficient. The STPT emphasizes that the effectiveness of these measures is undermined when subsidiaries, joint ventures, and commercial partners of sanctioned entities remain outside the scope of international sanctions regimes. This allows for continued Sudanese Armed Forces sanctions evasion and the sustained operation of the Rapid Support Forces gold trading networks.

To address these systemic vulnerabilities, the STPT urges international governments to adopt a more coordinated and comprehensive strategy. Key recommendations include coordinating designations across various jurisdictions, strengthening enforcement mechanisms, and actively engaging regional partners, particularly Egypt and Gulf states. Such collaborative efforts are deemed essential to effectively disrupt the intricate business networks that continue to sustain the Sudan war economy. The report concludes that sanctions alone cannot bring an end to the conflict; they must be integrated into a broader political strategy that includes robust regional cooperation and measures aimed at mitigating harm to civilians.

The revelations from the STPT's report underscore a heightened risk environment for compliance officers and legal counsel advising clients with any business ties to Sudan, or entities operating in Egypt and Gulf states with Sudanese connections. The intricate methods of Sudan sanctions bypass business networks STPT has uncovered necessitate a re-evaluation of existing due diligence practices. The continued operation of entities like Zadna International Company for Investment and the Al Junaid conglomerate, despite sanctions, signals a sophisticated effort to circumvent international restrictions.

This landscape demands that legal and compliance professionals anticipate increased international scrutiny on commercial activities linked to the region. There is a strong likelihood of an expansion of targeted entities beyond direct military actors, potentially encompassing a wider array of commercial partners, subsidiaries, and joint ventures involved in the Sudan war economy. Strengthened enforcement efforts against these commercial networks supporting both the SAF and RSF are to be expected, making enhanced due diligence not merely advisable but critical for mitigating legal and reputational risks associated with the Bypassing Sanctions Sustaining War Economy report's findings.

Compliance officers and legal counsel advising clients with any business ties to Sudan, or entities operating in Egypt and Gulf states with Sudanese connections, must be aware of the heightened risk of sanctions circumvention. They should anticipate increased international scrutiny, potential expansion of targeted entities beyond direct military actors, and strengthened enforcement efforts against commercial networks supporting the SAF and RSF, requiring enhanced due diligence.

Source: Original reporting via Sudan Transparency and Policy Tracker