The Star in Kenya on 22nd March reported that the US has imposed sanctions on 15 South Sudanese oil operators that it said were important sources of cash for the government, an action aimed at increasing pressure on President Salva Kiir to end the country’s conflict and humanitarian crisis.  The companies and government bodies would in future require special licenses to do business in the US, the State Department said.  The US has already placed sanctions on South Sudanese military and political figures, and in January imposed an arms embargo to halt the flow of weapons into the country, signalling that it had lost patience with South Sudan’s warring factions for ignoring ceasefires.  The US Department of Commerce placed the South Sudan Ministry of Mining, the South Sudan Ministry of Petroleum, and state oil firm Nile Petroleum and associated companies on its list; alongside Dar Petroleum Operating Company, an oil and gas consortium led by China National Petroleum Corp and Malaysia’s state-run oil and gas firm Petronas, the 2 largest oil firms operating in South Sudan.  The restrictions also cover oil distributor Nyakek and Sons; Greater Pioneer Operating; Juba Petrotech Technical Services; Nigeria’s Oranto Petroleum, and Sudd Petroleum Operating.


The US Department of Commerce, Bureau of Industry and security (BIS) Export Administration Regulations (EAR) contain a list of names of certain foreign persons – including businesses, research institutions, government and private organizations, individuals, and other types of legal persons – that are subject to specific license requirements for the export, reexport and/or transfer (in-country) of specified items. These persons comprise the “Entity List”.  On 22nd March, BIS added 15 South Sudan entities to the Entity List – the first South Sudan entities on the List –

Ascom Sudd Operating Company; Dar Petroleum Operating Company; DietsmannNile; Greater Pioneer Operating Co. Ltd; Juba Petrotech Technical Services Ltd; Nile Delta Petroleum Company; Nile Drilling and Services Company; Nile Petroleum Corporation; Nyakek and Sons; Oranto Petroleum; Safinat Group; SIPET Engineering and Consultancy Services; South Sudan Ministry of Mining; South Sudan Ministry of Petroleum; and Sudd Petroleum Operating Co.

These 15 entities are subject to a licence requirement for all exports and reexports destined for any of the entities and transfers (in-country) to them of all items subject to the EAR with a licensing review policy of a presumption of denial.  This licence requirement also applies to any transaction involving any of these entities in which such entities act as a purchaser, intermediate consignee, ultimate consignee or end-user.  Additionally, no licence exceptions are available to these entities.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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