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U.S. Government Issues a Business Advisory for South Sudan

The Departments of State, Labor, and Commerce today issued a Business Advisory on South Sudan.  The Advisory highlights the growing reputational, financial, and legal risks to U.S. businesses and Americans conducting business or transactions with companies that have significant ties to South Sudan’s extended transitional government or that are controlled by family members of government officials.

The transitional government has failed to implement key economic reforms and public financial management commitments made in the 2018 Revitalized Agreement on the Resolution of the Conflict in the Republic of South Sudan (R-ARCSS), which were due to be completed by February 2023.  The transitional government’s lack of progress on these reforms, the absence of significant progress over the original transition period, and the transitional government’s continued failure to adhere to its own laws in the transparent management of its oil revenue could adversely impact U.S. businesses, individuals, other persons and their operations in South Sudan and the region.

U.S. businesses and Americans operating in South Sudan and the region should undertake robust due diligence on corruption and human rights issues or abuses that contribute to violence.  They should also take care to avoid all dealings, including transactions transiting the United States, that involve any property or interests in property of persons, including from South Sudan, listed on the Department of the Treasury Office of Foreign Assets Control’s (OFAC) Specially Designated Nationals and Blocked Persons.  U.S. financial institutions should have familiarized themselves with their due diligence and suspicious activity report (SAR) filing obligations related to senior South Sudanese political figures, as is already required and as outlined in a 2017 advisory from the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN).  U.S. financial institutions should also refer to the 2020 joint guidance FinCEN issued with the Federal Banking Agencies on Bank Secrecy Act (BSA), “Due Diligence Requirements for Customers Who May Be Considered Politically Exposed Persons.

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