On July 1, 2014, OFAC issued regulations to implement E.O. 13664 of April 3, 2014 ("Blocking Property of Certain Persons with Respect to South Sudan"). OFAC indicated that it intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance and additional general licenses and statements of licensing policy.
On September 18, OFAC added two individuals — James Koang Chuol and Santino Deng Wol — to the SDN List pursuant to E.O. 13664 for threatening the peace, security or stability of South Sudan, and for extending the conflict or obstructing peace talks or processes in South Sudan. The two individuals were also designated for being leaders of groups whose members are likewise involved in activities sanctionable pursuant to E.O. 23664. James Koang Chuol is a leader of anti-government forces whose members targeted civilians, including women and children, with killing, sexual violence, and attacks on schools, hospitals, religious sites, and locations where civilians were seeking refuge. Santino Deng Wol is a Major General in the Sudanese People's Liberation Army who allegedly led and directed military actions against opposition forces and conducted confrontational troop movements in violation of the January 23, 2014 Cessation of Hostilities agreement.
On July 10, the European Union announced sanctions against Santino Deng Wol as well as rebel commander Peter Gadet Yaak. The EU has cautioned that sanctions targeting persons in South Sudan will be expanded swiftly to include more people if there are no signs of progress toward a peace agreement.
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