Complicit Dossier

State-owned and co-opted commercial entities · state-owned mining-supply company · Sudan

Sudamin Company Limited

سودامين · شركة سودامين المحدودة / شركة أم درمان للتعدين

  • Part of the SAF or state-controlled
  • Grade A: Official recordStrongest record: official record
  • Sanctioned byUK
  • 12 documented ties · 1 step from the SAF

Also recorded as: Sodamine; Sudameen; Sudamen; Sudamin; Sudamine; SUDAMIN COMPANY LIMITED; سودامين; Sudamin Company; …

UK says revenue is suspected of reaching both the SAF and the RSF. Do not present as purely SAF-side.

UK: 'a major state-owned gold mining company in Sudan with links to other SAF-owned mining companies, has provided the SAF with revenue from conflict gold'. UK press release adds past links to sanctioned (RSF) company Al Junaid.

Their response

  • No Sudanese government response in the articles read.

Records

6

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

Grade A: Official record

SUDAMIN COMPANY LIMITED

UK SoR: state-owned gold mining company that "has provided the SAF with revenue from conflict gold"

›Research notes

[Verification: Not purely SAF-side: the UK press release says Sudamin is "suspected of channelling revenue from conflict gold to both the SAF and RSF, including through past links to sanctioned company Al Junaid".]

  1. 1gov.uk
  2. 2opensanctions.org
Grade A: Official record

Sudamin Company Limited

UK: 'a major state-owned gold mining company in Sudan with links to other SAF-owned mining companies, has provided the SAF with revenue from conflict gold'. UK press release adds past links to sanctioned (RSF) company Al Junaid.

Why this grade
A (designation); B (shareholdings)
Sanctions
UK, 2026-07-16
›Research notes

[Verification: Not purely SAF-side: the UK press release says Sudamin is "suspected of channelling revenue from conflict gold to both the SAF and RSF, including through past links to sanctioned company Al Junaid".]

  1. 1UK HM Treasury/OFSI Financial Sanctions Notice: Sudan, 16 July 2026 · assets.publishing.service.gov.uk · 16 Jul 2026
  2. 2UK FCDO press release: UK sanctions illicit gold networks fuelling Sudan's war · gov.uk · 16 Jul 2026
  3. 3C4ADS Sudan SCE Explorer dataset (Ministry of Finance inventory, RDC seizures, C4ADS investigations) - extracted from site bundle · sudansce.c4ads.org · Jun 2022
  4. 4Chatham House (Soliman & Baldo), Gold and the war in Sudan (read from local copy raw/ch_gold.pdf; landing-page URL not verified) · chathamhouse.org · Mar 2025
Grade A: Official record

Sudamin Company Limited - portfolio of state minority stakes in concession companies

UK: state-owned; involved in the gold sector financing the conflict (see first pass). New here: Sudamin is the vehicle through which the state holds its minority share in foreign-operated concessions, including those of Emiral/Kush and Managem.

Why this grade
A (designation); B (stakes - MoF inventory 2019-2021, several rows flagged 'historical')
Sanctions
UK, 2026-07-16
›Research notes

English names are C4ADS machine translations of the Arabic register entries; counterparties' nationalities are mostly not given. 'Dubai International Mining Company' (NGM's 73% holder) is a UAE-suggestive name only - possible UAE link, unconfirmed. [Verification: Not purely SAF-side: the UK press release says Sudamin is "suspected of channelling revenue from conflict gold to both the SAF and RSF, including through past links to sanctioned company Al Junaid".]

  1. 1C4ADS Sudan SCE Explorer dataset (Ministry of Finance inventory / RDC seizures; 2019-2021 snapshot) - local extract raw/c4ads_sce_nodes.json, raw/c4ads_sce_edges.json · sudansce.c4ads.org · Jun 2022
  2. 2OpenSanctions consolidated sanctions targets (export of 2026-10-03), name/alias search - raw/p2/os_p2_hits.json · data.opensanctions.org · 3 Oct 2026

NamesEmiral / KushManagemUAE

Grade B: Corroborated

Sudamin

pre-war to present

State-owned company that controlled mercury/cyanide distribution; holds 25% of the Alliance/Kush operation per Ayin. Operations halted at start of war; imports of the chemicals resumed through Port Sudan from H2 2023 (STPT).

Why this grade
Regraded from A: reporting, not an official record.
Response
No response located in the sources reviewed.
Sanctions
UK sanctions list, 16 July 2026 (SUD0059).
›Research notes

[Verification: Not purely SAF-side: the UK press release says Sudamin is "suspected of channelling revenue from conflict gold to both the SAF and RSF, including through past links to sanctioned company Al Junaid".]

  1. 1Sudan Transparency and Policy Tracker (STPT), 'Fueling Sudan's War: How Gold Exports and Smuggling Are Prolonging the Conflict' · sudantransparency.org · 16 Oct 2024
  2. 2Ayin Network, 'Sudan's lead gold producer and the UAE' (revised version) · 3ayin.com · 3 Sep 2026
  3. 3Chatham House, 'Gold and the war in Sudan', ch.3 Gold production and trade during the war · chathamhouse.org · 25 Mar 2025
Grade C: Single source

Sudamin Ltd and Omdurman Mining Company

UK sanctions of 16 Jul 2026 on 'illicit gold networks': the two state companies are described as linked to gold revenues benefiting the Sudanese army.

Why this grade
Press report of an official act. The primary record is cited in another record for this actor.
Response
No Sudanese government response in the articles read.
Source
European broadcaster (independent)
  1. 1Euronews Arabic · arabic.euronews.com · 16 Jul 2026

NamesOmdurman Mining

Grade D: Unverified lead

Self-description of ownership on the company's page

page read 3 Oct 2026

The Facebook page in Sudamin's name describes it as 'a government company owned by the Ministry of Finance and Economic Planning 99% and the Central Bank of Sudan 1%'. Its director-general took part in the January 2025 meeting with NORINCO's Norin Mining in Riyadh.

Sanctions
UK.
›Research notes

Page not established as official (about 700 followers, no badge): grade D. To be checked against the Ministry of Finance inventory used in pass 3.

  1. 1Sudamin Company Limited Facebook page (page description) · facebook.com · 3 Oct 2026
  2. 2Sudamin Company Limited Facebook page: joint meeting between the Ministry of Minerals and the Chinese company Norinco · facebook.com · 16 Jan 2025

NamesCentral BankNorinco

3 more records below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see them.

2 more records at grade C (single source) or D (unverified lead). Change “Evidence shown” to see them.

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

Checked against the document

2

Statements compared with the wording of the primary document.

  • “updated the UK Sanctions List on GOV.UK with the following 11 additions.”

    UK Sanctions Notice: Sudan, 16 July 202616 Jul 2026verified verbatim

  • “Specifically, SUDAMIN, as a major state-owned gold mining company in Sudan with links to other SAF-owned mining companies, has provided the SAF with revenue from conflict gold.”

    UK Sanctions List, SUD0059, statement of reasons16 Jul 2026verified verbatim

    Correction: finance.json #9 says Sudamin has no UK listing and grades it B. Wrong: UK-listed 16 July 2026 (SUD0059, registration 40411). Raise to A. Add the nuance from the FCDO press release that Sudamin is "suspected of channelling revenue from conflict gold to both the SAF and RSF, including through past links to sanctioned company Al Junaid" - it is not a purely SAF-side entity.

Relationships

14

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

Ownership and control · 13

12 more relationships below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see them.

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

Money · 1

Sanctions listings

1

  • United Kingdom16 Jul 2026SUD0059

    ›Stated reason

    The Secretary of State considers that there are reasonable grounds to suspect that Sudamin Company Limited ( “SUDAMIN”) is an involved person under the Sudan (Sanctions) (EU Exit) Regulations 2020 as it has made available funds or economic resources that could contribute to activity which threatens the peace, stability and security of Sudan. Specifically, SUDAMIN, as a major state-owned gold mining company in Sudan with links to other SAF-owned mining companies, has provided the SAF with revenue from conflict gold. The SAF is one of the main warring parties in Sudan. sanctionslist.fcdo.gov.uk

Dated events

2

  1. Sudan's minerals delegation meets 'Norinco', represented by Norin Mining's general manager, in Riyadh. facebook.com

    Grade C: Single source

  2. C4ADS publishes 'Bullion for Bullets', naming Sudamin affiliates and Advanced Mining Works and tracing cyanide shipments to Omdurman Mining. c4ads.org

    Grade A: Official record

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

1 more event at grade C (single source) or D (unverified lead). 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
Sudan
Also named
United Arab Emirates (3), Saudi Arabia (1)
Places
Port Sudan, Omdurman, Dubai, Riyadh

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 5 in the file for how often it sits on the shortest documented chain between two others.

›Possible links to investigate · 7