The Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department and the U.S. State Department announced sanctions against the leader of Sudan’s Rapid Support Forces (RSF) and seven UAE trading companies used by the RSF to acquire weapons and engage in banking transactions in violation of U.S. sanctions. As noted in the OFAC press release, the RSF has engaged in a brutal armed conflict with the Sudanese Army, killing tens of thousands and engaging in war crimes and crimes against humanity. Many of today’s designations reference previously designated UAE entities and individuals, making clear that this action reflects an ongoing investigation by U.S. authorities.
Pursuant to Executive Order 14098 (Sudanese Sanctions) OFAC designated RSF’s leader, Mohammad Hamdan Daglo Mousa (“Hemedti”), and a network of UAE companies used and controlled by him and his close contacts. The sanctioned entities are:
Capital Tap Holding L.L.C. (Capital Tap Holding), a UAE-based holding company that manages 50 companies over ten countries, owned and controlled by Sudanese national Abu Dharr Abdul Nabi Habiballa Ahmmed (Abu Dharr). Capital Tap Management Consultancies L.L.C. and Capital Tap General Trading L.L.C. are Capital Tap Holding subsidiaries based in the UAE.
Creative Python L.L.C., a UAE-based company, also owned and managed by Abu Dharr, was used as a cut-out to obfuscate Hemedti’s business dealings to avoid sanctions. Creative Python’s manager is Hemedti’s brother, Algoney Hamdan Daglo Musa (“Algoney”), who was sanctioned on October 8, 2024.
Al Zumoroud and Al Yaqoot Gold & Jewellers L.L.C. (AZ Gold) is a UAE-based gold purchasing company also managed by Abu Dharr. AZ Gold has purchased gold from Sudan, presumably for the benefit of the RSF, and subsequently transported it to Dubai. Algoney maintained access to AZ Gold’s bank account in the UAE, which held millions of dollars.
Al Jil Al Qadem General Trading L.L.C. (Al Jil Al Qadem) is a UAE-based company co-owned and co-managed by Abu Dharr and Abdelrahim Hamdan Dagalo, another brother of Hemedti and also an RSF commander who was designated on September 6, 2023.
Horizon Advanced Solutions General Trading L.L.C. – Sole Proprietorship (Horizon Advanced Solutions) is a UAE-based subsidiary of Capital Tap Holding. In early 2023, Horizon Advanced Solutions imported cargo from GSK Advanced Business Co Ltd, an information technology and security company managed by Algoney. On September 28, 2023, OFAC designated GSK Advanced pursuant to E.O. 14098.
Impact
This action serves as a reminder that the United States remains focused on the UAE as a region of concern for sanctions enforcement. Local and regional businesses should be mindful if they engage in trade or transactions with these designated entities or any related entities. The announcement notes that Capital Tap Holding manages 50 companies in ten countries—all of which will be deemed sanctioned under OFAC’s “50% Rule” if they are majority owned by Capital Tap. Moreover, regardless of ownership, any companies controlled by this network will present sanctions risk to counterparties and business affiliates. Companies involved in international business in the UAE should consider an OFAC compliance review.
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The foregoing is for informational purposes only. It is not intended as legal advice and no attorney-client relationship is formed by the provision of this information.