Sanctions Update No. 31 | LKS Attorneys

EU and UK expand sanctions against Sudan

On 13 and 16 July 2026, the European Union[1] and the United Kingdom[2] expanded their sanctions regime against Sudan respectively. These actions are a continued response to the conflict in Sudan.

Prohibitions. The EU has introduced new sectoral measures, which are designed to curb sources of financing for the conflict. The measures include:

A ban on the direct or indirect purchase, import or transfer of gold, gold waste or scrap, or gold coins originating in Sudan.
A ban on the direct or indirect sale, supply, transfer or export of mercury and cyanide, which are chemicals used for gold mining or gold exploitation, to Sudan.
Prohibitions on the provision of services, including technical assistance, brokering services and financial assistance related to the above bans.

Exclusions. The exclusions and relaxations provided by the EU are as follows:

The prohibitions gold, gold waste or scrap, or gold coins do not extend to gold which is necessary for the official purposes of diplomatic missions, consular posts or international organizations in Sudan enjoying immunities in accordance with international law.
The restrictions on mercury and cyanide do not apply to goods intended for humanitarian purposes, public health emergencies and disaster response.
For those contracts relating to the sale, supply, transfer or export of cyanide which were entered into before 15 July 2026, the prohibitions would not apply on their execution, up until 16 January 2027. This is subject to any export-control authorizations as ordinarily required under EU law.

Sanctioned persons. The UK sanctioned 11 individuals and entities under the Sudan sanctions regime. Most of the individuals and entities are from Sudan or the United Arab Emirates.

Reason(s) for sanctions. These individuals and entities have been sanctioned for supporting the conflict, through financial services and making funds, economic resources and weapons available to the key actors in the conflict. The UK has also recognized the role of ‘conflict gold’ as part of its sanctions.

Effect of sanctions. The sanctions measures imposed upon these individuals and entities are asset freezes and director disqualification sanctions. In the case of individuals, there is an additional travel ban as well. The obligation to comply with the requirements of sanctions fall on every individual and entity that is subject to UK jurisdiction.

LKS Comments

The EU and the UK have both taken a strong stance against actors contributing to the conflict in Sudan. In the recent past, the U.S. also sanctioned individuals and entities, including against an Indian individual, under its Sudan sanctions regime.

Businesses should therefore be cautious even where activities appear to have a legitimate civilian purpose. For example, transactions involving sectors such as gold mining can attract scrutiny where the resulting revenues are ultimately used to support sanctioned persons or conflict-related activities.

[1] Sudan: Council strengthens EU sanctions regime by targeting gold trade, available here, last accessed 20 July 2026; Council Regulation (EU) 2026/1724 of July 13, 2026, available here, last accessed 20 July 2026.
2Sanctions Notice: 16 July 2026 Regime: Sudan, available here, last accessed 20 July 2026.