Humanitarian Aid Commission (HAC)

State body under the SAF-led government. OBSTRUCTION (official findings): OFAC, sanctioning Burhan: 'The SAF is also responsible for the routine and intentional denial of humanitarian access, using food deprivation as a war tactic.' UN SG CAAC report for 2024: 38 denial-of-humanitarian-access incidents, of which SAF 12 and 'Sudanese Armed Forces Military Intelligence' 4 (RSF 18). UN FFM (Sept 2025): 'Humanitarian assistance has been obstructed, convoys attacked, and aid workers targeted'. The government suspended participation in the IPC famine-monitoring system in Dec 2024 on the eve of a famine finding, and expelled WFP's country director and operations manager in Oct 2025. RENT EXTRACTION: The New Humanitarian: HAC has 'profited by charging relief groups various fees, such as for travel permits and for the per diems it demands for its staff'; OCHA reported 'exorbitant financial demands'. Ayin: bribes disguised as 'facilitation' or 'gifts'; work-permit cost rose from ~35,000 to ~700,000 SDG; permits take 3-5 weeks; HAC demanded volunteer rosters and donor contacts from Emergency Response Rooms. WFP INVESTIGATION: Reuters (Aug 2024) - WFP's Inspector General examined whether staff concealed the army's obstruction of aid from donors (incl. Port Sudan authorities refusing 15 trucks in June 2024) and the alleged disappearance of 200,000+ litres of fuel in Kosti.

Why this grade

A (obstruction/denial of access); B (fees and rent extraction: TNH + Ayin + OCHA); C (bribery; diversion)

Response

HAC did not respond to The New Humanitarian. The acting agriculture minister said the IPC issues 'unreliable reports that undermine Sudan's sovereignty'. The foreign ministry said the WFP officials 'failed to heed repeated warnings'. WFP said it was reviewing 'allegations of individual misconduct'.

Sanctions

No designation of HAC. Burhan designated by OFAC 16 Jan 2025 partly on humanitarian-access grounds. EU listing of Keikal (2025/1480) also cites obstruction of humanitarian aid.

Government body under the SAF-led authorities. Obstruction: S/2026/357 para 191 attributes 2 verified denial-of-access incidents in 2025 to HAC by name (plus SAF 7 incl. MI 3). UN Panel S/2025/239 para 57: 'The Humanitarian Aid Commission delayed authorizations for convoys to travel from Port Sudan, approvals at times taking two months.' A/HRC/60/22 paras 109-110: 'in May 2025, only 110 of the 355 pending visa requests were approved, and the backlog is increasing'; 'imposed bureaucratic restrictions ... resulted in the denial of humanitarian access'. Leakage of aid into markets: CNN Arabic (16 Feb 2024) reported relief goods on sale in Port Sudan markets while displaced people registered with HAC said they received nothing. Ayin (21 Aug 2024): relief-labelled food 'can be found on the shelves of stores in Port Sudan'; a volunteer alleged 'the Humanitarian Aid Commission and security departments in Port Sudan are sending relief shipments to leaders of native administrations in Jabal, which is home to a large Sudanese army base ... to instill political loyalty'; local aid workers said 'HAC is the sole body that determines the locations for relief distribution'. Al-Taghyeer (12 Oct 2024): a medical-supplies trader said donated IV fluids and insulin 'leaked to the market through brokers affiliated with the federal Ministry of Finance'; 'other reports' said foreign traders bought relief in Port Sudan 'from officials affiliated with the Gebreil and Minawi movements'. Asharq Al-Awsat (7 Jan 2025): large quantities on sale in Port Sudan; notes that in Sept 2023 the cabinet dismissed the then HAC commissioner 'after media reports pointing to "major corruption" in the relief file'.

Why this grade

A (denial/delay of access); B (aid on sale in markets in SAF-held areas: CNN Arabic, Ayin, Al-Taghyeer, Asharq Al-Awsat); C (attribution to HAC, Finance Ministry brokers or movement officials: anonymous sources); no proof of organised diversion

Response

HAC Commissioner-General Salwa Adam Benya to Ayin: 'We have not recorded any incidents of this. If anyone is able to detect a case of selling relief aid and has proof, they must notify us'; to Asharq Al-Awsat: 'a citizen selling his relief ration in the market is not our responsibility', and a committee was formed to review NGO warehouses. A Finance Ministry source denied any role in receiving or distributing relief (Al-Taghyeer). HAC told the UN Panel that the RSF 'had blocked and diverted food aid'.

Sanctions

None on HAC located. (Al-Burhan: OFAC 16 Jan 2025, grounds include denial of humanitarian access - first pass.)

Context for the mobilisation networks. In September 2022 the HAC head re-registered 22-23 organisations the ERC had dissolved; an ERC member called them 'hidden facades' of the NCP and Islamic Movement consisting of 'banners, stamps, and bank accounts'. No source read shows these organisations funding the SAF or mobilisation after April 2023.

Why this grade

B for the re-registration; no evidence on wartime funding

Response

None in the articles read.