New Approaches to Address the Role of Gold in Sudan’s Civil War

Introduction

As the war in Sudan stretches on into its fourth year, the devastation is unceasing. The United States has formally determined that both the Sudanese Armed Forces and Rapid Support Forces (RSF) have committed war crimes, while also finding the RSF and allied militias to have committed genocide, crimes against humanity, and ethnic cleansing. Despite these determinations and the up to 400,000 deaths, the UN humanitarian coordinator in the country recently dubbed it an “abandoned crisis,” highlighting the lack of progress from the international community in putting an end to the violence and humanitarian devastation.

The violence, in tandem with years of failure to end it, has led to an ongoing, yet to date largely futile, search for leverage points that have the potential to change the situation on the ground and that major stakeholders are willing and able to utilize. A recent letter sent from congressional democrats to U.S. Secretary of State Marco Rubio demands “[t]he United States must use the leverage and influence at our disposal to prevent further atrocities in El Obeid and help bring this brutal war in Sudan to an end.” In the letter, the authors echo various human rights organizations and the U.S. intelligence community in laying out the substantial support coming from the United Arab Emirates (UAE) to the Sudanese RSF, facilitating much of the most horrific violence. The UAE, for its part, continues to deny any involvement in the war in Sudan.

While the letter focuses on ending arms sales to the UAE to prevent their eventual usage in Sudan—which has been well documented in several outlets—such as the Wall Street Journal, the Yale School of Public Health Humanitarian Research Lab, and by numerous NGOs—there is another avenue for pressure that exists, and has for some time, largely in plain sight: gold.

Sudan was estimated to produce 74.6 tons of gold in 2025, placing it in the top 20 producers worldwide and fifth overall on the continent. This makes revenue from gold a key driver for all sides of the conflict. Much of the gold flow is directed to and sourced by entities in the UAE. While Emirati officials put the trade at just over $1 billion in 2025, Swissaid, a key tracker of gold flows, estimates a far larger number. Some 50 to 70 percent of Sudanese gold production is also smuggled out of the country annually, a number that has “increased significantly” since the outbreak of war in April 2023.

Enter EU Sanctions

Over the first three years of war, there have been limited efforts to leverage this symbiotic relationship to end the conflict. However, on July 13, 2026, the European Commission announced a series of measures targeting the gold sector in Sudan. The two main measures prohibit (1) the purchase, import, or transfer of gold originating in Sudan, and (2) the sale, supply, transfer, or export of mercury and cyanide— often used as facilitators of gold extraction, especially in informal mining settings, to the extreme detriment of the environment and local populations—to Sudan.

This EU action builds on and complements the array of measures that the United States and the United Kingdom have taken since the outbreak of the conflict, which have principally been a number of sanctions designations against various individuals and companies and, in May 2023, a statement included in a Business Risk Advisory Update by the United States that

Sudanese gold should therefore be considered a mineral from a conflict-affected area for purposes of due diligence pursuant to the [Organisation for Economic Co-Operation and Development (OECD) Due Diligence Guidance], the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the UN Guiding Principles on Business and Human Rights, and other government- or industry-developed responsible sourcing frameworks. Consistent with these recommendations, actors with connections to gold value chains should conduct heightened due diligence to prevent or mitigate the risks associated with trading in gold from a conflict-affected area, as well as those risks identified in more detail in the May 2022 Advisory. Appropriate due diligence measures should include measures with respect to gold labeled as recycled that reasonably could be believed to include Sudanese gold.

Unfortunately, this statement by the Department of State—which one of the authors of this brief was the principal drafter of—led to little meaningful policy change or impact on the industry, either in Sudan or further downstream in the supply chain. The fear is that this EU action will have similar results, especially given the muted reaction from the industry itself, which clearly sees little disruption resulting from the action.

Based on available reporting, it does not appear that the European Union is a major importer of Sudanese-origin gold, nor a dominant exporter of mercury or cyanide. Those distinctions with respect to imports of gold from Sudan and precursor chemicals to Sudan largely rest, again, with the UAE. Interestingly, neither the EU statement about the imposition of the new measures nor its webpage devoted to the Sudan crisis and EU actions to address it mentions the UAE a single time, nor does there appear to be any sense that that is coming as a follow-up, escalatory measure.

It is possible that establishing this type of broad-based action by the European Union to target the overall trade rather than chasing specific actors could shift the dynamic of international pressure, even if the impact on EU companies is limited. And indeed, devoting time, resources, and political capital to try to identify a handful of targets for individual asset freeze sanctions upstream in the trade—such as from Sudan through the transit points to the UAE or other refining centers—is no longer worth it for governments. The conflict and the trade are both too ensconced and too resilient to be impacted by periodic sanctions. 

Instead, the shift downstream—i.e., from the UAE and refining centers through to retail jewelers, manufacturers, banks, and other end users of gold—is where the focus should now remain. This should not rest with simply more encouragement to conduct due diligence. As with sanctions, responsible sourcing due diligence in the gold sector, rooted in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and then adapted by various industry associations or companies, has failed to demonstrate that it can disrupt supply chains connected to conflict. Although due diligence is an essential process for maintaining responsible supply chains and creating appropriate paper trails, it has proved insufficient for proactively disrupting illicit supply chain actors or identifying regions or jurisdictions that should, at least for a period of time, be considered too risky.

Recognition of these failures should lead to bolder action, and the European Union’s action may be a starting point, if complemented and buttressed by other measures. But it remains unclear whether the European Union or others will fully take this leap and pressure downstream actors in impactful ways.

Developing a Wraparound Strategy to End the Bloodshed

Given the focus prior to the EU action on sanctions, it is worth assessing where sanctions have led thus far in response to the crisis in Sudan. When deployed effectively and strategically, sanctions do not stand alone. They are most impactful when they are a part of a well-defined and coherent policy position that utilizes multiple levers of influence and provides clear offramps for sanctioned parties and their broader networks. Put differently, the goal must be to end the bloodshed in Sudan, and sanctions should be considered as a potential means towards that goal, rather than seen as an end in themselves.

Suffice to say that, although there were elements of this approach in place during the immediate response from the United States and others in 2023, including talks featuring both parties and leading to an ill-fated ceasefire, the focus waned in early 2024 when different policy strategies were employed, and there has been little in the way of integrated, coordinated strategy since approximately mid-2024. And in recent years, ties between the UAE and the U.S. government have only deepened as this vacuum widened.

To complicate matters, on July 10, the Department of Commerce announced eased export controls to the UAE, upgrading the country’s status and allowing it greater access to technologies “in recognition of the UAE’s status as a U.S. Major Defense Partner and its support for advancing U.S. national security interests” and “the ongoing U.S.-UAE military partnership.” These ties go beyond government-to-government, with an Emirati Sheikh investing $500 million in the Trump family’s cryptocurrency business four days before President Trump’s second inauguration.

The ability to handle multifaceted relationships with other states is a key element of foreign relations. The United States having complex relationships with Gulf countries is not new—in addition to the UAE, Saudi Arabia is a key actor in the Sudanese conflict specifically and in minerals investments on the African continent more generally, and the conflict is deeply internationalized, including support from a long list of countries —nor does the Trump administration stand alone in its reticence to directly confront the regional facilitators of the war in Sudan. However, without addressing the flow of weapons and funding to those committing atrocities, approaches that seek to end the bloodshed are akin to treating symptoms while leaving the underlying condition unchecked.

Conclusion and Recommendations: Is this About “Us,” or “Them”?

One way to think about the policy and purpose of sanctions measures is to ask, “is this about them, or about us?” If it is about “them,” then the measures should be designed to have maximum impact and be part of a clear ongoing strategy to disrupt the behavior of concern. On the other hand, if it is about “us,” then the measures will usually be designed to be largely performative and without clear connection to a policy strategy that can bring about disruption and broader change through negotiations. Put another way, in these situations where it’s “about us,” the United States just needs to say it did something and to try to make sure that, even as it recognizes that blood is flowing and people are dying, it just wants to keep its hands as clean as they can be.

Unfortunately, it appears that, to date, the actions taken by the European Union, United States, and United Kingdom against the Sudanese conflict gold trade are about the collective “us,” in the West, and not “them” in Sudan. These are not measures that can meaningfully disrupt the supply chain in a way that can change the way the trade works, and thus the potential profits and financing it offers.

One need only ask whether the gold supply chain itself has been meaningfully disrupted in the last three years, which could be expected when a genocide is unfolding in a major producer and gold is consistently pointed to as a key economic driver. On the contrary, the sector is experiencing record prices and profits during the Sudan conflict. Eliminating this driver may not stop the war or alleviate the humanitarian disaster, but it would change the incentive calculation of key stakeholders while limiting the flow of resources for continued atrocities.

Changing this dynamic boils down to two types of action: government policy and private sector collaboration.

Government Policy and Tools

1. Call for an end to the conflict and make clear all tools will be used for that purpose. The United States, European Union, and other governments should articulate a clear policy directive and statement that the Sudan conflict must be brought to an end and that all measures will be taken against those who finance or profit from it, including the UAE, Saudi Arabia, and others playing a proxy or enabling role.
2. Create mechanisms to enable meaningful intelligence sharing on illicit gold. Starting with Sudan, these mechanisms could enable communication between industry and governments to identify and take action against actors engaged in this trade, including through loss of bank accounts, loss of importing privileges, removal from trade certification bodies, prosecutions, and when deemed effective, sanctions. The United Kingdom has led the way with establishment of a subgroup of its Joint Money Laundering Intelligence Taskforce focused on gold. The UK mechanism needs to begin more concrete action, and other governments should follow this lead and, where appropriate, join forces. Again, the focus should be using these mechanisms to target and unravel entire networks, not chase a company here or there for sanctions purposes.
    

Government and Private Sector Pressure/Collaboration: Shift Downstream

1. Build pressure on the downstream actors benefitting from the lack of disruptive action and meaningful due diligence against Sudanese gold. This should especially apply to certification initiatives such as the Responsible Jewellery Council (RJC) and London Bullion Manufacturers Association as well as major companies in the jewelry, banking, and refining sectors. In particular, the RJC and broader jewelry sector should be a focus of engagement and enforcement as principal end users of gold. International trade associations in the jewelry sector, such as the World Jewellery Confederation (CIBJO), should be pressured to devote substantial resources and meaningful action to address the crisis.
2. Implement the approach that the United States has taken with the Uyghur Forced Labor Prevention Act. Establish a rebuttable presumption that all refined gold imported into the European Union from the UAE contains Sudanese gold unless the importer can prove otherwise.
3. Require gold importers to use traceability mechanisms to demonstrate that gold was not mined in Sudan. This would build on the G7 initiative implemented against Russian diamonds and require use of the growing field of gold traceability systems to require affirmative proof that gold was not mined in Sudan, regardless of its “country of origin,” which would typically be where mined gold is refined or processed into a new product. Traceability should not replace broader efforts at responsible sourcing due diligence, but as noted above, given that due diligence systems alone have not been sufficient to proactively disrupt the trade from Sudan, traceability can become a useful and more specific complement to initiatives like the EU import ban.
4. Impose a version of the responsible investment reporting requirements on downstream refiners and importers of gold. This should have a particular focus on ensuring public reporting on the specific due diligence undertaken with respect to gold mined in Sudan.
    

Andrew Friedman is director and senior fellow in the Human Rights Initiative at the Center for Strategic and International Studies (CSIS) in Washington, D.C. Brad Brooks-Rubin is a senior associate (non-resident) in the Human Rights Initiative and the Economics Program and Scholl Chair in International Business at CSIS.