Complicit Dossier

Procurement and supply networks · company · India

SBL Energy Limited

  • Documented supplier or backer
  • Grade A: Official recordStrongest record: official record
  • Sanctioned byUS
  • 5 documented ties · 2 steps from the SAF

Also recorded as: AMIN EXPLOSIVES PRIVATE LIMITED; SBL ENERGY PRIVATE LIMITED; Amin Explosives Private Limited; SBL Energy Private Limited; SBL ENERGY LIMITED; Amin Explosives Private Limited (former); SBL Energy Private Limited (former); SEL; …

OFAC: TMAC 'has imported explosives and related material into Sudan from Egyptian and Indian companies, including India-based explosives manufacturer, SBL Energy Limited (SBL). These explosives are subsequently used in bombs deployed by the SAF. SBL... has supplied TMAC with over 200 shipments of explosives and explosives-related materiel since 2024.'

Their response

  • DENIED. SBL (statements 27 Jun-1 Jul 2026): it 'had exported only about 10 consignments of industrial mining explosives to Sudan since 2022'; shipments were 'supported by end-use certificates issued by the Government of Sudan and vetted through the Embassy of India in Sudan'; export licences issued by PESO, with DGFT/MEA clearances; products 'intended solely for civil construction and mining purposes'; it 'has appointed legal counsel and intends to cooperate fully with OFAC... and seek removal from the sanctions list'.
  • DENIED. CEO Alok Choudhari (The Hitavada, 28 June 2026, https://www.thehitavada.com/Encyc/2026/6/28/sbl-refutes-us-allegations-says-all-exports-were-strictly-for-civil-mining.html): company makes industrial explosives 'exclusively for civil mining, quarrying and construction'; exported 'only about 10 consignments' to Sudan since 2022, all with end-use certificates and Indian approvals.

Records

5

Each record carries its own grade. A grade describes the source for that record, not the actor.

Grade A: Official record

SBL Energy Limited

OFAC: TMAC 'has imported explosives and related material into Sudan from Egyptian and Indian companies, including India-based explosives manufacturer, SBL Energy Limited (SBL). These explosives are subsequently used in bombs deployed by the SAF. SBL... has supplied TMAC with over 200 shipments of explosives and explosives-related materiel since 2024.'

Why this grade
A (registration, LEI, designation); B (financials - rating agency); the supply claim itself is A as a sanctions finding but is disputed by the company
Response
DENIED. SBL (statements 27 Jun-1 Jul 2026): it 'had exported only about 10 consignments of industrial mining explosives to Sudan since 2022'; shipments were 'supported by end-use certificates issued by the Government of Sudan and vetted through the Embassy of India in Sudan'; export licences issued by PESO, with DGFT/MEA clearances; products 'intended solely for civil construction and mining purposes'; it 'has appointed legal counsel and intends to cooperate fully with OFAC... and seek removal from the sanctions list'.
Sanctions
US OFAC, SUDAN-EO14098, 2026-06-26, material support to Target Multiactivities Company Ltd; US OFAC, 2026-06-26
Grade A: Official record

SBL Energy Limited

2024 - 2026

Explosives manufacturer that supplied DIS-controlled TMAC with over 200 shipments of explosives and explosives-related materiel since 2024; OFAC states these explosives 'are subsequently used in bombs deployed by the SAF'.

Response
DENIED. SBL (statements 27 Jun-1 Jul 2026): it 'had exported only about 10 consignments of industrial mining explosives to Sudan since 2022'; shipments were 'supported by end-use certificates issued by the Government of Sudan and vetted through the Embassy of India in Sudan'; export licences issued by PESO, with DGFT/MEA clearances; products 'intended solely for civil construction and mining purposes'; it 'has appointed legal counsel and intends to cooperate fully with OFAC... and seek removal from the sanctions list'.
Sanctions
OFAC SDN, E.O. 14098, designated 26 Jun 2026; CEO Alok Choudhari designated the same day.
Grade A: Official record

'About 10 consignments' against 'over 200 shipments': what Indian customs data show

December 2024 - January 2026

India's monthly returns to UN Comtrade show no explosives exports to Sudan from January to November 2024, then a continuous flow: detonators and related items (HS 3603) in December 2024, and prepared explosives (HS 3602) in nine months of 2025 (February to September and November) and in January 2026. Totals for December 2024 to January 2026 are 6,672 tonnes of prepared explosives and 411 tonnes of HS 3603 goods, shipped in eleven separate months, with a declared value of about USD 10.4 million. Nothing is declared from February to July 2026, the last month India has reported, so the flow had stopped about five months before the designation of 26 June 2026. For comparison India declared 1,051 tonnes in 2022 and 500 tonnes in 2023. The two competing counts are therefore not necessarily contradictory: eleven monthly entries is close to SBL's 'about 10 consignments', while 6,672 tonnes at 15 to 20 tonnes per container would be some 330 to 450 container loads, in line with OFAC's 'over 200 shipments' if Treasury (which worked with the Customs and Border Protection National Targeting Center) counted containers or bill-of-lading lines. That reconciliation is an inference; neither side has said what unit it counted. SBL's phrase 'since 2022' sits awkwardly with the 2022 and 2023 tonnages unless other Indian exporters were also shipping.

Response
SBL (The Hitavada, 28 June 2026; UNI, 1 July 2026): it 'exported only about 10 consignments of industrial mining explosives to Sudan since 2022'; 'every shipment was supported by end-use certificates issued by the Government of Sudan and vetted through the Embassy of India in Sudan'; export licences came from the Petroleum and Explosives Safety Organisation; it 'will shortly submit a formal representation before the US Treasury Department, supported by documentary evidence'. No report that the representation was filed, and no statement from India's Ministry of External Affairs, DGFT or PESO, was found (three searches; Business Today, Scroll and The Wire coverage carries none).
Sanctions
OFAC, 26 June 2026 (E.O. 14098). No delisting found: SBL is on the SDN list as of 3 October 2026.
›Research notes

Grade A is for the customs statistics. Comtrade does not identify exporter or consignee, so the data cannot show that SBL or TMAC accounted for all of it, and HS 3602 covers civil mining explosives. Trade-data aggregators that could show bill-of-lading counts (Volza, Seair, Zauba, ImportGenius, InfodriveIndia) returned HTTP 403 or 404; Panjiva's public page for SBL shows no Sudan rows. Tonnes-per-container is this desk's assumption. Sources marked summary_only were read through an automated page summary; quotations from them should be checked against the page before publication.

Grade C: Single source

SBL Energy Ltd

OFAC (June 2026) says SBL Energy supplied TMAC with more than 200 shipments of explosives since 2024. The company's CEO was also designated according to Indian press.

Why this grade
Press report of an official act. The primary record is cited in another record for this actor.
Response
DENIED. CEO Alok Choudhari (The Hitavada, 28 June 2026, https://www.thehitavada.com/Encyc/2026/6/28/sbl-refutes-us-allegations-says-all-exports-were-strictly-for-civil-mining.html): company makes industrial explosives 'exclusively for civil mining, quarrying and construction'; exported 'only about 10 consignments' to Sudan since 2022, all with end-use certificates and Indian approvals.
Source
Al Bayan (UAE daily, Dubai government-owned; UAE is accused of backing the RSF) reporting a US Treasury (OFAC) action
  1. 1Al Bayan · albayan.ae · 26 Jun 2026

NamesTMAC

1 more record below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see it.

1 more record at grade C (single source) or D (unverified lead). Change “Evidence shown” to see it.

Checked against the document

3

Statements compared with the wording of the primary document.

  • “SBL, whose chief executive officer is Indian national Alok Choudhari (Choudhari), has supplied TMAC with over 200 shipments of explosives and explosives-related materiel since 2024.”

    US Treasury press release sb054426 Jun 2026verified verbatim

    Correction: arms.json #23 says "No company response found" - wrong: SBL issued denials on 27-28 June and 1 July 2026 (recorded in corporate.json #2). Carry the denial into arms.json and all_entities.json.

  • OFAC recent-actions pages and SDN.XML published 2 Oct 20262 Oct 2026verified verbatim

  • “Rejecting the allegation, Choudhari said SBL Energy had exported only about 10 consignments of industrial mining explosives to Sudan since 2022.”

    The Hitavada, "SBL refutes US allegations, says all exports were strictly for civil mining" (28 June 2026); Nagpur Today (1 July 2026)28 Jun 2026verified verbatim

    Correction: This is the newspaper's reported speech, not a direct quotation of the company statement; SBL's own website (sblenergy.com) could not be reached. corporate.json wording matches the newspaper. Nagpur Today adds that SBL says TMAC "was not a sanctioned entity at the time of the transactions", that "to the best of its knowledge, none of its products were diverted for military use", and that it "has appointed legal counsel and intends to cooperate fully with OFAC ... and seek removal from the sanctions list". Publish alongside the OFAC finding.

Relationships

6

← means the other party acts on this one; → means this one acts on the other.

Ownership and control · 4

1 more relationship below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see it.

Arms and supply · 2

Weapons, sites and other subjects

1

Recorded links to things, places, events and authorities rather than to organisations or people.

  • From Synergy Capital (Dubai); India SME Investments; Mukul Agrawal

    investors - Rs 325 cr compulsorily convertible debentures (no alleged role in Sudan trade) · Feb 2024-

    Grade B: Corroborated

Sanctions listings

1
  • United States (OFAC)26 Jun 2026OFAC SDN UID 57923

    ›Stated reason

    OFAC designated SBL pursuant to E.O. 14098 for being a foreign person who has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, TMAC, a person whose property and interests in property are blocked pursuant to E.O. 14098. home.treasury.gov

Dated events

5
  1. Indian explosives-related exports to Sudan resume after an eleven-month gap (HS 3603, 43 t); 6,672 t of prepared explosives follow by January 2026 comtradeapi.un.org

    Grade A: Official record
  2. Last month in which India declares explosives exports to Sudan (538 t of HS 3602); none declared February-July 2026 comtradeapi.un.org

    Grade A: Official record
  3. OFAC designates TMAC, Tariq Madani, SBL Energy, Alok Choudhari and Ports Engineering; cites Egyptian, Indian, Emirati and Turkish suppliers. home.treasury.gov

    Grade A: Official record
  4. OFAC designates TMAC, its managing director Tariq Hussain Muhammad Madani, Ports Engineering, SBL Energy and Alok Choudhari; Egyptian, Emirati and Turkish suppliers described but not named. content.govdelivery.com

    Grade A: Official record
  5. SBL Energy says it will 'shortly submit a formal representation' to the US Treasury thehitavada.com

    Grade B: Corroborated

1 more event below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see it.

Geography

Tags come from the recorded jurisdiction and from place names in the records. Coordinates on the map are approximate.

Based in
India
Also named
Egypt (1)

Position in the network

Derived by analysing the documented relationships. Nothing in this section is a finding.

Still connected to the SAF when only official records are counted. Ranks 26 in the file for how often it sits on the shortest documented chain between two others.

›Possible links to investigate · 1
  • Defense Industries System (DIS) hypothesis

    No direct tie is documented. Basis: shared intermediary; named in the other actor's record; cited in the same source (via Target Multiactivities Company Ltd (TMAC)).