Both the Sudanese Armed Forces (SAF) and the Rapid Support Forces (RSF) use proceeds from the gold trade to finance the purchase of weapons and the recruitment of fighters. The EU’s decision to act on this analysis through sanctions reflects what PAX and other organisations have long highlighted about the role of natural resources in the Sudanese conflict.
Nevertheless, the decision raises important questions about implementation. Announcing a trade ban is one thing; implementing it effectively is another. For now, it remains unclear how the EU intends to design and implement the sanction in practice. As long as this remains unclear, it is also difficult to see how compliance can be effectively monitored. There is no credible implementation and enforcement mechanism. Without such a mechanism, the sanctions package risks remaining largely symbolic.
In addition, sector-wide sanctions are a relatively blunt instrument. Effective action requires far greater insight into the international trade networks that facilitate the gold trade: which buyers, traders, refineries, transit countries and financial networks are involved. Without additional measures, there is a risk that the trade will shift to informal or illegal trading channels, making it even more difficult to trace and enforce. Only with detailed knowledge can sanctions be targeted at the actors that actually sustain the war economy.
Unintended side effect
Another concern is the potential impact on the Sudanese population. Most gold mining in Sudan takes place in the artisanal mining sector, where gold provides an essential source of income for hundreds of thousands of people – particularly in a country where large parts of the population face hunger and extreme poverty. A broad trade ban could therefore affect not only the warring parties, but also this vulnerable group. One unintended consequence could be that people who lose their income join an armed group out of sheer necessity.
Then there is the responsibility of European companies themselves. Sanctions do not change that. Companies that are part of the gold supply chain must continue to assess whether their activities contribute to human rights violations or the financing of the conflict. This is precisely why implementing the sanctions requires close cooperation between the EU and the private sector, so that government policy and corporate responsibility reinforce one another.
Broader policy inconsistency
In addition, this embargo exposes a broader policy inconsistency. The EU rightly holds companies in the gold supply chain to account for their potential contribution to the war economy, but is far less explicit about the responsibility of European companies that produce or export weapons to countries that demonstrably supply them to the warring parties in Sudan, most notably the United Arab Emirates. A credible policy requires the same standard to be applied to both sectors. As long as the EU tackles the financing of the war but does not address the supply of weapons with the same consistency, it risks undermining with one hand what it seeks to achieve with the other.
PAX calls on the EU not to view this embargo in isolation, but to embed it in a coherent and consistent policy. Only such an approach can prevent Europe from continuing, directly or indirectly, to fuel the conflict in Sudan.
