The Sudan conflict is being structurally prolonged by external financing streams, especially conflict gold flows routed through the UAE’s trading / refining system. As we pointed out in our recent analysis, the RSF’s sustainability is not endogenous, it is capital enabled. Western inaction is not a neutrality, it is an enabling environment. Western sanctions architecture has precedent, jurisdiction, teeth and precedents (Magnitsky, Global Human Rights Sanctions Regulations etc.) Sudan requires a shift from “condemnation” into enforcement.

This is a wholly solvable problem, the US / UK / EU national security, sanctions directorates, parliamentary committees, regulatory agencies, serious NGO and investigative networks have to be forced to act.

As a strategic objective we have to dramatically increase the economic, reputational, risk and compliance cost for any actor (state, corporate, logistics, refining) participating in conflict gold monetisation that fuels RSF operational persistence.

Key Leverage Points

Gold/ Refining
Action lever – Due diligence enforcement, audit transparency, sanctions on high risk refiners.
Why it matters – It hits the RSF’s primary capitalising mechanism.

Aviation
Action lever – Targeted pressure on Emirates/ Etihad cargo compliance.
Why it matters – Air logistics are choke-points.

Port/ Maritime
Action lever – DP World pressure, maritime sanctions design.
Why it matters – RSF cannot be sustained without safe export routes.

Sovereign Wealth Funds influence
Action lever – Scrutiny on Mubadala + ADQ partnership deals.
Why it matters – Western politics is paralysed because SWF money buys silence.

Banking AML
Action lever – Beneficial ownership transparency.
Why it matters – Removes anonymity and increases cost to move conflict capital.

Mixed Western Policy Package (14 day activation window)

US

• Office of Foreign Assets Control targeted sanctions on conflict gold supply chain facilitators.

• Congress letter to Treasury / State Departments demanding specific mapping and disclosures of conflict gold flows.

• Trigger 50 USC §1701 IEEPA framing to justify emergency national security interest.

UK

• FCDO (Foreign Commonwealth and Development Office) and OFSI (Office of Financial Sanctions Implementation) targeted sanctions on conflict resource based economic actors.

• FCA (Financial Conduct Authority) advisory to LBMA (London Bullion Market Association) and UK refiners to escalate due diligence standards on any UAE linked gold importer.

• City of London disclosure requirements on sovereign wealth partnership deals (Mubadala/ ADQ) with Sudan conflict exposure risk flagging.

EU

• EEAS (European External Action Service) DG FISMA (Directorate-General for Financial Stability, Financial Services and Capital Markets Union) directive conflict gold high risk importer list.

• Expand EU AML (Anti Money Laundering) package to include conflict resource mandatory enhanced due diligence where UAE is the intermediary jurisdiction.

• Euronext disclosure triggers for firms with UAE SWF major minority holdings.

Lawfare allows for the leveraging of:

• Existing Magnitsky frameworks.

• AML/counter illicit finance authority.

• Existing precedent on conflict minerals (DRC model).

Western governments do not need new laws, they need the political will to act.

The narrative framing for politicians (which matters more than policy text) is that:

• Sudan is not a remote conflict.

• Sudan is a test of whether Western rules based order applies equally when the perpetrator / enabler is a capital-rich actor the West likes doing business with.

• This is a credibility stress test.

If Western Governments do nothing, they effectively admit that rules are subordinate to sovereign wealth.

Our Parliamentary/ Congressional asks are:

1. Demand the Government publish a quarterly disclosure of conflict gold high risk jurisdiction import volumes.

2. Demand the Government publish sovereign wealth fund risk registers (Mubadala / ADQ flagged).

3. Demand the Government coordinate sanctions with US and EU simultaneously to prevent evasion through liquidity arbitrage.

Government measures only work if civil society and media pressures sustain a political will outlined in our policy brief.

Our third part on our Sudan briefing will convert this into activist toolkit and what the levers of a civil society mobilisation toolkit should include.