Your customer or buyer is asking about supply chain exposure to Sudan. Here is what the regulatory environment requires.
Sudan has been in a state of civil war since April 2023, when fighting broke out between the Sudanese Armed Forces (SAF) and the Rapid Support Forces (RSF). The conflict has created one of the world's worst humanitarian crises — with millions displaced and widespread atrocities documented, including what the US government has described as genocide in Darfur. Sudan was previously subject to comprehensive US sanctions (lifted in 2017) and remains subject to targeted sanctions. The country has significant agricultural exports — sesame, gum arabic, livestock — and gold mining. ESG compliance in Sudan is primarily relevant for food companies sourcing sesame and gum arabic, and for companies assessing conflict-related ESG risks.
Key regulations in Sudan — ESG Supplier Guide
International Sanctions — Sudan Conflict
The SAF and RSF leadership are subject to targeted UN, US, EU, and UK sanctions. EU companies must conduct enhanced sanctions screening for any transactions involving Sudan. The RSF has been accused of genocide, mass rape, and ethnic cleansing in Darfur — the US government formally designated the RSF's actions as genocide in March 2024.
EU CSDDD — Critical Risk Jurisdiction
Sudan is classified as a conflict-affected and high-risk area (CAHRA) under OECD guidelines and EU CSDDD. EU companies with any supply chain exposure to Sudan must conduct enhanced human rights and environmental due diligence. Key ESG risks include: conflict financing, genocide (Darfur), forced displacement, and governance collapse.
EU CSRD — Sesame and Gum Arabic Supply Chains
Sudan is one of the world's largest sesame exporters and the world's largest gum arabic producer (gum arabic is used in food, beverages, and pharmaceuticals). EU food companies sourcing Sudanese sesame and gum arabic face CSRD supply chain reporting requirements. Key ESG issues include: conflict financing risks, forced labour, and governance collapse.
Sudan Data Protection & Cyber Obligations
Sudan does not yet have a comprehensive data protection law or mandatory cyber incident reporting regime. The National Telecommunications Corporation (NTC) oversees telecommunications. The ongoing political and security situation significantly affects the operating environment. International sanctions and the restricted operating environment significantly affect engagement with Sudanese entities. Suppliers should obtain specialist legal advice before engaging with Sudanese entities.
What this means for you as a supplier
Sudan is a critical-risk jurisdiction. The ongoing civil war, genocide allegations against the RSF, and humanitarian crisis create the highest level of CSDDD due diligence requirements. Sanctions screening is mandatory. Most responsible EU buyers have suspended Sudanese supply chains. For unavoidable exposure (gum arabic, sesame), enhanced CSDDD due diligence and conflict financing assessment are required.
Key dates
Ongoing
UN/US/EU/UK sanctions on Sudan conflict parties — mandatory screening
FY2024 (ongoing)
CSRD — large EU companies must report on supply chain sustainability including Sudan exposure
July 2029
CSDDD Phase 1 — enhanced due diligence required for Sudan supply chains
Sudan civil war: one of the world's worst humanitarian crises
The Sudan civil war, which began in April 2023 between the Sudanese Armed Forces (SAF) and the Rapid Support Forces (RSF), has created one of the world's worst humanitarian crises. By early 2025, approximately 10 million people had been displaced — the world's largest displacement crisis — and widespread atrocities had been documented, including mass killings, mass rape, and ethnic cleansing in Darfur. The US government formally designated the RSF's actions in Darfur as genocide in March 2024. The conflict has caused the near-total collapse of Sudan's healthcare system, widespread famine, and the destruction of critical infrastructure. For EU companies with any Sudan supply chain exposure, the conflict creates the highest level of CSDDD due diligence requirements: conflict financing assessment (do purchases generate revenue that finances conflict parties?), forced labour assessment, and governance collapse assessment. Most responsible EU buyers have suspended Sudanese supply chains entirely.
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
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