Uncategorised
OFAC and FinCEN target South Sudanese PEPs

The US Office of Foreign Assets Control is targeting two South Sudanese government officials and one former official, plus three companies that are one of the officials owns/controls. Meanwhile, the Financial Crimes Enforcement Network has issued a non-binding 'advisory' to financial institutions to watch for movements of assets belonging to South Sudanese politically exposed persons.
The US Treasury, which is co-ordinating the effort, is claiming
that it does not like the idea of PEPs enriching themselves at
the expense of their citizenry.
OFAC has sanctioned Malek Reuben Riak Rengu, Michael Makuei Lueth
and Paul Malong Awan, in addition to three companies owned or
controlled by Malek Reuben Riak Rengu, in line with Executive
Order (EO) 13664, which authorises sanctions against people to do
with South Sudan. All their assets within the jurisdiction of the
United States are blocked and 'US persons' (companies included)
are generally prohibited from engaging in transactions with them.
FinCEN has issued an 'advisory' to alert US financial
institutions to their potential exposure to "anti-money
laundering risks" caused by certain South Sudanese senior
political figures attempting to use the US financial system to
move or hide the proceeds of public corruption. It is always keen
to receive suspicious activity reports (SARs) related to senior
foreign political figures.
Between 2013 and 2016, Malek Reuben Riak Rengu, the deputy chief
of defence force and inspector-general of the Sudan People’s
Liberation Army (SPLA), also held the position of deputy chief of
staff for logistics of the SPLA. When he did so, he played a
central part in the procurement of weapons during the first few
years of the conflict in South Sudan. United Nations experts say
that ammunition that the SPLA supplied to youth groups was
crucial in sustaining an offensive that resulted in widespread
transgressions against human rights. Malek Reuben allegedly
supported a hard-line position in a mid-2015 meeting of the
National Liberation Council, which met and decided to reject a
draft peace proposal. The Americans allege that he 'reportedly'
used his logistics position to issue contracts with inflated
prices in order to receive extensive kickbacks. In 2015, it
suspects, he fabricated procurement contracts for food provision
to SPLA troops. Malek Reuben also reportedly controls a private
company, Mak International Services Co Ltd, that sells explosives
to private companies in South Sudan in an arrangement promoted on
an exclusive basis by the SPLA, and has received payments and
cash deposits of hundreds of thousands of US dollars by
foreign-backed companies.
OFAC has also sanctioned or 'designated' All Energy Investments
Ltd, A+ Engineering, Electronics & Media Printing Co. Ltd, and
Mak International Services Co Ltd – all based in South Sudan –
for being owned or controlled by Malek Reuben.
Michael Makuei Lueth, the minister of information and
broadcasting, is suspected of orchestrating/being involved in
attacks against UN missions, obstructing humanitarian aid and
perpetuating conflict in his country. Paul Malong Awan, the
SPLA's former chief of general staff, is accused of similar
things and also of acts of corruption. After his dismissal from
his post, Malong was stopped outside Juba in early May 2017 and
reportedly found with currency worth millions of US dollars that
he had allegedly stolen from the SPLA treasury. In 2014, under
Malong, the ministry of defence procured loans of billions of
dollars from South Sudanese oil companies in order to acquire
military equipment but had still not made any actual military
purchases later in the year. Malong reportedly has several
properties outside his country and several of his children have
owned stakes in companies that appear to operate in a wide range
of business sectors, including a petroleum company.