What it captures
Actions in the U.S. Sudan sanctions program (31 CFR Part 546, formerly the Darfur Sanctions Regulations, renamed to Sudan Stabilization Sanctions Regulations in March 2024) issued under or pursuant to Executive Order 13067, Executive Order 13400, and Executive Order 14098.
The program's scope was materially broadened by E.O. 14098 (May 4, 2023) from a Darfur-atrocity-specific frame to a Sudan-wide authority covering:
- Persons threatening Sudan's peace, security, or stability
- Persons undermining Sudan's democratic transition
- Persons committing human rights abuses in Sudan
- Persons obstructing humanitarian assistance
Current entries:
- **2024-03-05 — OFAC renames and amends the Darfur/Sudan Stabilization
Regulations.** Implements E.O. 14098; adds general licenses for legal services (GL 508), African Union transactions (GL 511), and agricultural/medical exports (GL 513); updates definitions and adds interpretative provision on non-automatic blocking of entities with designated leadership (§ 546.412).
- **2025-12-09 — OFAC designates a Colombia/Panama-based mercenary
recruitment network under E.O. 14098.** First register entry targeting the RSF's external recruitment supply chain rather than direct combatants or financiers: four individuals/entities including Colombian recruiter Alvaro Andres Quijano Becerra, agency A4SI, and Panama-based contracting intermediary Talent Bridge, S.A.
Why it's a distinct theme
Sudan occupies a structurally different position from the adjacent themes:
- vs. sanctions-enforcement-civil-penalties — that theme captures
enforcement-completion actions (penalties, settlements on pre-existing perimeters). The Part 546 reissuance and E.O. 14098 implementation are perimeter-creation and regulatory architecture actions, not enforcement.
- vs. western-russia-sanctions — although the general-license
architecture (legal services, humanitarian, wind-down) mirrors post-2022 Russia templates, the Sudan program responds to a distinct conflict dynamic and has no energy-supply dependency calculus shaping its design.
- vs. post-Assad-syria-sanctions-restructuring — Syria's perimeter is
being narrowed as the Assad era ends and sanctions relief is being debated; Sudan's perimeter is in an expansion phase following the 2023 civil war outbreak.
Future entries likely include: first-tranche SDN designations under E.O. 14098 targeting SAF or RSF command structures or conflict financiers; humanitarian carve-out updates extending GL 513 to fuel/energy given Sudan's acute fuel shortage; and potential sectoral designations targeting gold-mining networks that fund both SAF and RSF.