Scope: This dossier examines foreign recruitment networks supporting Sudan’s Rapid Support Forces, the evidence concerning their connections to the United Arab Emirates, and the institutional implications of Lana Zaki Nusseibeh’s nomination as UN secretary-general, covering developments since 2023 and the outlook to 2031.

Executive Summary / BLUF

The official record supports a substantial transnational recruitment operation supplying Colombian military expertise to Sudan’s Rapid Support Forces (RSF); it does not, by itself, establish every allegation of Emirati state direction or individual responsibility contained in the supplied article. US sanctions provide a concrete enforcement baseline, while UN findings identify UAE-linked entities within the wider support network. Abu Dhabi disputes involvement. U.S. Department of the Treasury

The UAE formally nominated Lana Zaki Nusseibeh on 21 October 2026, creating a consequential test of institutional independence and public confidence. Her nomination is documented; personal involvement in recruitment operations is not established by the records examined. Emirates News Agency

The central policy question is whether investigators, financial authorities and UN member states can establish responsibility across the contracting chain while applying credible safeguards to the leadership selection process. National affiliation alone neither establishes personal culpability nor resolves legitimate questions about independence.

United Arab Emirates Real Estate and Capital Ecosystem – The Broken Safe Haven: Macroeconomic Realignment, Sovereign Risk Quantification

Sudan’s Foreign Fighters Expose the UN’s Independence Test

The nomination of UAE Minister of State Lana Zaki Nusseibeh as UN secretary-general on 21 October 2026 places an institutional contradiction before governments already confronting evidence of external support for Sudan’s war. The organisation is examining recruitment networks linked to the country sponsoring a candidate for its highest administrative office. The consequence is a test of whether member states can preserve investigative independence while converting documented findings into enforceable restrictions on military services, finance and transport. Nusseibeh’s personal involvement in recruitment is not established by the dossier. The policy failure would be to let the contest over her candidacy consume the attention needed to constrain the support system itself. Appointment scrutiny and enforcement must produce separate, verifiable decisions. UAE nomination announcement — Emirates News Agency — October 2026.

The workforce supplied military capability through commercial contracts

The December 2025 US Treasury findings describe recruitment for drone operators, snipers and translators, with deployed personnel performing infantry, artillery, vehicle-operation and instruction duties. That combination matters because it supplies capabilities whose effectiveness depends on trained people as much as equipment. A security-services contract can organise employment and payment while leaving the decisive military relationship elsewhere: with whoever assigns the personnel, specifies their tasks and receives their operational reports. Enforcement must follow those functions across the contractual chain. Treasury Sanctions Transnational Network Recruiting Colombians to Fight in Sudan’s Civil War — December 2025.

The September 2026 UN fact-finding report describes foreign specialists operating and maintaining systems as well as providing instruction. The distinction determines how external support transmits into military endurance. Operators make equipment usable immediately; maintenance preserves availability; instructors can transfer skills and reduce future dependence. Removing a contractor therefore has different consequences depending on whether the service has become replaceable. Counting departures without identifying the function lost would provide a poor measure of disruption. Fuelling Sudan’s conflict: weapons, fighters and external support networks — UN Fact-Finding Mission — September 2026.

The numbers expose a mismatch between scale and scrutiny

The UN mission recorded recruitment estimates ranging from 350 to 2,000 and assessed that the total could approach the upper figure. That is not a verified count of personnel simultaneously available for combat. The financial record is similarly consequential but incomplete: the EU’s May 2026 listing instrument describes transfers totalling millions of US dollars during 2024–2025, without establishing a precise operating budget. Neither figure supports an invented salary bill or a calculated share of Rapid Support Forces operations. Their policy significance is that an international labour-and-payment system requires scrutiny beyond individual battlefield sightings. Council Implementing Regulation (EU) 2026/1051 — May 2026.

The institutional deadlines are more precise. Security Council Resolution 2830 renewed the relevant UN sanctions measures until 11 December 2026 and the experts’ mandate until 11 January 2027. The EU separately extended its autonomous framework until 10 October 2027. Governments therefore face an immediate continuity decision before they can credibly assess a longer enforcement campaign. Preserving European restrictions would not independently preserve the UN’s monitoring function; renewing an expert mandate would not demonstrate that prohibited services had been interrupted. UN Security Council Resolution 2830 — October 2026; Council Decision (CFSP) 2026/2261 — October 2026.

Corporate changes make enforcement a continuity problem

The April 2026 Treasury action identified Fénix Human Resources as a replacement for International Services Agency, known as A4SI. Fénix reportedly opened in February 2025, before A4SI’s December 2025 US designation. That chronology prevents a convenient but unsupported conclusion that its creation responded to that later sanction. It nevertheless establishes the need to examine continuity through ownership, contracts, signatories and payments. Screening a company’s current name cannot answer whether its predecessors’ obligations and activities survived under another structure. Treasury Sanctions Recruitment Network Enabling War in Sudan — April 2026.

Treasury’s June 2026 action also recorded Global Staffing’s rebranding as Talent Bridge in July 2025 and changes among its officeholders. The enforcement question is what changed operationally. If contractual responsibilities, payment instructions and services continued, a new presentation would not demonstrate interruption. If those functions ceased, shared personnel alone would not prove that another company inherited them. Authorities need records connecting legal identity to actual performance; otherwise, they risk missing continuity or attributing transactions to the wrong entity. Treasury Sanctions Networks Fueling Sudan’s Civil War — June 2026.

European law reaches the services surrounding the weapons

Council Decision 2014/450 already addresses military equipment, related technical assistance and brokering, associated finance and circumvention, subject to specified exceptions and authorisation conditions. This gives European governments a concrete implementation question: whether identified services fall within existing restrictions. A transport, maintenance or financing relationship cannot be assessed solely through its commercial description. The provider, destination, intended use and applicable jurisdiction determine which prohibition requires examination. Council Decision 2014/450/CFSP, articles 1–2, consolidated June 2026.

Italy, France and Germany consequently have distinct tasks within a common European framework. Italy can examine any substantiated domestic nexus to the recruitment system. France can reconcile equipment-diversion allegations with product identification, export authorisations and onward-transfer records; its June 2026 parliamentary answer stated that consultations had not established a reported presence involving French equipment. Germany’s convening role at the April 2026 Berlin conference creates a basis for demanding implementation reports from partners. None of these functions is discharged by endorsing another communiqué. French government response to written question 10906 — June 2026; Germany and Sudan: Bilateral relations — July 2026.

The United Kingdom’s February 2026 designations provide a separate enforcement track, while the November 2026 G7 declaration supplies a shared demand that external actors stop military, logistical and financial support. The missing connection is between that demand and verified outcomes: interrupted prohibited services, substantiated investigations and cooperation that resolves disputed evidence. Agreement on language does not establish agreement on which transaction, licence or relationship governments will examine. UK Sudan sanctions notice — February 2026; G7 foreign ministers’ declaration — November 2026.

Jurisdictional limits leave substantive questions unresolved

The UAE disputes involvement and states that its investigations found no relevant connection between GSSG and the alleged mercenary activity. Those claims require assessment against the records examined, the period covered and the treatment of contradictory evidence. Corporate proximity to officials cannot independently establish state direction; a general denial cannot reconcile specific contracts, movements or instructions. The next useful diplomatic request is therefore documentary: what was investigated, through which powers, and with what substantiated findings? UAE letter to the Security Council, S/2025/666 — October 2025.

The ICJ’s May 2025 dismissal of Sudan’s case against the UAE addressed jurisdiction, reflecting the Emirati reservation to Article IX of the Genocide Convention. It did not adjudicate the underlying allegations. Nor does failure to establish state control over a particular operation settle every question of assistance or prevention. Legal precision matters operationally: governments need to identify the conduct and obligation at issue, rather than wait for a single judgment to resolve the entire support system. Sudan v. United Arab Emirates, Order of 5 May 2025 — International Court of Justice.

The next two years will reveal who absorbs enforcement failure

Nusseibeh’s candidacy should be assessed against Article 100’s independence obligations and the funding-disclosure provisions of General Assembly Resolution 79/327. Her campaign states that she has taken leave from UAE government responsibilities. The consequential questions concern how conflicts would be reviewed, sensitive administrative decisions documented and investigative work protected. These safeguards must survive any appointment outcome: a leadership contest cannot resolve allegations concerning recruitment, and an appointment would not confer authority over every accountability institution. UN Charter, Article 100; General Assembly Resolution 79/327 — September 2025.

Between November 2026 and November 2028, the decisive test will be whether governments preserve monitoring and translate existing restrictions into changes in actual service delivery. If they settle for repeated declarations, providers able to replace intermediaries can retain room to operate while investigators lose time and evidence. If enforcement instead obstructs authorised relief payments, Sudanese civilians bear an additional cost without any demonstrated reduction in military support. Resolution 2830’s approaching deadlines make the choice concrete: governments must finance and protect the capacity to establish what is happening, act on substantiated findings and keep humanitarian channels functioning. Sudan’s civilians pay first for failure; donors finance the consequences, and the UN absorbs the loss of credibility.

ASYMMETRIC DISSOLUTION AND KINETIC REALIGNMENT: A MULTI-DOMAIN INTELLIGENCE SYNTHESIS ON THE INSTITUTIONAL SEVERANCE OF THE UNITED ARAB EMIRATES FROM THE OPEC+ ARCHITECTURE AMID THE 2026 PERSIAN GULF CONFLICT

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Navigational Index

Pillar I — The Recruitment System and Its Operational Effects

• Chapter 1 — From Private Recruitment to Combat Support: Actors, documentary baseline and the distinction between security employment and participation in hostilities.
• Chapter 2 — Transit Corridors and Technical Dependence: Recruitment, contracting, transport and the operational value of foreign specialists.
• Chapter 3 — Money, Corporate Intermediaries and Enforcement: Payment structures, corporate continuity and sanctions exposure.

Pillar II — Responsibility, Attribution and International Governance

• Chapter 4 — The UAE Connection: Official allegations, Emirati responses and the evidence required to establish state responsibility.
• Chapter 5 — Sudan, International Law and Accountability: Investigative findings, jurisdictional limits and the consequences of outsourcing military functions.
• Chapter 6 — The Secretary-General Candidacy: Appointment rules, independence obligations and safeguards against interference.

Pillar III — External Leverage and the 2027–2031 Outlook

• Chapter 7 — European and International Choices: Separate implications for Italy, France, Germany, the United Kingdom and the European Union.
• Chapter 8 — Scenarios, Decision Thresholds and Final Net Assessment: Network adaptation, investigative cooperation, institutional credibility and feasible responses.

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Libya–Türkiye Maritime Accord: Haftar’s Strategic Pivot and the Mediterranean Balance of Power

Master Abstract

The documented network makes financial accountability immediately relevant

The strongest starting point is the US Treasury’s 9 December 2025 action against four individuals and four entities. Treasury identified International Services Agency, known as A4SI, as a recruitment node; Panama-based Global Staffing, subsequently Talent Bridge, as a contracting intermediary; and Maine Global Corp as a payment facilitator. It identified retired officer Alvaro Andres Quijano Becerra, based in the UAE, as a central organiser. These are official sanctions findings, rather than criminal convictions, but they establish an actionable enforcement record extending beyond political allegations. Treasury Sanctions Transnational Network Recruiting Colombians to Fight in Sudan’s Civil War — US Department of the Treasury — Dec 2025. U.S. Department of the Treasury

The analytical consequence is that responsibility should be examined function by function. Recruiting personnel, signing employment agreements, arranging transport, paying salaries and directing military employment are distinct activities. Their separation across companies can complicate attribution without making the operation commercially or legally disconnected. Investigators therefore need to connect contracts to actual services, payments to beneficiaries, and deployment instructions to the people who issued them. A company’s incorporation jurisdiction identifies a potential investigative authority; it does not automatically identify the government directing its activities.

Treasury’s subsequent 26 June 2026 action described further associates of Talent Bridge and recorded its change of name from Global Staffing in July 2025. The same release addressed procurement and recruitment networks benefiting both Sudanese belligerents. This matters because enforcement must follow corporate continuity and actual conduct rather than rely exclusively on a company’s current name or on the political identity of its customers. Treasury Sanctions Networks Fueling Sudan’s Civil War and Worsening Humanitarian Crisis — US Department of the Treasury — Jun 2026. U.S. Department of the Treasury

Foreign specialists can sustain capabilities beyond their numerical strength

The UN fact-finding mission’s September 2026 report assessed that Colombian recruitment could approach 2,000, while recording varying estimates. It described reported transit through the UAE, Bosaso, Libya and Chad, training at a military-style facility in Ghayathi, and contractors’ roles in drones, artillery, maintenance and instruction. Its conclusions concerning UAE-linked networks appear in paragraphs 125–126. These findings support scrutiny of a structured support system; the estimate should not be presented as a verified simultaneous battlefield strength. Fuelling Sudan’s conflict: weapons, fighters and external support networks, A/HRC/63/23, paragraphs 85–94 and 125–126 — Independent International Fact-Finding Mission for the Sudan — Sep 2026. wapsphp.test.ohchr.un-icc.cloud

The operational implication is qualitative. A relatively limited contingent can sustain a much larger force when it supplies skills required to operate, repair or integrate specialised equipment. Conversely, the departure of technicians can reduce capability even when weapons remain physically available. This creates a potential enforcement opportunity: measures directed at replacement recruitment, maintenance support and payment continuity may affect military effectiveness differently from measures aimed solely at equipment shipments.

That mechanism also limits what can responsibly be inferred. Presence near a battlefield does not establish responsibility for every operation conducted there. Technical employment, participation in a particular attack and involvement in an atrocity require different evidence. An assessment that collapses these categories would weaken the prospects of identifying those actually responsible.

The UAE’s denial must be assessed against the underlying records

Sudan’s 5 September 2025 Security Council submission explicitly accused GSSG and A4SI of facilitating foreign recruitment and deployment. It included annexed material, but remains a submission by a government associated with one side of the conflict. Its circulation as a UN document does not convert its allegations into findings adopted by the Security Council. Letter dated 5 September 2025 from the Permanent Representative of the Sudan to the United Nations addressed to the President of the Security Council, S/2025/555 — Sudan / United Nations — Sep 2025. digitallibrary.un.org

The UAE’s 22 October 2025 response rejected support for either belligerent, challenged the provenance and completeness of Sudan’s documentation, and stated that its authorities had investigated GSSG and found no connection to the alleged mercenary activity. That response is an official statement of Abu Dhabi’s position, not an independently demonstrated resolution of the allegations. Letter dated 22 October 2025 from the Permanent Representative of the United Arab Emirates to the United Nations addressed to the President of the Security Council, S/2025/666 — UAE / United Nations — Oct 2025. digitallibrary.un.org

The decisive next step is documentary reconciliation. Investigative conclusions become more persuasive when authorities disclose their scope, records examined, relevant corporate identities and treatment of conflicting evidence. A general denial cannot substitute for that comparison; equally, commercial relationships or proximity to senior officials cannot independently establish orders from the state. The report’s assessment would materially change if authenticated records demonstrated official authorisation, operational instructions or knowing financial support—or, in the other direction, a credible investigation explained the disputed transactions and movements.

The ICJ proceedings did not determine the substantive allegations

On 5 May 2025, the International Court of Justice rejected Sudan’s request for provisional measures and removed the case against the UAE from its General List because it lacked jurisdiction, reflecting the UAE’s reservation to Article IX of the Genocide Convention. The Court’s published summary explains the jurisdictional reasoning. This outcome did not adjudicate the factual merits of the alleged support. Summary of the Order of 5 May 2025, Summary 2025/2 — International Court of Justice — May 2025. api.icj-cij.org

This distinction affects diplomatic messaging and policy design. A jurisdictional dismissal cannot establish that the alleged conduct occurred, and it cannot establish that the conduct did not occur. Other competent authorities must assess evidence under their own mandates. Decision-makers should therefore distinguish judicial findings, administrative sanctions, investigative assessments and diplomatic submissions instead of treating them as interchangeable measures of proof.

Nusseibeh’s candidacy raises a governance question requiring specific safeguards

The UAE’s state news agency recorded Nusseibeh’s formal nomination on 21 October 2026, following a presidential letter to the presidents of the General Assembly and Security Council. It also recorded her service as UAE permanent representative from 2013 to 2024. The nomination is therefore a documented state initiative, although the nomination announcement is an interested-party account of her qualifications. UAE formally nominates Lana Nusseibeh for United Nations Secretary-General — Emirates News Agency — Oct 2026. Emirates News Agency

Under Article 97, the General Assembly appoints the secretary-general on the Security Council’s recommendation. National nomination alone does not confer authority over the organisation. Charter of the United Nations, Article 97 — United Nations — 1945. Codification Division Publications Under Article 100, the secretary-general and Secretariat must remain independent of governmental instructions, while member states must respect that independence. Charter of the United Nations, Article 100 — United Nations — 1945. Codification Division Publications

The appropriate scrutiny concerns how those obligations would operate in practice: protection of investigative staff, preservation of evidence, transparent handling of conflicts and consistent treatment of allegations involving the candidate’s country of nationality. These are proposed governance safeguards, not findings that interference has occurred. The supplied material does not establish that Nusseibeh personally organised or financed the recruitment operation. Nor does the coexistence of a nomination and investigations prove that the nomination was designed to obstruct them. Such an intention would require additional evidence.

Key Evidence Table

Indicator	Value/status	Reference date	Definition/scope	Issuer	Exact source
Initial US recruitment-network action	Four individuals and four entities sanctioned	9 Dec 2025	Administrative designations; not criminal convictions	US Treasury / OFAC	Treasury sanctions announcement
Subsequent enforcement	Further network associates designated	26 Jun 2026	Includes associates of Talent Bridge	US Treasury / OFAC	Treasury follow-up action
Colombian recruitment estimate	Could approach 2,000	Sep 2026	Estimate of recruitment; not simultaneous deployed strength	UN fact-finding mission	A/HRC/63/23, paragraph 85
GSSG involvement	Alleged by Sudan; rejected by UAE	Sep–Oct 2025	Conflicting state submissions	Sudan; UAE	S/2025/555; S/2025/666
Nusseibeh nomination	Formally announced	21 Oct 2026	Candidacy, not appointment	Emirates News Agency	Official announcement
Sudan v. UAE proceedings	Removed for lack of jurisdiction	5 May 2025	No substantive determination of the allegations	ICJ	Summary 2025/2

The entries above retain the distinction between enforcement decisions, estimates, official positions and procedural outcomes. U.S. Department of the Treasury

Competing Explanations and Discriminating Indicators

The record supports examination of several explanations for the degree of official involvement, but it does not yet provide sufficiently diagnostic evidence to rank three distinct hypotheses through a formal competing-hypotheses matrix.

Explanation to examine	Evidence needed to strengthen it	Evidence that would weaken it
Private commercial organisation operating without state direction	Authenticated private financing and instructions; credible evidence of concealment from authorities	Official deployment orders or knowingly provided state resources
Private organisation benefiting from official tolerance or facilitation	Documented official knowledge, permissions or continued assistance after specific warnings	Effective investigations, interrupted deployments and substantiated enforcement
Operation subject to state direction	Authenticated tasking, command relationships or financing tied to deployment decisions	Independently corroborated records establishing autonomous decisions and action against organisers

These explanations can overlap across institutions and periods. Evidence of facilitation at one stage would not automatically establish state command over battlefield activity.

Principal Gaps and Watch Indicators

Consequential gap	Record or observation required	Decision consequence
Identity of the ultimate commissioning party	Authenticated service contracts, amendments and deployment instructions	Determines whether responsibility extends beyond recruiters and intermediaries
Source and purpose of funds	Bank records, payment instructions, invoices and beneficial-ownership evidence	Enables transaction-specific enforcement
Nature of official knowledge or assistance	Facility access records, authorisations and communications	Distinguishes private activity, tolerance, facilitation and direction
Scope of Emirati investigations	Findings, investigative mandate and explanation of conflicting evidence	Tests the substance of the official denial
Responsibility for particular violations	Unit assignments, orders, attack records and corroborated testimony	Connects individual conduct to identifiable incidents
Protection of UN independence	Published commitments and observable treatment of investigators and evidence	Tests whether institutional safeguards operate in practice

For the 2027–2031 outlook, the most consequential indicators are documented interruption of recruitment, continuity or replacement of payment intermediaries, cooperation with competent investigators, and credible action against proven violations. A reduced public profile would not demonstrate that the underlying network had ceased operating.

European policy should follow a common evidentiary standard while assigning different tasks to the relevant authorities. The following are proposed workstreams, not assertions that the countries concerned have already adopted these positions.

Actor	Priority workstream	Threshold for stronger action
Italy	Examine any substantiated Italian nationality, corporate or financial connection through competent authorities	Evidence connecting a person or transaction within jurisdiction to prohibited conduct
France	Assess diplomatic safeguards and any substantiated financial, transport or supply-chain connection	Documentary evidence of facilitation or diversion
Germany	Examine substantiated banking, corporate and controlled-technology connections	Identifiable transactions or transfers requiring investigation
United Kingdom	Examine substantiated company, professional-service and financial connections	Evidence supporting action under applicable domestic powers
European Union	Coordinate evidence sharing and assess options through the competent institutions	An adequately supported legal and factual basis for collective measures

WordPress Relationship Component

This component distinguishes the documented corporate functions from the separate institutional question raised by the candidacy. It contains no quantitative scale and makes no claim of a proven connection between Nusseibeh and recruitment activity.

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Pillar I — The Recruitment System and Its Operational Effects

Assessment cut-off: 13 November 2026.

Chapter 1 — From Private Recruitment to Combat Support

The recruitment system’s military significance lies in the functions personnel performed after deployment, the organisations that assigned those functions, and the contractual arrangements connecting recruitment to battlefield employment. Descriptions such as “security services” cannot settle those questions. Equally, the designation “mercenary” requires legal analysis beyond establishing foreign nationality, previous military service or payment. The available official record supports investigation of an organised recruitment and deployment system; individual responsibility must be connected to identifiable conduct and decisions.

Recruitment requirements reveal the intended service

The US Treasury’s December 2025 account identified recruitment campaigns for drone operators, snipers and translators, alongside the deployment of personnel serving as infantry, artillerymen, vehicle operators and instructors. Those requirements reveal a demand for differentiated military skills. They also provide a documentary basis for distinguishing a workforce intended for ordinary premises protection from one assembled to support military operations. Treasury Sanctions Transnational Network Recruiting Colombians to Fight in Sudan’s Civil War — US Department of the Treasury — Dec 2025. U.S. Department of the Treasury

The analytical question is when each participant understood the intended destination and duties. A recruitment intermediary might receive a requirement expressed in military terms while an individual applicant receives a more general employment offer. A contracting company might possess deployment schedules unavailable to a local recruiter. These possibilities require separate examination because knowledge cannot be assumed to pass unchanged through every layer. Investigators need to compare the original client requirement, vacancy descriptions, applicant communications, signed agreements and subsequent instructions. Differences between those records can establish where duties changed, who authorised the change and whether recruits received accurate information.

The April 2026 Treasury action added a more specific allegation about knowledge: it stated that recruiter Jose Oscar Garcia Batte continued recruiting for A4SI after learning that its personnel were being sent to fight for the RSF. That is an official administrative finding concerning a named organiser; it should not be generalised into a finding about every recruiter or recruit. Treasury Sanctions Recruitment Network Enabling War in Sudan, Calls for Humanitarian Truce — US Department of the Treasury — Apr 2026. U.S. Department of the Treasury

Stage of employment	Decisive documentary question	Records needed	Analytical consequence
Initial approach	What work and destination were represented?	Original advertisement, messages and recruitment presentation	Establishes the offer received by the applicant
Selection	Which skills did the commissioning party request?	Job specification, interview criteria and skills assessment	Tests whether military employment was anticipated
Contract signature	Who undertook to employ, pay and supervise the recruit?	Complete agreement, annexes and authorised signatures	Identifies contractual obligations and counterparties
Preparation	Who selected training and equipment?	Course instructions, attendance lists and equipment records	Connects recruitment requirements to preparation
Deployment	Who issued destination and movement instructions?	Travel orders, tickets, manifests and communications	Identifies responsibility for assignment
Employment in Sudan	Who assigned actual tasks and controlled performance?	Rosters, orders, reporting chains and corroborated testimony	Connects corporate arrangements to military conduct

The table identifies investigative requirements; it does not assert that every listed record is publicly available.

Private employment does not determine humanitarian-law status

According to the International Committee of the Red Cross, private military and security personnel’s status depends on their functions and circumstances. Personnel generally remain civilians unless incorporated into state armed forces or performing combat functions for an organised armed group belonging to a conflict party. Operating weapons in combat, collecting tactical military intelligence and defending a military base against an opposing party can constitute direct participation in hostilities. The commercial identity of the employer does not override that functional assessment. International humanitarian law and private military/security companies — FAQ — ICRC — Dec 2013. International Committee of the Red Cross

This distinction changes how a deployment should be investigated. A person paid by a security company may perform ordinary civilian work, participate in a particular military operation, or assume an enduring combat function within an armed group. A single employment label cannot establish which category applies. Investigators therefore need individual assignments and actual activity, rather than nationality-based classifications. The same caution applies to company-level findings: evidence that some employees operated weapons does not establish that every employee did so.

The ICRC’s interpretive guidance distinguishes specific acts of direct participation from a continuous combat function within an organised armed group. It also distinguishes activity integral to a particular military operation from more general support, including equipment maintenance outside specific operations. These are the ICRC’s interpretive positions; they should not be represented as a judicial determination of the status of the personnel discussed here. Interpretive Guidance on the Notion of Direct Participation in Hostilities under International Humanitarian Law — ICRC — 2009.

Function requiring examination	Relevant distinction	Evidence needed for an individual assessment
Ordinary civilian-site protection	Civilian security work versus involvement in hostilities	Site purpose, assignment and actual conduct
Operating a weapon during an attack	Direct involvement in a specific military operation	Operator identity, orders and operational records
Providing tactical targeting information	Information integral to an attack versus general analysis	Content, recipient, timing and operational use
Maintaining equipment	General technical support versus an integral role in a particular operation	Maintenance task, operational context and assignment
Recurring combat employment	Occasional participation versus continuous combat function	Sustained duties, organisational integration and command relationship
Administrative or payroll work	Support for an organisation versus direct participation	Actual activity; employment association alone is insufficient

Legal basis: ICRC Interpretive Guidance — 2009. The categories require case-specific assessment.

“Mercenary” is a narrower legal category than paid foreign fighter

Article 47 of Additional Protocol I defines a mercenary through six cumulative conditions covering recruitment to fight, actual direct participation, motivation and comparatively excessive compensation, nationality or residence, armed-force membership, and official deployment by a non-party state. It addresses combatant and prisoner-of-war entitlement within the Protocol’s international-conflict framework. Its definition cannot automatically determine status throughout Sudan’s conflict merely because foreign personnel receive salaries. Protocol Additional I to the Geneva Conventions, Article 47 — 1977, reproduced by the ICRC.

Article 47 criterion, summarised	Consequential evidence gap
Specifically recruited to fight in an armed conflict	Original recruitment purpose and instructions
Actually takes a direct part in hostilities	Individual conduct
Essentially motivated by private gain and promised substantially higher compensation than comparable fighters	Motivation, promised remuneration and a valid comparator
Neither a national of a conflict party nor resident in territory it controls	Nationality and relevant residence
Not a member of a conflict party’s armed forces	Membership and organisational status
Not officially sent by a non-party state as a member of its armed forces	Official service and deployment status

Source: Additional Protocol I, Article 47 — 1977. These conditions are cumulative.

The practical consequence is that an investigation need not depend exclusively on proving this particular classification. Recruitment-related sanctions, unlawful conduct during hostilities and other applicable offences raise their own questions. A finding that the evidence does not establish every mercenary criterion would leave those questions open. Conversely, describing someone as a mercenary does not establish participation in a particular atrocity.

Child recruitment requires age-specific evidence

Treasury’s December 2025 announcement alleged that some Colombian personnel trained children for the RSF. Establishing responsibility for particular cases requires identification of the trainees, their ages, the training provided and the roles of the individuals involved. The official allegation is consequential, but it is not a substitute for that incident-level evidence. Treasury Sanctions Transnational Network Recruiting Colombians to Fight in Sudan’s Civil War — US Treasury — Dec 2025.

For non-international armed conflict, Article 8(2)(e)(vii) of the Rome Statute addresses conscripting or enlisting children under 15, or using them to participate actively in hostilities. The ICC’s Elements of Crimes additionally requires examination of whether the perpetrator knew or should have known the person’s age, alongside the conflict-related elements. Evidence that a trainee was “a child” therefore needs a more precise age determination for this particular offence; the threshold does not resolve all other protections applicable to children. Rome Statute, Article 8 — United Nations — 1998; Elements of Crimes, Article 8(2)(e)(vii) — International Criminal Court. icc-cpi.int

Key judgments

The decisive distinction is between the service advertised, the service commissioned and the service actually performed. Their comparison can establish deception, knowledge or changes of assignment more reliably than a general description of the workforce.

Private contracts do not independently establish civilian status, combatant status or criminal responsibility. Each requires evidence appropriate to the question being answered.

What would change the assessment

Authenticated commissioning requirements and tasking instructions would clarify whether combat employment was planned from the outset. Corroborated individual assignments would permit stronger conclusions about participation in hostilities and responsibility for specific acts.

Open official record

The consequential missing records are complete employment agreements, recruitment instructions, deployment orders, organisational rosters and age-specific evidence concerning alleged child trainees.

Chapter 2 — Transit Corridors and Technical Dependence

The operational system should be understood as a set of connected facilities and services rather than a single route. Its military effect depends on whether personnel can move between recruitment, preparation, transit and operational employment, and whether technical services continue after arrival. Evidence of a transport connection establishes only part of that chain: it does not independently establish a flight’s passengers, cargo, commissioning party or ultimate purpose.

Libya provided more than geographic passage

The March 2026 Libya Panel of Experts report assessed that the RSF benefited from a rear logistical base approximately 75 kilometres south-south-west of Kufrah, access to Maateen al-Sarrah airbase, and facilities near Kufrah used for Colombian transit and vehicle modification. It described support involving the Libyan Arab Armed Forces and Subul al-Salam. This adds an operational dimension to the corridor: facilities could support preparation and onward movement, rather than simply border crossing. Final report of the Panel of Experts on Libya, S/2026/224, paragraphs 35–38 — UN Security Council — Mar 2026. digitallibrary.un.org

That distinction matters because the responsible actors can differ at each stage. Permission to land, access to a facility, vehicle preparation and onward movement may involve separate organisations. Demonstrating one organisation’s role in a particular service does not establish its control over the entire operation. An effective investigation would connect the facility-level records: arrival and departure dates, personnel lists, equipment movements, payments and communications authorising access.

The same report’s aviation annex recorded the following July 2025 flight movements. They provide dated evidence of connections between Somalia and eastern Libya; they do not identify the contents of each flight. S/2026/224, annex 18, appendix 18.D — UN Panel of Experts on Libya — Mar 2026.

Flight date	Recorded origin	Recorded destination	Recorded status
10 July 2025	Benghazi	Bosaso	Landed
11 July 2025	Benghazi	Bosaso	Landed
12 July 2025	Bosaso	Al-Kufra	Landed
14 July 2025	Bosaso	Benghazi	Landed

Source: UN Panel of Experts on Libya, S/2026/224, annex 18 — Mar 2026. Aircraft movement and payload identification are separate evidentiary questions.

The route evidence supports several deployment sequences

The Sudan fact-finding mission described initial movements through the UAE, Bosaso and Benghazi, followed by desert transit into Darfur. Subsequent groups reportedly travelled through Bosaso or the UAE and Chad before entering through Nyala Airport. Witnesses described approximately two months of training at a military-style facility in Ghayathi. These are reported sequences and testimony-based findings, not a complete itinerary for every contractor. Fuelling Sudan’s conflict: weapons, fighters and external support networks, A/HRC/63/23, paragraph 90 — UN Fact-Finding Mission — Sep 2026.

Multiple reported sequences suggest potential flexibility, but the extent of substitution remains unresolved. A network might possess alternative transit points while still depending on a small number of employers, specialist instructors or payment providers. Geographic breadth therefore cannot be treated as proof of resilience. The relevant test is whether an interrupted function can be replaced at acceptable cost and speed. Publicly documented movements identify places to investigate; they do not establish how quickly the system could recover from losing access to one of them.

Operational stage	What the record supports	What remains unresolved
Preparation in the UAE	Witness accounts of training at Ghayathi	Complete participant lists, authorisations and course records
Bosaso transit	A reported recurring transit role	Passenger identity and purpose for individual movements
Eastern Libya	Panel findings concerning facilities and onward movement	Responsibility for each movement and service
Chad-linked deployment	Reported passage before entry through Nyala	Complete arrival, transit and onward-transfer records
Employment in Sudan	Reported technical and military roles	Strength, assignments and operational availability on particular dates

Sources: A/HRC/63/23, paragraphs 84 and 90–94 — Sep 2026; S/2026/224, paragraphs 35–38 — Mar 2026.

Technical dependence must be measured through service continuity

In its September 2026 Human Rights Council presentation, the fact-finding mission described foreign personnel as integral to RSF drone operations, including operation, maintenance and training. It also identified the supply of equipment, logistical assistance and personnel to Nyala and other RSF-held areas. This supports assessing the deployment as a package of military services rather than an infantry reinforcement alone. HRC 63 — Human Rights in Sudan — UN Geneva Multimedia Newsroom — Sep 2026. 07 September 2026

The resulting dependence has several possible forms. Operators can provide an immediately usable service; instructors can transfer skills; maintenance personnel can preserve equipment availability. These functions have different consequences if external personnel leave. A service dependent on foreign operators would be more exposed to their departure than one successfully transferred to local crews. A training deployment might reduce future dependence, while continuing maintenance requirements could preserve it. These are analytical mechanisms to test, not measured outcomes established for every system deployed in Sudan.

A credible capability assessment therefore needs more than a count of personnel or weapons. It needs evidence of trained crews, serviceable equipment, spare parts, communications, ammunition and authority to employ the systems. The record reviewed does not provide a sufficiently consistent series to calculate sortie generation, equipment availability or the share of RSF operations attributable to Colombian personnel. Assigning such figures would create precision unsupported by the evidence.

Capability function	Potential military effect	Evidence needed to measure the effect	Consequence if the service stops
Weapon operation	Makes equipment usable in combat	Crew assignments and employment records	Effect depends on availability of replacement crews
Technical maintenance	Preserves serviceability	Repair records, parts use and equipment downtime	Availability can fall despite unchanged inventory
Training	Expands the number of qualified personnel	Course completion and demonstrated proficiency	Immediate effect may be limited if skills have transferred
Tactical information support	Connects observation to military decisions	Tasking, reporting and operational use	Can reduce the effectiveness of otherwise available systems
Coordination and translation	Connects foreign specialists with local units	Reporting chains and liaison assignments	Friction can increase even when personnel remain present

Analytical framework derived from the functions described in the UN mission’s September 2026 presentation; the table does not quantify their realised effect.

Recruitment totals cannot establish deployed strength or combat contribution

The fact-finding mission recorded estimates ranging from 350 to 2,000 and assessed that recruitment could approach the upper figure. These estimates are not a time series of personnel simultaneously present or operationally available. A/HRC/63/23, paragraph 85 — UN Fact-Finding Mission — Sep 2026.

The distinction prevents several misleading calculations. Dividing an estimated cumulative recruitment total by a deployment period would not establish monthly arrivals. Multiplying that total by an assumed salary would not establish expenditure. Nor would a presence estimate identify how many people operated drones, served as instructors or remained medically fit for duty. Rotations, departures, deaths, incomplete contracts and delayed deployments would all affect the relationship between recruitment and available strength, but the necessary reconciled records are absent.

Measure	What it would answer	Required denominator or record
Cumulative recruitment	How many people entered the recruitment process or accepted employment?	Defined inclusion criteria and unique identities
Completed deployment	How many reached the assignment location?	Arrival records reconciled with recruitment lists
Strength on a given date	How many remained present?	Arrivals minus departures and other removals
Operational availability	How many could perform assigned duties?	Strength adjusted for readiness and qualification
Technical contribution	Which services supported which operations?	Individual tasking and operational records

Key judgments

The corridor evidence supports a geographically distributed system with identifiable facilities and dated aviation connections. It does not support attributing every flight or movement to the same personnel deployment.

The military importance of specialists should be assessed through the continuity and replaceability of their services. Headcount alone cannot measure that contribution.

What would change the assessment

Reconciled manifests, facility logs and deployment rosters would strengthen route attribution. Evidence of successful transfer of technical duties to RSF personnel would weaken an assessment of enduring dependence on foreign specialists.

Open official record

The central gaps concern passenger and cargo identification, facility access authorisations, personnel rotations, qualification records and system-level operational availability.

Chapter 3 — Money, Corporate Intermediaries and Enforcement

The financial system’s significance lies in the separation of contractual employment, fund receipt, currency conversion and salary payment across several entities. That structure creates distinct investigative responsibilities and potential sanctions exposure. Enforcement effectiveness depends on identifying the legal person and activity behind a transaction, including continuity across name and management changes.

Corporate changes require a dated account of continuity

The April 2026 Treasury action identified Fénix Human Resources S.A.S., opened in February 2025, as a replacement for A4SI. It also identified Global Qowa Al-Basheria S.A.S., known as GQAB or Mi Futuro Global, as an additional recruitment company. The succession date matters: Fénix’s reported creation preceded A4SI’s December 2025 US designation. Chronology therefore does not support describing its creation as a response to that later sanction. Treasury Sanctions Recruitment Network Enabling War in Sudan, Calls for Humanitarian Truce — US Treasury — Apr 2026.

Treasury’s June 2026 action recorded Global Staffing’s rebranding as Talent Bridge in July 2025, when Jack Peter Derman Guzman succeeded Claudia Viviana Oliveros Forero as president. It also identified Enrique Daniel Palacios Quintanilla and Fredy Alejandro Lopez Ocampo among the company’s associates and officeholders. These facts support examination of continuity across names and management; the change alone does not establish why it occurred. Treasury Sanctions Networks Fueling Sudan’s Civil War and Worsening Humanitarian Crisis — US Treasury — Jun 2026. U.S. Department of the Treasury

Entity	Jurisdiction identified in the official account	Function or continuity issue	Source
A4SI	Colombia	Original recruitment node	US Treasury — Dec 2025
Fénix Human Resources	Colombia	Identified as A4SI’s replacement; opened February 2025	US Treasury — Apr 2026
GQAB / Mi Futuro Global	Colombia	Additional recruitment intermediary	US Treasury — Apr 2026
Global Staffing / Talent Bridge	Panama	Contracting intermediary; July 2025 rebranding	US Treasury — Jun 2026
Maine Global Corp	Colombia	Fund administration, payroll and currency conversion	EU Regulation 2026/1051 — May 2026

The investigative task is to identify which changes were merely nominal and which transferred actual responsibility. Relevant comparisons include registration numbers, bank accounts, authorised signatories, ownership, contractual liabilities and operational communications. Shared personnel can indicate continuity, but a common individual’s involvement does not make every associated company the same legal entity. Both errors matter: treating a renamed company as unrelated can miss continuity; treating separate companies as interchangeable can misattribute transactions.

Payment processing connects employment to a wider financial footprint

The EU’s May 2026 implementing regulation identifies Mateo Andres Duque Botero as managing Maine Global Corp and describes its role in disbursing funds, processing payroll and converting euros and Colombian pesos into US dollars. It records transfers totalling millions of US dollars during 2024–2025 involving associated US-based firms and relevant companies. The instrument provides no precise total from which to calculate the operation’s budget. Council Implementing Regulation (EU) 2026/1051 — Council of the European Union — May 2026. eur-lex.europa.eu

Financial reconstruction must distinguish promised compensation, amounts invoiced, funds transferred and wages received. These measures answer different questions. An invoice can include recruitment or transport charges as well as labour costs. A transfer can settle more than one obligation. A payroll instruction does not establish that the beneficiary received the full amount. Currency conversion introduces another reconciliation requirement: the original amount, conversion date, rate and fees are needed before values in different currencies can be compared.

Financial record	What it can establish	What it cannot establish alone
Employment agreement	Promised wage and contractual payer	Actual payment
Client invoice	Amount billed and service description	Performance of the service or ultimate beneficiary
Bank transfer	Movement between identified accounts	Full commercial purpose without supporting records
Foreign-exchange record	Currency conversion, date and rate	Whether the underlying service was lawful
Payroll instruction	Intended employee payment	Final receipt and deductions
Beneficiary statement	Amount received by the individual	Identity of the ultimate commissioning party
Corporate distribution	Transfer to an owner or related company	Whether the funds originated from a particular deployment

This table describes the reconciliation needed to investigate the payment functions recorded in EU Regulation 2026/1051 — May 2026.

Enforcement moved across distinct legal systems

Quijano’s UN listing is dated 28 April 2026. The EU subsequently adopted Implementing Regulation 2026/1051 on 7 May 2026, adding Quijano, Oliveros and Duque to the relevant annex. These developments extend the enforcement baseline beyond the US measures discussed in the opening assessment. They remain sanctions actions and must not be described as criminal convictions. Alvaro Andres Quijano Becerra — UN Security Council Sanctions Committee — Apr 2026; Council Implementing Regulation (EU) 2026/1051 — May 2026.

Date	Authority	Action relevant to this network	Interpretation
9 December 2025	US Treasury / OFAC	Four individuals and four entities designated	Initial US action against the identified recruitment and payment network
17 April 2026	US Treasury / OFAC	Five individuals and entities designated	Extended coverage of recruitment relationships
28 April 2026	UN sanctions regime	Relevant organisers listed	Separate international listing process
7 May 2026	Council of the EU	Regulation 2026/1051 adopted	EU implementation concerning three named organisers
26 June 2026	US Treasury / OFAC	Further Talent Bridge associates designated within a broader action	Extended scrutiny of corporate officeholders

Sources: US Treasury — Dec 2025; US Treasury — Apr 2026; UN listing — Apr 2026; EU implementing regulation — May 2026; US Treasury — Jun 2026. Counts concern separate actions and should not be added to produce a unique-person total.

The sequence does not demonstrate that recruitment ceased. It demonstrates expanding formal attention to different parts of the system. Measuring effect requires evidence of interrupted transactions, reduced recruitment, terminated services or unsuccessful replacement arrangements. Counting designations alone measures enforcement activity rather than operational impact.

Ownership and control create different sanctions questions

OFAC’s 50 Percent Rule treats entities owned, directly or indirectly, 50 percent or more in aggregate by blocked persons as blocked. Its guidance requires examination of ownership through intermediate companies. A name-only screening process therefore cannot establish whether an unlisted company falls within the rule. FAQ 401 — Office of Foreign Assets Control — current guidance retrieved Nov 2026.

OFAC separately explains that control without the requisite ownership does not automatically trigger that rule, although an entity may be designated under available criteria. Thus, “linked to,” “managed by,” “controlled by” and “owned by” cannot be used interchangeably when describing automatic blocking. FAQ 398 — Office of Foreign Assets Control — current guidance retrieved Nov 2026. Office of Foreign Assets Control

Relationship	Automatic result under OFAC’s 50 Percent Rule	Required assessment
Aggregate blocked ownership of at least 50 percent	Entity is treated as blocked	Verify direct and indirect ownership
Control without the ownership threshold	No automatic blocking solely under this rule	Check separate designation and transaction restrictions
Shared director or manager	No automatic result from the association alone	Identify the person’s role and relevant dealings
Commercial relationship	No automatic ownership inference	Assess the parties, services and applicable prohibitions
Renaming of the same legal person	Name change does not establish a new legal identity	Match registration and historical identifiers

Legal distinctions: OFAC FAQ 401 and OFAC FAQ 398.

The US Treasury’s June announcement also explains that US persons and transactions within or transiting the United States are generally subject to the stated prohibitions involving blocked property, unless authorised or exempt. Foreign participation therefore requires transaction-specific analysis; foreign incorporation alone does not determine exposure, and the announcement should not be read as imposing a universal prohibition on every foreign transaction. Treasury Sanctions Networks Fueling Sudan’s Civil War and Worsening Humanitarian Crisis, sanctions implications — US Treasury — Jun 2026.

Enforcement effectiveness depends on connecting jurisdictions

The network’s division of functions creates a cooperation problem. Recruitment evidence can identify who entered employment, corporate records can establish authority to sign, and payment records can show how services were financed. Each becomes more useful when reconciled with the others. A complete financial account would connect the original commissioning obligation to intermediate transfers and final beneficiaries, while preserving the distinction between a commercial service and the military activity it supported.

That reconstruction also provides a basis for proportionate action. An authority may possess enough evidence to examine a transaction or preserve records before it possesses enough evidence to establish criminal responsibility. The appropriate threshold depends on the measure and legal system. The practical requirement is to specify the conduct, actor and jurisdiction rather than treat every institution touching the payment chain as equally responsible.

Key judgments

The additional official record identifies corporate succession, a rebranding date, supplementary recruitment relationships and payment functions that merit investigation as a connected system.

The published financial evidence establishes scale only in broad terms. It does not support a precise operating budget, average salary, profit margin or funding allocation by sponsor.

Sanctions designations create legal consequences, but their effectiveness must be assessed through changes in recruitment, service delivery and financial access.

What would change the assessment

Authenticated bank records connecting the ultimate payer to deployment-specific invoices would materially strengthen attribution. Evidence that replacement companies preserved the same contracts and payment instructions would strengthen a finding of operational continuity. Verified cessation of those services would weaken an assessment that the system remained functional.

Open official record

The decisive outstanding records are dated ownership histories, company identifiers across name changes, complete contracting chains, transaction-level payment records, foreign-exchange reconciliations and evidence of actual enforcement outcomes.

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Pillar II — Responsibility, Attribution and International Governance

Assessment cut-off: 13 November 2026.

Chapter 4 — The UAE Connection: Official Allegations, Emirati Responses and State Responsibility

The principal unresolved question is which conduct can be attributed to Emirati public authorities, under which legal rule, and with what consequences. Corporate connections, access to government-controlled facilities and official knowledge can each have evidentiary significance, but they establish different propositions. A defensible assessment must distinguish responsibility for authorising or facilitating a deployment from responsibility for subsequent battlefield operations and from a failure to take legally required preventive measures.

The official dispute concerns the meaning and provenance of evidence

Sudan’s September 2025 Security Council submission accused the UAE of involvement in foreign recruitment and identified GSSG within that alleged system. The UAE’s October response disputed both the allegations and the reliability of the supporting material, arguing that corporate-registration documents did not establish mercenary activity and that travel documents were incomplete or unverifiable. Abu Dhabi also stated that its authorities had investigated GSSG and found no relevant connection. These submissions establish the parties’ positions; their circulation as Security Council documents does not constitute Council endorsement of either account. Letter dated 5 September 2025, S/2025/555 — Permanent Representative of Sudan — Sep 2025; Letter dated 22 October 2025, S/2025/666 — Permanent Representative of the UAE — Oct 2025.

The dispute therefore cannot be resolved by counting allegations and denials. The substantive task is to examine whether the challenged records can be authenticated, whether independent records corroborate them, and whether the UAE’s investigation addressed the same transactions, persons and deployment periods. A finding concerning a company’s registration would answer a different question from an investigation into its contracts or personnel movements. Similarly, a finding that a document does not prove government direction would leave open whether it establishes a narrower corporate relationship.

Contested proposition	Evidence capable of supporting it	Evidence that would materially weaken it	Remaining attribution question
A company participated in deployment arrangements	Authenticated contracts, instructions and reconciled personnel records	Reliable evidence that records concern another entity or unrelated work	Who authorised the company’s conduct?
Public facilities supported the operation	Access logs, responsible officials’ instructions and service records	Verified misidentification of the facility or activity	Was assistance official, unauthorised or otherwise explained?
Authorities knew the deployment’s purpose	Dated communications identifying destination and duties	Evidence that information was concealed or materially inaccurate	Which authority knew, and when?
Public resources facilitated deployment	Authenticated expenditure, transport or equipment records	Credible records showing unrelated commercial provision	What conduct and obligation are implicated?
Officials directed subsequent operations	Specific operational instructions and corroborated command evidence	Evidence of autonomous decisions inconsistent with alleged tasking	Which operation or act was directed?
Authorities failed to prevent prohibited activity	A relevant duty, notice, available measures and evidence of inaction	Timely, credible preventive or enforcement action	What measures were reasonably available?

This is an evidentiary assessment framework, not a finding that the listed records have all been obtained.

Attribution requires a connection to the conduct under examination

The International Law Commission’s 2001 articles distinguish conduct of state organs, entities exercising legally delegated governmental authority, and private persons acting on state instructions or under state direction or control. Article 7 addresses conduct performed in an official capacity even when authority is exceeded. These articles are not themselves a comprehensive treaty; their provisions and commentary provide a central framework whose customary status and application must be assessed rule by rule. Draft articles on Responsibility of States for Internationally Wrongful Acts, articles 4–8 and commentaries — International Law Commission — 2001.

Applied to the allegations, this means that a senior official’s relationship with a company raises an investigative question without independently answering it. The relevant inquiry concerns the capacity in which that person acted, the decision taken and its connection to the disputed conduct. A private commercial interest, an official authorisation and an operational order would require different documentary treatment. An official title cannot substitute for evidence that a particular decision was made through public authority.

A licence also needs careful interpretation. Authorisation to provide private security services does not, by itself, demonstrate delegation of governmental powers or permission to recruit personnel for a foreign war. The decisive documents would be the applicable legal authorisation, its scope, and evidence of the company acting under that authority in the particular instance.

Record or relationship	Evidentiary value	Additional inquiry required
Corporate registration	Establishes legal identity and recorded particulars	Whether the entity undertook the disputed activity
Historical ownership	Identifies an economic relationship at a particular date	Whether the owner authorised or knew of relevant conduct
Official position held by an associate	Identifies potential access or public authority	Whether that authority was exercised in the operation
Security licence	Establishes authorised commercial activity within its terms	Whether deployment fell within, exceeded or departed from that scope
Access to a restricted facility	Can corroborate an institutional connection	Who approved access and understood its purpose
Official operational instruction	Can directly connect authority to specified conduct	Authenticity, scope, implementation and resulting acts

The distinctions follow the attribution questions addressed in the ILC’s articles and commentaries, particularly articles 4–8 — 2001.

Support, operational control and prevention must be investigated separately

The UN fact-finding mission’s September 2026 assessment identified a significant role for individuals and entities operating from, registered in or linked to the UAE. It recommended stronger measures to prevent, investigate and halt relevant activities. Its formulation concerning networks should be preserved: it does not eliminate the need to establish the legal connection between particular conduct and the state. Fuelling Sudan’s conflict: weapons, fighters and external support networks, A/HRC/63/23, paragraphs 125–126 — Independent International Fact-Finding Mission for the Sudan — Sep 2026.

The practical implication is that investigators should construct separate accounts of authorisation, assistance, knowledge and battlefield direction. Evidence that an authority facilitated departure could be highly consequential while remaining insufficient to attribute every subsequent operation to that authority. Conversely, failure to establish control over an attack would not resolve a separate question concerning unlawful assistance or prevention.

Article 16 of the ILC articles specifically addresses one state assisting another state in an internationally wrongful act. It cannot simply be transferred, without further analysis, to assistance allegedly provided to the non-state RSF. The applicable substantive prohibition and the status of the actors must be identified. Draft articles on State Responsibility, article 16 and commentary — ILC — 2001.

The distinction between attribution and prevention also has judicial significance. In the Bosnia genocide case, the ICJ did not attribute the Srebrenica genocide to Serbia but nevertheless found a breach of the obligation to prevent it. The Court treated prevention as an obligation to use reasonably available means, assessed against the state’s capacity and circumstances. This precedent supplies a legal distinction, not a factual analogy establishing Emirati responsibility. Summary of the Judgment of 26 February 2007, case 164, particularly the discussion of paragraphs 428–438 — United Nations, Summaries of ICJ Decisions 2003–2007. legal.un.org

The chronology of official notice is consequential

The mission recorded UAE responses on 24 February and 19 June 2026, alongside meetings on 26 February and 19 June. It also recorded Colombia’s cooperation and expressly distinguished private recruitment activity from Colombian state direction. This demonstrates why the existence of a territorial or nationality connection cannot automatically decide state responsibility. A/HRC/63/23, paragraphs 118–126 — UN Fact-Finding Mission — Sep 2026.

Notice matters because it establishes when an authority received sufficiently specific information to examine. It does not automatically prove the allegations notified. The subsequent question is what the authority did with that information: whether it identified relevant companies, preserved records, interviewed decision-makers, examined transactions and addressed contradictory evidence. An investigation should be evaluated through those steps and its findings, rather than through the fact that an investigation was announced.

Official engagement	Date	What the record establishes	What it does not independently establish
Sudanese Security Council submission	5 September 2025	Formal notification of allegations	Their factual correctness
UAE written response	22 October 2025	Denial and stated investigative conclusion	Completeness of the underlying investigation
UAE response to the fact-finding mission	24 February 2026	Engagement with the inquiry	Acceptance of its allegations
Meeting with the mission	26 February 2026	An opportunity to address questions	Resolution of disputed evidence
Further UAE response and meeting	19 June 2026	Continued formal exchange	Public availability of all supporting records

Sources: S/2025/555 — Sep 2025; S/2025/666 — Oct 2025; A/HRC/63/23, paragraph 121 — Sep 2026.

Key judgments

The evidence supports a focused inquiry into the relationship between private activity and public authority. Stronger conclusions about state responsibility require identification of the relevant conduct, the applicable obligation and the legal basis for attribution.

The most consequential distinctions concern official authorisation, knowing assistance, operational direction and prevention. They should remain separate throughout diplomatic and legal assessment.

What would change the assessment

Authenticated official instructions, authorisations identifying the deployment’s purpose, or records connecting public expenditure to specified conduct would strengthen attribution. A substantiated investigation that reconciled the disputed evidence would materially affect the assessment in either direction.

Open official record

The decisive gaps concern the scope and findings of Emirati investigations, relevant authorisations, records of official knowledge and evidence connecting public decision-makers to particular acts.

Chapter 5 — Sudan, International Law and Accountability

Accountability depends on matching each allegation to a competent institution, an available jurisdictional basis and the required standard of proof. An investigative finding can justify further action without establishing criminal guilt. A jurisdictional dismissal can close a particular proceeding while leaving substantive allegations unresolved. Outsourcing military functions creates additional evidentiary layers, but responsibility remains assessable through identifiable decisions and conduct.

The ICJ decision closed a jurisdictional route

The ICJ’s 5 May 2025 order rejected Sudan’s provisional-measures request by 14 votes to two and removed the case from the General List by nine votes to seven. Paragraphs 33–35 explain the jurisdictional consequences of the UAE’s reservation to Article IX of the Genocide Convention. Paragraph 36 distinguishes acceptance of the Court’s jurisdiction from compliance with substantive international obligations. Application of the Genocide Convention in Sudan, Sudan v. United Arab Emirates, Order of 5 May 2025, paragraphs 33–37 — International Court of Justice — May 2025. api.icj-cij.org

The division in the voting should be reported with its subject. It concerned the Court’s procedural dispositions; it cannot be converted into a numerical measure of judges’ views on the truth of the underlying allegations. The operative consequence was the termination of that case on jurisdictional grounds. Any assessment of another accountability route must begin with that institution’s own legal basis rather than assume that the same jurisdictional obstacle applies everywhere.

ICJ disposition	Vote	Immediate consequence	Interpretation to avoid
Rejection of provisional measures	14–2	Requested measures were not indicated	Treating the vote as a merits finding
Removal from the General List	9–7	The case was closed	Treating closure as factual exoneration or proof of guilt
Reasoning on jurisdiction	UAE reservation and absence of another basis	Court could not adjudicate the application	Assuming that every other forum lacks jurisdiction

Source: ICJ Order, paragraphs 33–37 — May 2025.

Darfur’s ICC referral has a distinct geographic and temporal scope

Security Council Resolution 1593, adopted on 31 March 2005, referred the situation in Darfur since 1 July 2002 to the ICC Prosecutor. Its cooperation provisions distinguish the obligations imposed on Sudan and parties to the Darfur conflict from the resolution’s call for wider cooperation. The referral does not, by its wording alone, establish a blanket territorial referral covering every crime anywhere in Sudan. Security Council Resolution 1593, paragraphs 1–2 — United Nations — Mar 2005.

For investigations involving cross-border services, the relevant question is how the alleged conduct connects to crimes within the Court’s jurisdiction and to a recognised mode of individual responsibility. An overseas location does not itself resolve that inquiry. Nor does a Darfur-related investigation establish that every associated transaction constitutes an international crime. Jurisdiction, criminal contribution and the required mental element each need separate examination.

Accountability route	Principal subject	Core jurisdictional question	Potential result
ICJ contentious proceedings	State responsibility	Has the state consented to the Court’s jurisdiction for the dispute?	Binding determination within the Court’s competence
ICC proceedings	Individual criminal responsibility	Does the alleged crime and accused conduct fall within the Court’s jurisdiction?	Judicial decisions concerning individuals
Domestic criminal proceedings	Offences under applicable national law	Does the jurisdiction possess a territorial, nationality or other lawful basis?	Investigation, prosecution and available penalties
UN sanctions process	Conduct meeting designation criteria	Does the evidence satisfy the applicable listing framework?	Restrictive measures
Human-rights fact-finding	Violations, patterns and responsibility within a mandate	What does the mechanism have authority to investigate?	Findings and recommendations

Institutional distinctions: ICJ Order — May 2025; Resolution 1593 — Mar 2005; Resolution 1591 — Mar 2005. Domestic jurisdiction must be established under the relevant national law.

Investigative and judicial findings have different thresholds

The Sudan fact-finding mission applies a reasonable grounds to believe standard. It also reported constraints affecting documentation, including intimidation and limited connectivity. Those limitations require scrutiny of corroboration and provenance; they do not justify discarding testimony merely because investigators faced access restrictions. A/HRC/63/23, paragraphs 3–9 — UN Fact-Finding Mission — Sep 2026.

ICC proceedings distinguish reasonable grounds at the arrest-warrant stage, substantial grounds at confirmation of charges, and proof beyond reasonable doubt for conviction. These standards belong to different procedural decisions. A finding at one stage cannot be presented as satisfying a later one. Rome Statute, articles 58, 61 and 66 — International Criminal Court.

Decision or finding	Applicable formulation	What it establishes
Sudan fact-finding assessment	Reasonable grounds to believe	An investigative conclusion under the mission’s methodology
ICC arrest warrant	Reasonable grounds to believe, with additional statutory requirements	A basis for the specified pre-trial measure
ICC confirmation of charges	Substantial grounds to believe	Sufficient basis to commit confirmed charges to trial
ICC conviction	Beyond reasonable doubt	Criminal guilt established at trial

Sources: A/HRC/63/23, paragraph 3 — Sep 2026; Rome Statute, articles 58, 61 and 66.

The shared use of similar language does not make the mission’s findings equivalent to an ICC warrant. The deciding institutions, evidentiary procedures and legal consequences differ. Governments should preserve that distinction when announcing action: supporting an investigation, making a sanctions designation and alleging criminal guilt require different formulations and justifications.

Outsourcing requires reconstruction of decisions and effective authority

The Rome Statute distinguishes individual participation under Article 25 from responsibility of commanders and other superiors under Article 28. The latter requires examination of effective authority or control, the applicable knowledge standard and failures to take required measures; commercial seniority alone cannot establish it. Rome Statute, articles 25 and 28 — ICC.

For the alleged deployment system, investigators would need to reconstruct who could assign personnel, change duties, receive reports, interrupt services and respond to misconduct. A director who signed an employment agreement and an officer who exercised battlefield authority may occupy different positions in that account. Responsibility must follow demonstrated actions and authority rather than the apparent prominence of a name.

Investigative question	Relevant records	Why it matters
Who assigned the disputed task?	Orders, tasking messages and acknowledged instructions	Identifies the decision and its author
Who received reports of misconduct?	Reports, complaints and distribution records	Establishes the information available
Who could change or stop the activity?	Delegations, reporting structures and actual interventions	Tests effective authority
What happened after a warning?	Suspension orders, inquiries and follow-up communications	Tests the response
Did the service contribute to an identified crime?	Incident evidence reconciled with personnel and service records	Connects support to the alleged offence
Was relevant evidence preserved?	Original files, custody logs and access histories	Supports authenticity and later judicial use

These are proposed investigative applications of the responsibility questions in Rome Statute articles 25 and 28, not findings against named individuals.

Preservation can proceed before a final attribution judgment

The immediate policy priority is to prevent evidence from becoming unavailable while jurisdictional and responsibility questions are examined. Where domestic law permits, competent authorities can seek preservation of corporate, banking and travel records relevant to a defined investigation. Such steps should specify the persons, transactions and periods concerned, protect confidential material and preserve exculpatory evidence alongside incriminating material.

This approach also reduces the risk that publicity becomes a substitute for proceedings. Public attribution may generate pressure, but a durable case requires original records, reliable testimony and an opportunity to challenge the evidence. Institutional cooperation should therefore focus on usable evidence packages and lawful transfer arrangements, including witness consent and protection, rather than merely exchanging published reports.

Key judgments

The ICJ’s jurisdictional decision and Darfur’s ICC referral concern different institutions and legal questions. Neither should be used to make claims about the other’s competence without further analysis.

The strongest accountability strategy connects incidents to individual decisions and authority while preserving evidence that can support, qualify or contradict the allegations.

What would change the assessment

Judicial decisions identifying relevant suspects, authenticated evidence connecting external services to particular crimes, or substantiated national proceedings would materially change the accountability picture.

Open official record

The principal gaps concern incident-specific evidence, effective authority, knowledge of violations, preservation of original records and the jurisdictional basis for proceedings against particular persons.

Chapter 6 — The Secretary-General Candidacy: Appointment Rules, Independence and Safeguards

Nusseibeh’s candidacy creates a legitimate governance question because the office carries administrative authority within an organisation examining allegations involving her nominating state. That question should be assessed through the office’s actual powers, the candidate’s commitments and verifiable safeguards. The records examined do not establish her personal participation in the recruitment system or a plan to use the candidacy to obstruct investigations.

National nomination and international appointment are separate stages

The UAE’s official announcement records a presidential nomination submitted on 21 October 2026. Under Article 97 of the Charter, appointment requires the General Assembly to act on the Security Council’s recommendation. The Council’s Article 27 voting framework requires nine affirmative votes for non-procedural decisions, with the permanent-member provisions separately applicable. National sponsorship therefore begins a process whose decisive institutional stages lie elsewhere. UAE formally nominates Lana Nusseibeh for United Nations Secretary-General — Emirates News Agency — Oct 2026; UN Charter, Article 97; UN Charter, Article 27.

Stage	Responsible actor	Institutional significance
Nomination	Sponsoring member state or states	Presents the candidate
Candidate disclosures and dialogue	Candidate and relevant UN process	Enables public and member-state scrutiny
Recommendation	Security Council	Required constitutional step
Appointment	General Assembly	Confers the office
Exercise of office	Secretary-general under the Charter	International responsibilities replace representation of a national government

Sources: UN Charter, Article 97; General Assembly Resolution 79/327, paragraph 42 — Sep 2025.

The distinction also affects the proper standard of political evaluation. Member states can assess suitability, independence and public confidence without making a criminal accusation. Those assessments should nevertheless identify their grounds. Nationality alone is an inadequate substitute for examining a candidate’s conduct and proposals; diplomatic experience alone is an inadequate substitute for demonstrating how conflicts would be managed.

Campaign disclosures provide a concrete basis for scrutiny

Resolution 79/327, adopted on 5 September 2025, states that candidates should disclose funding sources at nomination and provide vision statements. It provides for webcast dialogues and a public candidate list including campaign-financing disclosures. Its separate provision that candidates holding UN-system positions should consider suspending their work concerns those UN roles; it should not be misrepresented as an automatic rule governing every national ministerial position. Revitalization of the work of the General Assembly, A/RES/79/327, paragraph 42(g)–(j) — UN General Assembly — Sep 2025. un.org

Nusseibeh’s campaign website states that she took leave from her UAE government responsibilities and presents commitments to multilateral reform and accountability. Those statements are relevant candidate positions, not independent evidence that all possible conflicts have been resolved. The appropriate examination concerns the practical scope of the leave, campaign support and the arrangements proposed for exercising international responsibilities. Lana Nusseibeh announces candidacy for United Nations Secretary-General — Candidate’s official campaign website — Oct 2026.

Disclosure or commitment	Question for substantive scrutiny	Evidentiary limit
Funding-source disclosure	Which public or private sources support the campaign?	Naming a source does not establish expenditure or conditions
Support provided in kind	Who supplies staff, travel or professional services?	Its treatment must be checked against the disclosure framework
Leave from national responsibilities	Which duties, resources and reporting relationships are suspended?	A public announcement does not specify every arrangement
Independence commitment	What procedure would apply to a matter involving the nominating state?	A general pledge requires operational detail
Accountability programme	How would staffing and resources protect mandated work?	A vision statement is an intention, not implementation

Resolution-based disclosure provisions: A/RES/79/327, paragraph 42. Candidate position: official candidacy announcement — Oct 2026. The questions above are proposed scrutiny criteria.

The secretary-general does not control every accountability mechanism

The institutional architecture limits any claim that winning the office would confer authority to terminate all relevant investigations. The Human Rights Council is a subsidiary organ of the General Assembly. The Sudan sanctions panel operates within a Security Council mandate. The ICC Prosecutor is an independent organ of a separate court and may not act on external instructions. These are distinct sources of authority. Human Rights Council, A/RES/60/251, paragraph 1 — UN General Assembly — Mar 2006; Work and mandate — Sudan Panel of Experts — UN Security Council; Rome Statute, Article 42 — ICC.

Administrative authority remains consequential. Article 101 gives the secretary-general responsibility for staff appointments under General Assembly regulations and specifies efficiency, competence and integrity as paramount considerations. Staffing decisions and administrative support can therefore warrant scrutiny even where the substantive investigative mandate belongs to another body. This identifies a governance exposure; it does not establish that interference has occurred. UN Charter, Article 101.

Institution or function	Source of authority	Limit relevant to the candidacy
Human Rights Council	General Assembly establishment and member-state decisions	Its authority is not derived solely from the secretary-general
Human-rights fact-finding mechanism	Its establishing and subsequent mandate	Substantive mandate must be distinguished from administrative support
Sudan sanctions panel	Security Council resolutions and committee framework	Reporting and mandate questions require attention to Council authority
ICC Prosecutor	Rome Statute	Secretary-general has no prosecutorial command authority
Secretariat staffing	Charter and applicable regulations	Administrative decisions remain subject to international duties and oversight

Sources: A/RES/60/251; Sudan Panel mandate; Rome Statute, Article 42; Charter, Article 101.

Independence requires duties on both sides of the relationship

Article 100 prohibits the secretary-general and staff from seeking or receiving governmental instructions and requires member states to respect the international character of their responsibilities. Safeguards should consequently address both the officeholder’s decisions and attempts by governments to influence them. UN Charter, Article 100.

The most useful commitments would explain how a potential conflict becomes visible, who reviews it and how decisions remain traceable. A broad promise of impartiality gives less assurance than a defined process for handling sensitive administrative decisions. Conversely, an excessively broad withdrawal from all Sudan-related functions could impair the office’s ability to conduct legitimate diplomacy. The objective should be to protect particular decisions and evidence without disabling mandated responsibilities.

Proposed safeguard	Purpose	Observable evidence	Implementation limitation
Written conflict-assessment procedure	Identifies matters requiring additional review	Recorded assessments and reasons	Must protect legitimately confidential information
Documented delegation where appropriate	Reduces personal involvement in a specified decision	Defined scope, delegate and duration	Delegation cannot erase institutional accountability
Independent review of sensitive staffing changes	Protects expertise and continuity	Recorded selection and review process	Must remain consistent with applicable rules
Evidence-access controls	Protects originals and confidential sources	Access logs and documented transfer decisions	Security cannot become a pretext for blocking authorised investigators
Reasons for material administrative changes	Makes decisions assessable	Written explanation and competent review	Some operational details require restricted handling
Clear reporting of external pressure	Makes attempted interference visible	Protected reporting and follow-up	Requires credible protection against retaliation

These are proposed governance measures grounded in the independence and staffing duties in Charter Article 100 and Article 101. They are not presented as safeguards already adopted by the candidate or UN.

Member states must distinguish oversight from instructions to investigators

Member-state scrutiny should concentrate on whether mandates can be carried out, records preserved and findings assessed on their merits. Pressuring investigators to reach a predetermined conclusion would undermine the same independence that scrutiny is intended to protect. A credible process should permit evidence to strengthen allegations, narrow them or establish that particular claims are unsupported.

The EU’s September 2026 statement supported the fact-finding mission’s accountability work and called for compliance with humanitarian and human-rights obligations. That establishes a collective diplomatic position; it does not establish how individual European governments will assess Nusseibeh’s candidacy or vote in the relevant bodies. HRC63 — EU Statement on the Fact-Finding Mission report on Sudan — European External Action Service — Sep 2026.

Decision point	Evidence relevant to confidence	Development warranting stronger scrutiny
Candidate evaluation	Specific answers on independence and conflicts	Evasion of defined procedural questions
Campaign scrutiny	Disclosures that explain identified support	Material inconsistencies requiring clarification
Senior appointments	Demonstrated competence and reasoned procedures	Unexplained changes affecting sensitive work
Administrative support	Continuity sufficient to perform mandates	Selective restrictions without substantiated justification
Treatment of findings	Consistent evidentiary standards	Pressure to alter conclusions for political reasons

Analytical indicators, rather than allegations that these adverse developments have occurred.

Key judgments

Nusseibeh’s nomination warrants substantive examination of independence arrangements. It does not establish personal responsibility for the recruitment system, and the office would not confer command over every institution examining Sudan.

The strongest safeguards address specific administrative decisions, evidence handling and external pressure. They should be applicable to any secretary-general facing a comparable conflict, rather than constructed around nationality.

What would change the assessment

Detailed candidate commitments, substantiated information about campaign support, or documented attempts to influence mandated work would materially affect the governance assessment. Verified compliance with transparent procedures would provide evidence in the opposite direction.

Open official record

The consequential records are the candidate’s complete financing disclosure, detailed conflict-management commitments, the scope of her stated leave from national duties and any documented administrative decisions affecting relevant accountability mechanisms.

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Pillar III — External Leverage and the 2027–2031 Outlook

Assessment cut-off: 13 November 2026. Forward-looking judgments are conditional assessments, not predictions supported by numerical probabilities.

Chapter 7 — European and International Choices

European leverage depends on combining distinct national responsibilities with coordinated diplomatic demands. Italy, France and Germany operate within common EU restrictions but retain national implementation and investigative functions. The United Kingdom possesses a separate sanctions framework and an established diplomatic role on Sudan. Their effectiveness should be assessed through interrupted prohibited services, usable evidence, protected humanitarian access and sustained investigative capacity. Public statements and financial commitments establish policy intent; their operational consequences require separate measurement.

The immediate institutional calendar is shorter than the five-year outlook

Two recent decisions establish different deadlines. Security Council Resolution 2830, adopted on 8 October 2026, renewed the relevant UN sanctions measures until 11 December 2026 and extended the Panel of Experts’ mandate until 11 January 2027. Separately, the EU extended its autonomous Sudan sanctions framework until 10 October 2027. These are distinct instruments: continuation of one cannot be assumed to preserve every function of the other. Resolution 2830 — UN Security Council — Oct 2026; Council Decision (CFSP) 2026/2261 — Council of the European Union — Oct 2026. Security Council

The practical implication is that governments must address institutional continuity before evaluating the longer-term effectiveness of pressure. Restrictive measures require a continuing legal basis; investigations require a mandate, personnel and access to records. Renewal of a framework does not establish that enforcement is effective, but uncertainty over renewal can complicate planning and cooperation. Conversely, an EU extension cannot independently preserve a UN expert mechanism whose authority derives from the Security Council.

Instrument or mechanism	Verified deadline	Time remaining from 13 November 2026	Decision significance
UN sanctions measures renewed by Resolution 2830	11 December 2026	28 days	Near-term Council decision on continuation
Sudan Panel of Experts mandate	11 January 2027	59 days	Continuity of mandated monitoring and investigation
EU autonomous framework under Decision 2023/2135, as amended	10 October 2027	331 days	Longer EU policy horizon, subject to applicable review and amendment

Calendar intervals calculated from the assessment cut-off. Sources: UN Resolution 2830 — Oct 2026; EU Decision 2026/2261 — Oct 2026. The dates are legal deadlines, not forecasts of termination.

Italy: connect humanitarian engagement with examination of a domestic nexus

Italy’s documented engagement provides an operational starting point. The Foreign Ministry’s April 2026 account of Italy for Sudan records €5 million offered to the FAO and €1 million to the Red Cross federation in March. It also distinguishes assistance already transported from supplies planned for subsequent delivery. Those statements demonstrate specific commitments and activities; they do not establish Italy’s complete national expenditure or the final delivery of every planned intervention. Italy for Sudan. L’impegno umanitario dell’Italia — Ministry of Foreign Affairs and International Cooperation — updated Apr 2026.

The country-specific enforcement question concerns any substantiated Italian connection to the conduct under examination. The EU listing records an Italian nationality connection for Quijano. Its relevance is to the examination of applicable jurisdiction and obligations, rather than an automatic conclusion that an Italian offence has occurred. Competent authorities would need to establish the relevant acts, dates, nationality circumstances and statutory basis before drawing conclusions. Council Implementing Regulation (EU) 2026/1051, annex — Council of the European Union — May 2026.

Italy’s most useful policy contribution would therefore combine continued humanitarian delivery with a defined assessment of any domestic investigative nexus and any relevant export or service relationship. This approach gives practical meaning to diplomatic demands without making aid conditional on the outcome of a politically contested attribution dispute. It also creates an auditable distinction between Italy’s humanitarian commitments and its obligations to examine conduct within its jurisdiction.

France: test industrial-diversion allegations through traceable records

France has combined conference diplomacy with humanitarian and development support. In a government answer published on 2 June 2026, the Foreign Ministry stated that the Berlin announcement brought French support since the conflict began to €275 million. The same answer addressed allegations concerning French equipment, stating that consultations, including with manufacturer Étienne Lacroix, had not established the reported presence. Both propositions require attribution to the government: the first is an official account of support; the second is its stated investigative conclusion. Written question 10906, government response — French National Assembly — Jun 2026.

For France, the consequential choice is whether allegations of diversion can be translated into a reproducible examination of product identity, serial or batch information, export authorisations, end-user undertakings and onward-transfer records. Consultation with a manufacturer can resolve technical identification questions, but the strength of the resulting conclusion depends on the records examined and the specificity of the allegation. Unsupported equipment identification should be corrected; substantiated identification should be followed through the relevant commercial and authorisation history.

France also has an identified financial implementation channel. The Treasury’s Sudan guidance identifies the applicable EU frameworks and provides procedures for reporting asset freezes and suspected circumvention. This permits transaction-specific examination rather than reliance on broad political association. Soudan — Directorate-General of the Treasury — Mar 2026.

Germany: turn convening power into sustained implementation

Germany hosted the 15 April 2026 Berlin conference. Its Foreign Office’s July account records €232 million in German contributions within a conference that mobilised approximately €1.5 billion internationally. These figures describe the official account of conference financing; they do not independently establish final disbursement or access to every intended beneficiary. Germany and Sudan: Bilateral relations — Federal Foreign Office — Jul 2026.

Germany’s subsequent leverage rests on follow-through: tracing the execution of its commitments, supporting capable implementing partners and using the conference’s coordination structure to request measurable action against external military support. Hosting provides an opportunity to reconcile different governments’ undertakings. It does not confer authority over their national investigations or expenditure.

The German development ministry separately announced an additional €20 million in April 2026, following €155.4 million made available at the end of 2025 for projects in Sudan and affected neighbouring countries. These figures have a different institutional and temporal scope from the Foreign Office’s conference total and should not be added without a reconciliation of overlap. Sudan-Konferenz in Berlin: Deutschland erhöht Unterstützung für notleidende Bevölkerung Sudans um 20 Millionen Euro — BMZ — Apr 2026.

This reporting distinction is operationally important. A government can announce a conference contribution, a ministry can allocate programme funds and implementing partners can subsequently receive disbursements. Treating those stages as separate expenditure would exaggerate the response. Germany could improve coordination by promoting reporting that connects pledges to allocations, transfers and achieved access.

United Kingdom: combine existing designations with financial implementation and local delivery

The UK’s 5 February 2026 sanctions notice designated Quijano, Oliveros and Duque alongside other individuals. The notice specified asset freezes, travel bans and director-disqualification sanctions. This adds a national enforcement track to the measures examined in the earlier chapters and makes the effectiveness of implementation a concrete question. Sanctions Notice, Sudan — Foreign, Commonwealth and Development Office — Feb 2026.

The UK’s parliamentary response of 8 June 2026 explicitly addressed reports concerning Colombian contractors and UAE bases, reiterated opposition to external supplies of weapons, finance and personnel, and supported extending the UN embargo throughout Sudan. This is a stated policy objective; it should not be described as an expansion already enacted. Written parliamentary answer concerning Colombian contractors and external support — FCDO — Jun 2026.

On humanitarian delivery, the UK announced £146 million for financial year 2026/27, including support to local responders increased up to £15 million. The announcement also identified support for documentation by Sudanese human-rights defenders. These arrangements create a policy link between assistance, local access and preservation of evidence, although an announcement does not establish the eventual performance of each programme. UK boosts funding to local responders to help more than 1.8 million people in Sudan’s humanitarian crisis — FCDO — Apr 2026. GOV.UK

The UK’s practical advantage is the ability to connect these functions: examine relevant corporate and financial relationships, support international monitoring and preserve functioning aid channels. Its statutory guidance expressly provides for humanitarian exceptions and licensing, subject to conditions. Implementation should therefore distinguish prohibited support from authorised humanitarian activity rather than encourage indiscriminate withdrawal from Sudan-related transactions. Sudan sanctions: statutory guidance — UK Government — current guidance retrieved Nov 2026.

European Union: the common framework already reaches services and finance

The EU’s Sudan restrictions extend beyond physical arms shipments. Decision 2014/450 addresses military equipment, related technical assistance and brokering, associated financing, and circumvention, with specified exceptions and authorisation conditions. This is directly relevant to a system alleged to combine personnel, technical services and transport. A lawful assessment must identify the service, provider, territorial or nationality connection and applicable provision; the term “security contractor” alone does not determine the result. Council Decision 2014/450/CFSP, articles 1–2, consolidated version of 22 June 2026 — European Union.

The Council’s policy account also records July 2026 restrictions on Sudan-origin gold and on mercury and cyanide supplied to Sudan, intended to constrain conflict financing. These measures widen the financial-policy context, but they do not establish that a particular gold transaction financed the recruitment system. Such a connection would require transaction-level evidence. Sudan — Council of the European Union — reviewed Jul 2026.

European implementation should consequently connect service and financial investigations with export controls while keeping their legal questions distinct. Equipment diversion, prohibited military assistance and dealing with a designated person can involve overlapping evidence but different prohibitions. A common evidence package can improve coordination without replacing the competent authority’s assessment.

Financial commitments require compatible definitions

The following figures illustrate the documented scale and diversity of engagement. They cannot support a donor ranking because their periods, geographic coverage and accounting status differ.

Actor	Officially reported amount	Period or reference point	Meaning and limitation
Italy	€5 million to FAO; €1 million to the Red Cross federation	March 2026	Specific contributions described by the ministry; not a complete national total
France	€275 million	Cumulative support since the conflict began, following April 2026 announcement	Government-reported cumulative support; not a statement that the entire amount was disbursed
Germany	€232 million	April 2026 conference contribution, reported July	Conference-related German contribution
United Kingdom	£146 million	Financial year 2026/27	Announced aid allocation
EU institutions	€360.8 million	April 2026 conference pledge	Includes €215.5 million for Sudan and €145.3 million for the regional refugee response

Sources: Italian Foreign Ministry — Apr 2026; French government response — Jun 2026; German Foreign Office — Jul 2026; FCDO — Apr 2026; Council of the EU — Jul 2026. Amounts retain their original currencies; no exchange-rate conversion or inflation adjustment has been applied.

Diplomatic convergence does not establish agreement on implementation

The G7 foreign ministers’ 9–10 November 2026 declaration called on external actors to stop supplying or facilitating military, logistical and financial support to the belligerents. It also supported civilian-led political dialogue and unhindered humanitarian access. This establishes a recent shared position, but it does not identify every enforcement measure governments will adopt against particular actors. Joint declaration following the G7 Foreign Ministers Meeting in Paris — France Diplomatie — Nov 2026.

The September ministerial co-chairs’ statement separately supported stronger UN measures and application of the sanctions regime throughout Sudan. The gap between this position and enacted instruments is a central coordination test. Governments should specify which proposals require Security Council action, which can be pursued through existing national or EU powers, and which depend on voluntary cooperation from relevant states. Co-chairs’ statement on de-escalation and inter-Sudanese dialogue — France Diplomatie — Sep 2026.

Actor	Priority contribution	Principal constraint	Evidence of implementation
Italy	Examine a substantiated domestic nexus and sustain humanitarian delivery	Jurisdiction must be established; selected aid commitments are not national totals	Reasoned investigative action and documented delivery
France	Reconcile equipment allegations with export and financial records	Identification disputes and incomplete onward-transfer information	Auditable findings and action where breaches are substantiated
Germany	Maintain conference follow-through and programme continuity	Pledges, allocations and disbursements can overlap	Reconciled financing and delivery reports
United Kingdom	Implement existing designations and preserve local aid channels	Financial restrictions can create unintended payment obstacles	Enforcement outcomes alongside functioning authorised transfers
European Union	Coordinate service, financial and export-control implementation	Different national responsibilities and uneven evidence access	Consistent application and documented cross-border cooperation

Key judgments

European governments possess relevant diplomatic, regulatory and financial instruments. Their main implementation challenge is connecting evidence across jurisdictions while preserving humanitarian activity.

The near-term UN deadlines make institutional continuity an immediate priority. The longer EU extension provides policy continuity within its own framework but cannot substitute for every UN function.

What would change the assessment

Documented enforcement outcomes, reconciled disbursement records, substantive cooperation from relevant jurisdictions or enacted changes to the UN measures would alter the assessment of European leverage.

Open official record

The decisive gaps concern actual transaction disruption, outcomes of national investigations, execution of aid commitments and the decisions that will follow the approaching UN deadlines.

Chapter 8 — Scenarios, Decision Thresholds and Final Net Assessment

The central forecasting question is whether external pressure changes the availability of military services and the incentives of those supplying them. Corporate announcements, sanctions counts and diplomatic language provide incomplete measures. The assessment should instead track whether personnel can still be recruited and deployed, whether prohibited services remain financeable, whether investigations obtain usable evidence and whether humanitarian access improves without political concessions being imposed on civilians.

Adaptation is a justified planning assumption, not a measured forecast

The official enforcement record documents organisational succession and changes in corporate presentation, including the recruitment relationships addressed in the April 2026 Treasury action and the Talent Bridge officeholders addressed in June. These findings justify preparing for adaptation. They do not establish the present scale of any replacement system or demonstrate that every organisational change was caused by sanctions. Treasury Sanctions Recruitment Network Enabling War in Sudan — US Treasury — Apr 2026; Treasury Sanctions Networks Fueling Sudan’s Civil War — US Treasury — Jun 2026.

The mechanism is straightforward: a restriction aimed at one legal entity can affect operations only to the extent that the relevant services, assets, personnel or counterparties remain connected to it. When activities continue through another entity, investigators must establish continuity through evidence rather than resemblance. Conversely, changing a company name or director does not prove that services continued. A credible outlook therefore needs observations of actual recruitment, payments and delivery after the intervention.

The strongest working approach is to monitor several pathways that can coexist. A network can experience disruption in one jurisdiction while adapting elsewhere; diplomatic cooperation can improve while access to witnesses deteriorates. These pathways are therefore not mutually exclusive, and no numerical probabilities are assigned.

Pathway, 2027–2031	Conditions that would support it	Expected consequence	Evidence that would weaken it
Coordinated disruption	Several relevant jurisdictions act on shared evidence; replacement services are identified and constrained	Higher cost, delay or reduced availability of prohibited support	Continued service delivery at comparable scale through substitutes
Selective enforcement and adaptation	Measures affect named entities while other participants remain accessible	Partial disruption with continued operational support	Sustained cessation across recruitment, payment and deployment records
Verified diplomatic restraint	Relevant governments permit meaningful verification and take observable preventive action	Reduced external support and improved investigative access	Commitments without corroborated changes in conduct
Institutional attrition	Monitoring mandates, expertise or evidence access deteriorate	Lower visibility and weaker accountability	Renewed mandates, adequate support and protected evidence access

These are analytical pathways, not assertions that the conditions have already occurred.

Declining visibility must be distinguished from declining activity

A fall in public advertising, identifiable flights or published reporting could reflect reduced activity. It could also reflect different recruitment channels, incomplete transport data or reduced investigative access. The same observation therefore has several possible explanations. The assessment should change only when corroborating evidence distinguishes them.

An absence of new allegations is particularly weak evidence when monitoring capacity has contracted. Conversely, continuing allegations do not demonstrate that enforcement has had no effect. Investigators need comparable observations: completed deployments, successful and failed payments, service continuity and documented replacement arrangements over a defined period.

Observation	Possible favourable explanation	Competing explanation	Record needed to distinguish them
Fewer visible recruitment notices	Recruitment has declined	Recruitment moved to less visible channels	Reconciled recruitment and employment records
Fewer identifiable movements	Deployment has fallen	Movement data became incomplete or routes changed	Manifests and arrival records
Lower payments through a known intermediary	Funding was interrupted	A different payer assumed the function	Counterparty and beneficiary reconciliation
Departure of foreign specialists	External services ended	Rotation or replacement occurred	Departure, arrival and assignment records
Fewer public investigative findings	Violations or support declined	Access, staffing or publication capacity weakened	Mandate, resource and case-processing records

The value of this framework is that it identifies what would falsify an optimistic interpretation. Governments should avoid declaring success because a visible intermediary disappears while the underlying service remains available. They should also avoid assuming uninterrupted continuity when verified records show that an essential function has actually ceased.

Decision thresholds should match the proposed action

Different interventions require different legal and evidentiary foundations. The following thresholds are proposed decision rules for policy planning; they do not replace statutory tests, judicial standards or the discretion of competent authorities.

Proposed action	Decision trigger	Minimum record required for a defensible decision	Required restraint
Seek preservation of records	A credible, specific allegation connects records to conduct within a lawful inquiry	Identified persons, period, transaction or activity	Preserve potentially exculpatory material as well
Open or expand an investigation	Available information establishes a relevant jurisdictional and factual basis	Defined alleged conduct and applicable legal authority	Do not equate investigation with guilt
Examine a suspected sanctions breach	Identified activity may fall within a prohibition	Relevant parties, transaction, date and legal provision	Assess exceptions, licences and identity errors
Propose an additional designation	Evidence supports the applicable designation criteria	Individualised reasons and substantiated supporting material	Preserve review and challenge procedures
Reassess an export or service authorisation	Credible evidence raises a material end-use or compliance concern	Product or service identification and authorisation history	Avoid unsupported generalisation across unrelated exports
Escalate diplomatic demands	Repeated, substantiated concerns remain materially unanswered	Specific requests, responses and unresolved findings	Identify the practical remedy being sought

The sequence matters. A narrowly framed request for records can resolve a disputed identity before a wider accusation is made. An investigation can uncover facts that justify a stronger measure or establish that the initial allegation was mistaken. Preserving that possibility strengthens the legitimacy and usefulness of enforcement.

Feasible responses require named authorities and measurable effects

A coherent policy package would combine evidence preservation, targeted implementation, verified diplomacy and humanitarian continuity. These measures address different mechanisms and should be assessed separately. More severe measures are not inherently more effective: a broad restriction that disrupts relief payments while leaving military services accessible would perform poorly against the stated objectives.

The EU’s restrictions on military assistance and associated finance provide one legal foundation for examination of relevant services. The UK’s guidance provides a separate framework, including financial implementation and humanitarian exceptions. Any particular action must be taken by the competent authority under the applicable instrument. Council Decision 2014/450/CFSP, articles 1–2; Sudan sanctions: statutory guidance — UK Government. GOV.UK

Course of action	Responsible authority	Expected effect	Implementation burden	Time to effect
Preserve and reconcile relevant records	Competent national investigative and judicial authorities	Protects evidence and clarifies relationships	Lawful requests, secure handling and cross-border cooperation	Preservation can precede a complete investigation; analysis takes longer
Enforce existing restrictive measures	Competent sanctions, financial and customs authorities	Constrains prohibited transactions or services	Reliable identification and transaction-specific analysis	Begins when the applicable obligation is identified; network effects require observation
Review substantiated end-use concerns	Competent export-control authorities	Identifies diversion or non-compliance	Technical identification and access to transfer records	Depends on availability of product and authorisation records
Negotiate verifiable preventive commitments	Governments and relevant international representatives	Tests willingness to stop identified support activities	Agreed requests, verification and follow-up	Commitments can be immediate; compliance requires repeated verification
Maintain authorised humanitarian payment channels	Donors, competent licensing authorities and implementing partners	Reduces interruption of lawful assistance	Clear guidance, responsive processing and beneficiary protection	Depends on payment obstacles and applicable permissions
Protect investigative continuity	Mandating bodies and responsible administrative authorities	Preserves monitoring, expertise and evidence	Renewal decisions, staffing and resources	Most urgent before mandate or staffing gaps arise

Course of action	Reversibility	Potential second-order consequence	Principal risk
Records preservation	Time-limited measures depend on the relevant legal process	Improves later accountability	Excessive collection or inadequate confidentiality
Targeted implementation	Reviewable under the applicable framework	Encourages improved counterparty scrutiny	Misidentification or displacement into less visible channels
End-use review	Authorisation decisions can be revisited under applicable rules	Strengthens supply-chain documentation	Commercial disruption from unsupported assumptions
Verified diplomatic commitments	Commitments can be revised; lost evidence may be irrecoverable	Creates a basis for continued cooperation	Verification becomes a substitute for action despite non-compliance
Humanitarian continuity	Procedures can be adjusted as risks change	Preserves access and local capacity	Relief channels are obstructed or misused
Investigative continuity	Administrative arrangements can change	Preserves institutional memory	Nominal renewal without adequate operating capacity

Humanitarian protection must be measured alongside enforcement

The Berlin conference communiqué stated that sustained humanitarian access should not be contingent on a truce or ceasefire. This is a consequential policy standard: assistance should not become a bargaining instrument while military or diplomatic negotiations continue. Third International Sudan Conference, Berlin: co-hosts’ statement — UK Government — Apr 2026.

Donors should therefore measure the performance of financial restrictions and relief channels together. A payment refused because a genuine prohibition applies differs from a lawful payment delayed because an intermediary cannot interpret the rules. Both require attention, but they require different remedies. Programme monitoring should record the reason for interruption, its duration and the consequence for intended recipients, while protecting sensitive beneficiary information.

Performance question	Useful measure	Misleading substitute
Are prohibited services being constrained?	Verified interruption of the service or transaction	Number of public announcements
Is recruitment declining?	Reconciled completed recruitment and deployment records	Fewer visible advertisements
Are investigations progressing?	Authenticated evidence obtained and consequential questions resolved	Number of meetings held
Are humanitarian channels functioning?	Completed authorised transfers and documented delivery	Funding pledged
Are diplomatic commitments implemented?	Independently corroborated changes in identified conduct	Repetition of agreed language
Is monitoring capacity preserved?	Mandate continuity, available expertise and access	Formal renewal alone

These measures should be reported over consistent periods. Comparing a full year of payments with a partial year, counting the same beneficiary through several programmes or treating a pledge as cash received would distort the assessment. Where access prevents reliable measurement, the limitation should remain visible rather than be replaced by an assumed success rate.

The outlook to 2031 turns on three successive tests

The first test concerns continuity through the approaching institutional deadlines. Governments need to establish what remains legally in force, which investigative functions continue and whether relevant records and expertise are preserved. An interruption would not establish that the underlying allegations were unfounded; it would reduce the capacity to resolve them.

The second test concerns implementation beyond named intermediaries. During 2027–2028, an effective assessment would examine whether restrictions changed actual access to recruitment, financial services and military support. This is a proposed review period, not a prediction of when enforcement will succeed. Evidence that the same functions continued under demonstrably connected arrangements would justify reassessment of the measures.

The third test concerns durability through 2029–2031. A sustained improvement would require more than temporary disruption: relevant states would need functioning preventive measures, credible cooperation and reliable treatment of new evidence. The strongest evidence of institutional credibility would be consistent application when findings are politically inconvenient, including findings that qualify or contradict earlier allegations.

Review horizon	Principal test	Evidence of improvement	Evidence of deterioration
Late 2026–2027	Legal and investigative continuity	Clear mandates, preserved evidence and operating capacity	Gaps in authority, expertise or access
2027–2028	Effect on actual services	Corroborated reductions in prohibited support	Continued provision through verified replacement arrangements
2029–2031	Durability and accountability	Sustained cooperation and implementation across cases	Recurrent support, selective enforcement or weakened scrutiny

The periods are proposed analytical review horizons. They are not legal deadlines beyond those separately identified in Chapter 7.

Institutional credibility must survive any leadership outcome

The secretary-general selection process cannot serve as a substitute for investigating the alleged support networks. Nor should a candidate’s success or failure determine whether an existing allegation receives proper examination. Funding-source disclosures and public scrutiny under Resolution 79/327 provide tools for candidate evaluation, while Article 100 supplies the continuing independence obligation for the officeholder and staff. General Assembly Resolution 79/327, paragraph 42 — Sep 2025; UN Charter, Article 100.

The relevant indicators are behavioural and institutional: whether evidence remains accessible to authorised investigators, whether sensitive administrative decisions receive proper review and whether external pressure is resisted. These standards apply regardless of who holds office. A change in leadership without protection of those functions would provide limited reassurance; credible safeguards could remain valuable even when governments disagree sharply over a candidate.

Key judgments

The most defensible planning assumption is that pressure can produce both disruption and adaptation. Success must be demonstrated through changes in services and conduct rather than inferred from sanctions totals or reduced visibility.

European and international actors have different authorities but compatible practical tasks: preserve evidence, enforce applicable restrictions, verify preventive commitments and maintain humanitarian access. Their effectiveness depends on coordination without dilution of legal responsibility.

What would change the assessment

The assessment would strengthen toward effective disruption if several relevant jurisdictions produced corroborated evidence of service interruption and prevented connected replacement arrangements. It would shift toward continuing adaptation if operational support persisted despite changes in names, routes or payment providers. Verified cooperation could improve both prevention and attribution; deterioration in investigative access would increase uncertainty rather than resolve the allegations.

Open official record

The decisive outstanding records are post-measure recruitment and deployment data, transaction-level enforcement outcomes, verified implementation of governmental commitments, decisions on the approaching UN deadlines and evidence of uninterrupted humanitarian delivery.

Final net assessment

The documented recruitment system has created a concrete international enforcement problem and a separate test of institutional independence. The evidence examined supports action against identifiable conduct under applicable law, continued examination of the relationship between private networks and public authority, and scrutiny of safeguards surrounding the UN leadership process. It does not establish that every alleged activity was state-directed or that Nusseibeh personally participated in the system.

The most feasible response combines targeted legal implementation with specific requests for cooperation and independent verification. Governments should judge that response by whether prohibited support becomes harder to provide, consequential evidence becomes easier to obtain and civilians retain access to assistance. Through 2031, the decisive distinction will be between institutions that merely register concern and institutions that can establish facts, act within their authority and preserve those functions when powerful states contest the findings.

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