The ICC Banking Commission conducted its final meeting of 2024 virtually via Teams on 20-21 November. Four separate portions of the event open to Banking Commission members and ICC National Committee representatives took place.
On 1 June 2023, the US Treasury’s Office of Foreign Assets Control (OFAC) designated for sanctions controls four companies which it identifies as generating revenue from, and contributing to, the ongoing conflict in Sudan. The entities designated include two companies affiliated with the paramilitary Rapid Support Forces (RSF) — Al Junaid Multi Activities Co Ltd and Tradive General Trading L.L.C. – and two companies affiliated with the Sudanese Armed Forces (SAF) — Defense Industries System and Sudan Master Technology.
As stated by OFAC in announcing its action, “Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.” OFAC has issued three general licenses which “authorize certain activities of international organizations and nongovernmental organizations and certain transactions relating to the provision of water, food, and agricultural and medical items to Sudan.”
Regarding Defense Industries System (DIS), said to be Sudan’s largest defense enterprise with hundreds of subsidiaries throughout Sudan’s economy and manufacturer of various small arms, conventional weapons, ammunition, and military vehicles for the SAF, OFAC contends that DIS “uses a complex system to hide its ownership of these subsidiaries and to obtain favorable letters of credit from the Sudan Central Bank.” According to OFAC, DIS “not only defaults on the loans obtained under these letters of credit but also uses these favorable funds guarantees to compete unfairly with civilian businesses that do not enjoy such favorable financial terms.”
