Holland & Hart LLP: OFAC Sanctions “Sudanese Oligarch” for Fraud and Corrupt Dealings in South Sudan

On October 11, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on Ashraf Seed Ahmed Hussein Ali, a Sudanese national widely known by his pseudonym “Al-Cardinal,” pursuant to Executive Order 13818 and the Global Magnitsky Human Rights Accountability Act, for his alleged involvement in bribery, kickbacks, and procurement fraud with senior government officials in South Sudan.  OFAC’s placement of Al-Cardinal on the Specially Designated Nationals and Blocked Persons (SDN) List for his actions in South Sudan is particularly notable for at least two reasons.  First, the designation of Al-Cardinal illustrates the impact that private actors and public reporting can have in prompting and effectuating U.S. sanctions efforts.  Second, the designation provides confirmation that some of the challenges and problems facing South Sudan originate from outside its borders…

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