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South Sudan Country Summary

Sanctions

UN, EU and US sanctions in place

FATF AML Deficient List

Yes

Terrorism
Corruption
US State ML Assessment
Criminal Markets (GI Index)
EU Tax Blacklist
Offshore Finance Center

Please note that although the below Summary will give a general outline of the AML risks associated with the jurisdiction, if you are a Regulated entity then you may need to demonstrate that your Jurisdictional AML risk assessment has included a full assessment of the risk elements that have been identified as underpinning overall Country AML risk. To satisfy these requirements, we would recommend that you use our Subscription area.

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Anti Money Laundering

FATF status

South Sudan is on the FATF List of Countries that have been identified as having strategic AML deficiencies

Latest FATF Statement - 25 October 2024

Since June 2021, when South Sudan made a high-level political commitment to work with the FATF and ESAAMLG to strengthen the effectiveness of its AML/CFT regime, South Sudan has taken steps towards improving its AML/CFT regime, including by disseminating the results of their recently completed NRA to all stakeholders. South Sudan should continue to work to implement its action plan, including by: (1) finalising its comprehensive review of the AML/CFT Act (2012) to comply with the FATF Standards; (2) fully implementing the 1988 Vienna Convention, the 2000 Palermo Convention, and the 1999 Terrorist Financing Convention; (3) ensuring that competent authorities are suitably structured and capacitated to implement a risk-based approach to AML/CFT supervision for financial institutions; (4) developing a comprehensive legal framework to collect and verify the accuracy of beneficial ownership information for legal persons; (5) finalising the operationalisation of a fully functioning and independent FIU; (6) establishing and implementing the legal and institutional framework to implement targeted financial sanctions in compliance with United Nations Security Council Resolutions on terrorism and WMD proliferation financing; and (7) commencing implementation of targeted risk-based supervision/monitoring of NPOs at risk of TF abuse.

The FATF notes South Sudan’s limited progress across its action plan with all deadlines now expired and work remaining. The FATF again encourages South Sudan to continue to implement its action plan to address the above-mentioned strategic deficiencies as soon as possible and demonstrate strong political and institutional commitment to strengthen the effectiveness of its AML/CFT regime, particularly in supporting the lead AML/CFT agency in coordinating national AML/CFT efforts.

Compliance with FATF Recommendations

South Sudan has not yet undertaken a Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards.

Sanctions

As a UN member, South Sudan must adhere to sanctions aimed at maintaining international peace and security. The UN Security Council has established various sanctions regimes since 1966, including those targeting individuals and entities that threaten peace or commit human rights violations, with ongoing measures in place as of October 2023.

Sanctions against South Sudan include travel bans, asset freezes, and arms embargoes, reflecting concerns over human rights abuses and the need for a supportive transition. Recent discussions highlighted the negative impact of these sanctions, with calls for a more constructive approach to aid South Sudan's peace processes and security reforms.

Bribery & Corruption

Rating 0 (bad) - 100 (good)
Transparency International Corruption Index 13
World Bank: Control of Corruption Percentile Rank 0

South Sudan faces significant challenges in combating corruption, with laws in place but little enforcement and considerable gaps in legislation. The country has been ranked as the most corrupt globally, with politically connected individuals often immune from prosecution and government officials routinely demanding extralegal payments. Despite the establishment of anti-corruption bodies, such as the Southern Sudan Anti-Corruption Commission, these organizations lack the necessary resources and political support to effectively investigate and prosecute corruption, leading to a pervasive culture of impunity.

Economy

South Sudan's economy is heavily reliant on oil revenue, which accounts for the majority of its income, with approximately $1.6 billion generated annually. However, the economy suffers from endemic corruption, mismanagement, and a lack of transparency, particularly within the oil sector, which has led to significant risks for businesses operating in the country. The transitional government has made little progress in implementing necessary reforms, further exacerbating the challenges faced by investors.

The investment climate in South Sudan remains challenging, with no significant improvements in trade and investment conditions over the past year. The lack of essential reforms, such as a permanent constitution and a functional judicial system, exacerbates corruption and increases risks for businesses. Additionally, the slow pace of political and financial reforms, coupled with a complex and opaque registration process for foreign investors, further deters potential investment.

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