The Council of the European Union adopted Council Decision (CFSP) 2026/2261 on October 9, 2026, amending Decision (CFSP) 2023/2135 on restrictive measures in view of activities undermining the stability and political transition of Sudan. The decision prolongs that regime until October 10, 2027 and replaces three Annex entries on the asset-freeze and travel-ban list. EU banks and credit institutions, EU payment institutions and e-money issuers, EU trade finance providers and correspondent banks, EU customs brokers and freight forwarders, and EU importers and exporters with Sudan supply-chain exposure must immediately update sanctions screening filters against the revised EU Sudan asset-freeze and travel-ban list, screen transactions and customer portfolios, and freeze the assets of designated persons, or non-compliance is a criminal offence in EU Member States, with fines and imprisonment under national law, plus regulatory enforcement and reputational damage.
No name is added and no name is removed. The three replaced entries are persons already listed: Mirghani Idriss Suleiman, a Sudanese Armed Forces lieutenant general directing the Defence Industry System; Mustafa Ibrahim Abdel Nabi Mohamed, financial director of the Rapid Support Forces, a director of Al-Khaleej Bank and majority shareholder of Shield Protective Solutions; and Abu Aqla Mohamed Ahmed Kaikal, leader of the Sudan Shield Forces after leaving the Rapid Support Forces. Council Implementing Regulation (EU) 2026/2262 writes the same Annex change into Regulation (EU) 2023/2147, the instrument that applies the asset freeze directly to every person in the Union.
What does Council Decision (CFSP) 2026/2261 change?
Decision (CFSP) 2023/2135 was due to lapse on October 10, 2026. Decision (CFSP) 2026/2261 keeps the travel ban and the asset freeze in force until October 10, 2027, and it substitutes updated statements of reasons and identifiers for three existing Annex entries. Screening files that still carry the previous wording of those entries are out of date even though the names were already designated.
| Person | Revised statement of reasons | List effect |
|---|---|---|
| Mirghani Idriss Suleiman | Sudanese Armed Forces lieutenant general directing the Defence Industry System | Annex entry replaced, still designated |
| Mustafa Ibrahim Abdel Nabi Mohamed | Rapid Support Forces financial director, director of Al-Khaleej Bank, majority shareholder of Shield Protective Solutions | Annex entry replaced, still designated |
| Abu Aqla Mohamed Ahmed Kaikal | Leader of the Sudan Shield Forces, affiliated with the Sudanese Armed Forces | Annex entry replaced, still designated |
The Council gives those roles as the grounds for maintaining the listings. Defence Industry System, Al-Khaleej Bank, Shield Protective Solutions and the Sudan Shield Forces are not, on this act, new designated names. Whether a company is caught still turns on ownership or control by a designated person. A UN Security Council extension of the UN Sudan regime is a separate list, issued by a different jurisdiction, and does not replace the EU Annex.
Who must apply the amended Sudan list?
Exposure follows activity into the European Union, not a Sudanese place of incorporation. EU banks and credit institutions, EU payment institutions and e-money issuers, and EU trade finance providers and correspondent banks must freeze funds and economic resources they hold or transfer, including letters of credit and cross-border payments with a Sudan nexus. EU customs brokers, freight forwarders, and importers and exporters with Sudan supply-chain exposure are covered where a party, a payment or a cargo interest matches a designated person or an entity that person owns or controls.
What must screening teams change, and how fast?
The required action is immediate. There is no compliance date and no grace period in the decision: the prolongation prevents the regime from ending on October 10, 2026, and the replaced entries are the list version to screen against.
- Load Decision (CFSP) 2026/2261 and Implementing Regulation (EU) 2026/2262 into the sanctions list feed and confirm the three Annex entries have been overwritten, not duplicated.
- Refresh identifiers, functions and statements of reasons for Mirghani Idriss Suleiman, Mustafa Ibrahim Abdel Nabi Mohamed and Abu Aqla Mohamed Ahmed Kaikal.
- Re-screen customer portfolios, open payments and trade-finance transactions against the revised entries.
- Test ownership and control where a file links a customer or a counterparty to the Defence Industry System, Al-Khaleej Bank, Shield Protective Solutions or the Sudan Shield Forces through one of the three persons.
- Freeze the assets of designated persons and of entities they own or control, and block funds from being made available to them.
- Retain the list version, the screening run and any freeze or rejection on the file.
Continuous, per-jurisdiction monitoring is what surfaces an Official Journal sanctions amendment at publication, ahead of the next batch screening cycle.
What happens if designated assets are not frozen?
Non-compliance with EU sanctions is a criminal offence in EU Member States: fines and imprisonment under national law, plus regulatory enforcement and reputational damage. Decision (CFSP) 2026/2261 does not create a new EU fine schedule. It keeps the freeze and the travel ban in force until October 10, 2027.
Verify whether any customer, payment or shipment touches the three replaced entries or an entity they own or control. Confirm the screening filter is on the amended Annex, not the pre-October 9, 2026 wording. Brief sanctions, trade finance and logistics on the prolongation to October 10, 2027, and record the freeze decision where a match is confirmed.
