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Political instrumentalities


The NSS was established in the wake of South Sudan’s independence in 2011 as an advisory and intelligence gathering agency.24 The NSS “shall respect the will of the people, the rule of law, civilian authority, democracy, human rights and fundamental freedoms,” says the Transitional Constitution of the Republic of South Sudan, 2011, which is still in force.25
In the decade since its creation, the NSS has gone far beyond its remit to advise and gather intelligence, having grown into a highly militarized force that now has some 10,000 agents and its own tanks, weapons, and training facilities.26, 27 “The NSS has taken over the role of the police,” a South Sudanese civil society activist told The Sentry, continuing, “They also act as a combat force; they are heavily armed. They have partly taken over the role of the military.”28 The NSS is an “autonomous fighting force capable of influencing South Sudan’s politics, society, and economy,” and it is “better equipped and trained than regular SSPDF [South Sudan People’s Defense Forces] forces,” according to the United Nations Panel of Experts in 2019.29
Operating under the direct supervision of the President Salva Kiir,30 and with Kiir loyalist Akol Koor Kuc serving as director general of the Internal Security Bureau (ISB), the NSS has been repurposed as the president’s own security force against internal threats to his rule.31 As early as 2013, the agency was expanded in response to concerns that the then-army chief of staff General Paul Malong, with whom Kiir and Kuc have had a long-running political rivalry, was becoming a threat to Kiir’s power.32 Although Malong is no longer army chief of staff, he still holds significant influence, having command of rebel forces.33

As a signatory to the African Charter on Human and People’s Rights, South Sudan has pledged to uphold human rights, including the rights to express and disseminate opinions, to receive information, to free association, and to freedom of movement.34 Discrimination in recognizing these rights on the basis of ethnic group or “political or any other opinion” is expressly forbidden.35
Yet the NSS operates in such a way that it threatens rather than protects the human rights of its citizens and restricts rather than promotes their fundamental freedoms. Its well-rehearsed playbook of repression includes illegal detention, politically motivated arrest, suppression of freedom of speech, interference in civil society and the press, censorship, and economic control.36, 37, 38
These operations are a clear breach of international best practice on the constraints of power for intelligence agencies, with the UN Human Rights Council (UNHRC) advising that “intelligence services are explicitly prohibited from undertaking any action that contravenes the Constitution or international human rights law.”39 Intelligence services operating according to good practice “carry out their work in a manner that contributes to the promotion and protection of the human rights and fundamental freedoms of all individuals under the jurisdiction of the State,” it says.40 Security services and civil society organizations need to have a “mutual trust,” according to the African Union.41
Illegal detention
The 2014 National Security Act gives the NSS the power to “arrest and detain suspects in accordance with the provisions of this Act in crimes related to National Security as provided for under section 7 of this Act.”42, 43 This is a clear breach of international best practice. Intelligence services “are not given powers of arrest and detention if this duplicates powers held by law enforcement agencies that are mandated to address the same activities,” according to the good practices identified by the UNHRC.44
In cases where intelligence services do have powers of arrest and detention, well-functioning systems ensure that they are “subject to the same degree of oversight as applies to their use by law enforcement authorities, including judicial review of the lawfulness of any deprivation of liberty” and that they “comply with international human rights standards on rights to liberty and fair trial, as well as the prohibition of torture and inhuman and degrading treatment.”45
South Sudan’s government has committed to abide by international norms on arbitrary arrest and detention. Article 6 of the African Charter on Human and People’s Rights, of which South Sudan is a signatory, states that “no one may be arbitrarily arrested or detained.”46 “Every individual shall have the right to have his cause heard,” states Article 7, which includes “the right to be presumed innocent until proved guilty by a competent court or tribunal; the right to defense, including the right to be defended by counsel of his choice,” and “the right to be tried within a reasonable time by an impartial court or tribunal.”47 Nevertheless, the NSS has been found to routinely make arbitrary arrests and detain people without access to legal counsel or a timely trial.48
It is also widely accepted that intelligence agencies should not “operate their own detention facilities” or “make use of any unacknowledged facilities operated by third parties.”49 These rules are “essential safe- guards against arbitrary detention by intelligence services and/or the possible development of a parallel



The NSS headquarters, known as the Blue House for its blue tinted windows, is where many detainees are held. Detainees at the Blue House are often held without access to family visits, a lawyer, adequate food, or healthcare. Illustration: The Sentry.

Silencing opposition
Despite the protections of free speech that South Sudan has signed on to,53 the NSS is frequently used to arrest and detain political opponents and dissidents for no more than expressing an opinion or their political affiliations. James Gatdet Dak, a spokesperson for the then-leader of the rebel opposition, Riek Machar, was unlawfully transferred from Kenya to South Sudan in November 2016.54, 55 Dak claimed that he was deceived by Kenyan security forces, who told him he was being taken to a meeting in the office of the president of Kenya, Uhuru Kenyatta, but who instead took him to a police station and informed him that he was being deported due to a Facebook post criticizing the South Sudanese government.56
Dak was held in “poor detention conditions” at NSS headquarters, spending nearly seven months in solitary confinement.57 International best practice is for security forces to require permits from other state organs, such as a court of law, for detention for more than two or three days.58 On August 23, 2017, he was charged under South Sudan’s 2008 Penal Code with inciting violence, “abetment,” treason, publishing or communicating false statements prejudicial to Southern Sudan, and undermining the authority of or insulting the president.59 Dak was sentenced to death after being found guilty of treason.60 Over six months later, he received a presidential pardon and was released after two years of detention.61

Kuel Aguer Kuel, the former governor of Northern Bahr el Ghazal state, was arrested by the NSS in August 2021 and is still detained for co-founding and signing several declarations by the People’s Coalition for Civil Action (PCCA), a group of reform activists.62, 63 After over a month in the Blue House, he was transferred to Juba Central Prison.64 He has been in detention for over a year, and family members say his health is deteriorating.65 Aguer’s PCCA colleagues were also accused, and they fled the country after his arrest.66

detention regime in which individuals could be held in conditions that do not meet international standards of detention and due process,” according to the UNHRC.50  The NSS operates three known facilities in Juba: the notorious Blue House, Riverside, and Hai Jalaba.51 In these facilities, detainees are often held without trial for a prolonged period with limited access to food, clean water, medical care, or communication with the outside world, according to Human Rights Watch, which has interviewed dozens of former detainees and reported extensively on the human rights abuses committed by the NSS.52

Kanybil Noon, a civil society activist, was detained by the NSS in May 2020 for a Facebook post criticizing Akol Koor Kuc.67 Youth activist Michael Wetnhialic was arbitrarily arrested and detained by the NSS in May 2019, having previously been arrested twice on suspicion of using Facebook to criticize the NSS and senior NSS officials.68 Joseph Bengasi Bakosoro, former governor of Western Equatoria state and leader of the South Sudan National Movement for Change, an opposition movement, was detained by the NSS in December 2015 without charges.69, 70 Bakosoro was held for several months without access to a lawyer or family visits.71, 72 According to his family, he was beaten during his detention.73 Bakosoro left the country following his release in 2016 and was the subject of a thwarted kidnapping attempt by South Sudanese security agents in 2018.74, 75 He returned to South Sudan in 2020.76
Controlling the narrative
Under international best practice, intelligence services “are prohibited from using their powers to target lawful political activity or other lawful manifestations of the rights to freedom of association, peaceful assembly and expression.”77 Freedoms of expression, association, and assembly are “fundamental to the functioning of a free society, including political parties, the media and civil society,”78 and should be given state protection from targeting by intelligence services.79 Member states of the African Union should create an environment that “will enable civil society and the media to hold governments to the highest levels of transparency and accountability.”80  A free media is crucial for a functioning democracy, with journalists operating as a mechanism to ensure government accountability.81 A decline in press freedom can be both a “symptom of and a contributor to” a decline in democracy.82 South Sudan’s Transitional Constitution enshrines the “right to freedom of the press and other media,”83 while the Media Authority Act is supposed to provide for the development of a “free and pluralistic media.”84 In practice, the press is shackled, and journalists report harassment and censorship from the very agency created to protect them.85. South Sudan ranks 128 out of 180 countries in terms of press freedom, according to Reporters Without Borders.86 The government severely curtails the activity of the press, according to a 2021 press release from the UN Commission on Human Rights.87 The head of the UN Mission in South Sudan has expressed concern to South Sudan’s leaders over the “increasingly restricted civic space, characterised by the detention of journalists.”88 According to a 2019 report by the UN Panel of Experts, the NSS is responsible for this restricted civic space.89 The NSS has taken the lead role in restricting the activities of anyone who is critical of the government, particularly journalists and civil society representatives, according to the report.90 These efforts are often led by Deng Tong Kenjok, an active NSS agent who ran the South Sudan Relief and Rehabilitation Commission, said the report.91.  Journalists in South Sudan are routinely threatened, harassed, and kidnapped by NSS agents, with impunity as “the rule in nearly all cases.”92 This severely limits their ability to inform the public, a South Sudanese journalist told The Sentry.93 Since South Sudan’s independence in 2011, 11 journalists have been killed; 10 have been killed since 2014.94, 95 Soon after independence, senior government officials made it clear that journalists were not allowed to interview opposition leaders.96 This is not confined to South Sudanese journalists; many international journalists are also harassed, intimidated, detained without cause, and expelled from the country.97, 98



In the first half of 2022 alone, there have been numerous incidents of human rights violations against journalists by the NSS. Eight reporters covering a press conference were detained by the NSS in February and had their recording devices and phones confiscated.99 Several of the journalists expressed concern that the NSS had extracted contacts and other information from their phones and that it was a threat to themselves and their families.100 A similar incident occurred in June, when the NSS detained at least nine journalists covering a Sudan People’s Liberation Movement in Opposition (SPLM-IO) press conference.101 One detained journalist said the security officers “threatened to deal with some of them.”102

News Corporation, with the business name Dawn Newspaper, is owned by Sudd Services and Investment and Emmanuel Monychol. Photo: South Sudan Ministry of Justice.  Such incidents have rippling consequences on the state of journalism in South Sudan. Given the dangers of the job and the extremely low pay,103 many journalists leave the profession to pursue safer and more lucrative jobs else- where.104, 105 The result is that “journalism in South Sudan often fails to live up to ethical standards,” according to the Ethical Journalism Network.106.  The NSS also poses a major barrier to the free operation of South Sudan’s press. The agency distorts and disrupts the flow of news in South Sudan by censoring the media, infiltrating news outlets, and engaging in outright violence and intimidation of reporters and editors. NSS agents are posted at Universal Printers, Garnish Printers, and RAK Media so that they can censor articles that they don’t ap- prove of right before printing.107 These three-printing companies are responsible for the production of all the country’s major newspapers.108
In the first quarter of 2022, the NSS removed dozens of articles from the Juba Monitor, according to their editor-in-chief.109 What’s more, the NSS has started making efforts to disguise the censorship: Censors used to leave blank space where material had been removed, but more recently have begun to enlarge other articles and advertisements or otherwise redesign newspaper pages to cover up their censorship, a South Sudanese journalist told The Sentry.110

The NSS has infiltrated several news outlets, as well. According to corporate records, the News Corporation is majority owned by persons who internal government documents reviewed by The Sentry identify as NSS agents.111, 112 The News Corporation, meanwhile, owns and runs the Dawn Newspaper, one of the four print newspapers in Juba.113, 114 Several influential NSS officials are also shareholders in The Telegraph Media Company Limited,115, 116 which ran a now-defunct newspaper directly tied to the Office of the President that was designed to “promote ‘national sovereignty.’”117, 118 The editor-in-chief was Emmanuel Monychol Akop, a major with the NSS according to internal documents reviewed by The Sentry,119 who has been the edi- tor-in-chief of the Dawn Newspaper since 2015.120, 121, 122, 123

Crushing civil society
The NSS also represses civil society groups, and civil society activists view the NSS as the biggest obstacle to their job, a civil society activist told The Sentry.124 The NSS infiltrates organizations, intimidates personnel, and creates obstacles to them doing their job.125 NSS harassment of journalists and activists limits their ability to criticize the government without fear of reprisal, and pressure for government accountability from civic groups and a free press is key to a thriving democracy.126, 127 The Office of the UN High Commissioner for Human Rights describes both activists and journalists as human rights defenders, stating that the ability of human rights defenders to operate freely is crucial “for making development and peace sustainable.”128
Human Rights Watch has reported extensively on how the NSS installs spies within nongovernmental organizations (NGOs) as a means of curbing dissent.129 The NSS infiltrates civil society groups and installs agents within their staff, a source with knowledge of multiple civil society groups told The Sentry.130 The NSS has also made it mandatory for civil society groups to request permission from the NSS prior to organizing events or meetings, and the agenda and participants of any such event must be approved by the NSS.131 The NSS has formed its own civil society groups to infiltrate the space, as well, and has recruited agents from existing civil society staff to spy on their colleagues.132 One civil society member was arrested by the NSS and detained without charge at the Blue House in order to intimidate other members of the organiza- tion, a colleague of the person arrested told The Sentry.133
The NSS has also imposed operational barriers to civil society organizations. The UN Panel of Experts de- scribed the NSS as being involved in the “extortion of humanitarian actors.”134 Deng Tong Kenjok, the former registrar general of the governmental Relief and Rehabilitation Commission and an NSS agent, according to internal documents reviewed by The Sentry,135 played a key role in pushing forward new and confusing policies on humanitarian activities and saw NGO fees raised in 2017.136, 137
In July of 2021, the NSS instructed the Bank of South Sudan, the country’s central bank, to order commercial banks in South Sudan to freeze the assets and bank accounts of civil society members carrying out work that the NSS did not agree with.138 The accounts of civil society members have still not been reinstated, according to a human rights analyst familiar with the matter.139

Economic Capture
Throughout South’s Sudan’s short history, public institutions, revenue streams, government contracts, and sometimes entire sectors have been captured by politically connected elites who seek to line their pockets at the expense of the public.140, 141, 142 The NSS plays a critical role in the capture of public institutions and revenue streams in South Sudan. Published reports, correspondence, eyewitness accounts, and corporate records indicate that the NSS has a broad set of tools and tactics for infiltrating and influencing public and private sector institutions for political and economic gain.
To map the extent of NSS commercial activities, The Sentry compiled a list of 684 members of the NSS, drawn from a roster of NSS officers included in a 2019 report by the UN Panel of Experts on South Sudan in 2019, as well as other official documents listing NSS personnel.143, 144, 145 The Sentry cross-referenced names on this list with corporate records filed with South Sudan’s Ministry of Justice and found that 50 NSS officers on the list have, between them, held stakes in 125 companies operating across South Sudan’s economy, including in oil, mining, agriculture, aviation, telecommunications, publishing, logistics, import and export, and procurement.
NSS personnel have occupied key posts in state institutions, including the National Revenue Authority (NRA) and the national oil company, Nile Petroleum Corporation (Nilepet).146, 147, 148, 149 The NSS also has a role in approving private company operations in the mining and security sectors, which in practice makes it a gatekeeper of these sectors.150, 151
Security agents have been able to quietly embed themselves in various commercial institutions and business sectors, as the example of The Dawn Newspaper illustrates. These companies are often jointly owned or operated with other Kiir regime insiders, reinforcing a collective interest in maintaining the status quo. Taken together, these commercial operations provide the NSS with both the incentive and the means to resist oversight and regulation, as their commercial operations grant opportunities for enrichment and the revenue needed to operate autonomously, lessening the organization’s dependence on budgetary funding.  While government officials are legally required to declare their assets,152 there is no such requirement for members of the NSS. NSS members have been able to sidestep, undermine, intimidate, or eliminate individuals and institutions seeking to scrutinise their activities, penalize personnel involved in misconduct, or otherwise challenge NSS authority.153, 154, 155 NSS access to off-budget finances and diverted revenues undermines any attempt at scrutiny or operational oversight. When one NRA official refused to grant favours to regime insiders or ignore blatant misconduct, NSS officers appeared in his office to harass and intimidate him, and he was summoned to the Blue House to explain his actions before the NSS Economic Commit- tee.156
Oil sector
Oil is the most profitable sector in South Sudan, and revenue from crude oil sales accounts for more than 90% of the government’s operating budget.157 Inadequate due diligence in the oil sector has allowed for politically connected elites, including the NSS,158 to capture portions of the market and the means to make substantial profits.159, 160 The NSS benefits from oil revenue, has been involved in diverting revenue from

national oil company Nilepet,161, 162 and has received “in-kind donations” for providing security for oil fields that amount to “sizeable non-monetary and off-budget forms of payment.”163, 164. This is just the tip of the iceberg. The NSS is involved in every decision made in the oil sector, a source with years of experience in the oil sector told The Sentry.165 The NSS has an interest in hundreds of oil companies registered in the names of unaffiliated civilians to cover its tracks, said the source.166 The vast majority of government contracts in the oil sector are awarded to these companies, the source further alleges.167. The Sentry found that at least 10 private oil and petroleum companies registered in South Sudan have NSS shareholders.168 Some of them have been involved in multimillion-dollar corruption scandals,169 while others have influence in local supply chains relied on by airlines, NGOs, and the UN.170 A source in the oil industry told The Sentry that the NSS is also involved in ensuring that all information regarding corruption and environmental damage within the sector is kept hidden.171. The NSS has “blatant control over the State-owned oil company Nilepet,” according to the UNHRC.172, 173 The involvement of the NSS in Nilepet, a company integrated into the global oil market with annual revenues in the hundreds of millions, is of particular concern, as it gives the NSS the ability to rob the people of South Su- dan by withdrawing money to fund its own projects. Akol Koor Kuc, director general of ISB, was appointed by Kiir to Nilepet’s board in 2021.174, 175 Kuc had held a “secret seat” on the Nilepet board from 2014 to 2020,176 and he was “highly influential in deciding how the company and its resources were deployed,” according to the UNHRC.177, 178 For instance, in 2016, then-Minister of Petroleum and Mining Stephen Dhieu Dau wrote to Nilepet to ask for $1.5 million to cover security expenses, including costs incurred by ISB personnel.179 Dau’s letter cites an earlier letter signed by Kuc, suggesting that Kuc had sway over Nilepet expenditures.180, 181.  In fact, millions of dollars of Nilepet’s oil revenues have been diverted to the security services, who have used the money to fund militias and purchase weapons and other military equipment to pursue a devastating civil war.182, 183 In 2015, much of Nilepet’s revenue was used to fund soldiers stationed in conflict areas near oil fields.184, 185 There were around 100,000 active soldiers in the field, but funds were reportedly claimed for over 200,000 personnel, with wages for the “ghost” soldiers allegedly diverted into the pockets of more than 700 generals.186 The same year, Nilepet purchased small arms and ammunitions that were then transferred by Kuc’s ISB to the Padang Dinka, one of the local militias recruited to fight alongside the government.187 The United States Department of State described the fighting in 2015 as “some of the worst violence of the conflict” in South Sudan, with 300,000 people in Upper Nile driven from their homes and many subjected to “rape, extrajudicial killings … and denial of humanitarian access.”188, 189, 190. Nilepet is a shareholder in all three of the joint ventures responsible for oil production in South Sudan: Dar Petroleum Operating Company (DPOC), Greater Pioneer Operating Company (GPOC), and Sudd Petro- leum Operating Company (SPOC), giving it influence throughout South Sudan’s oil sector.191 It is also a shareholder in Eastpet Oil Services Limited, which provides field studies and technical services, and Nile Drilling Services Company Limited, which provides “drilling and associated integration services.”192, 193, 194
Manasa Machar Bol, an NSS officer and the Director of Oil Security in the Ministry of Petroleum,195, 196, 197 has been a beneficial owner of two oil companies: Transco Energy and Kush Petroleum.198, 199 Bol’s ownership in Kush Petroleum was through Nile Investment Partners.200 Kush Petroleum supplies petroleum for numerous companies, airlines, and NGOs, including the UN World Food Programme.201 In 2014, it received two letters of credit totalling over $2 million to supply fuel and petroleum products.202, 203, 204 Oil export data reviewed
Profitable Connections
National Security Service officials hold stakes in a number of oil companies, and the director-general of the Internal Security Bureau of the National Security Service, Akol Koor Kuc, sits on the Nile Petroleum Corporation board.


by The Sentry could only account for approximately $150,000 worth of fuel being imported by Luqman Oil, the company that Kush Petroleum contracted with for delivery.205, 206 Bol has denied having ownership in or knowledge of the activities of either company. 207. The Sentry’s investigation uncovered links between NSS involvement in the oil sector and Kiir himself. NSS Brigadier General Akot Lual Arech is a shareholder in Conex Energy Company and has also held shares in South Gas Energy Company.208, 209, 210 Arech was Kiir’s personal secretary,211 and he told The Sentry that the president calls him “uncle,” an indication both of respect and of a community relationship.212 Arech’s fellow shareholders in Conex Energy include Kiir’s granddaughter, and until August 2014, the president’s daughter, Adut Salva Kiir, owned shares in the company.213. The NSS also performs a security function in the oil sector. An April 2020 report from a UN Panel of Experts noted that the NSS materially benefited from protecting oil fields.214 Additionally, the NSS provides security staff for one of South Sudan’s largest private oil companies, Trinity Energy, The Sentry found. Trinity Energy has numerous NSS officers on payroll listed as “security.”215 When asked about this, Ann Kathure Rutere, a former Trinity Energy director, told The Sentry that all companies in South Sudan have personnel from the NSS or “relevant institutions attached.”216
Financial sector
The NSS is also involved in critical aspects of the financial sector, from taxation and revenue collection to banking and foreign exchange. Its capture of revenue streams and government institutions allows the NSS to operate without concern for accountability and ensures a constant source of funding for their operations.
The NSS poses the biggest obstacle to government revenue collection, according to a source in South Sudan familiar with the process. Former NRA director Olympio Attipoe was often asked to grant powerful people favours or tax exemptions or to look the other way when taxes were not applied, he told The Sentry. If he refused, NSS officers were sent to his office to harass and intimidate him into action.217 Despite Attipoe’s efforts to improve transparency at the NRA, the NSS still managed to secure preferential treatment—tax exemptions on petroleum imports—during his tenure.218
Attipoe was dismissed from his role at the NRA by the minister of finance in August 2019 for allegedly violating financial policies,219 but some South Sudanese believed that it was due to his efforts to curb corruption.220, 221 After he was fired, the former head of finance for the NSS, Erjok Bullen Geu, was the acting NRA commissioner-general.222 In 2020, the UN Panel of Experts on South Sudan reported that the transparency of non-oil revenue collection had declined since Attipoe’s dismissal, noting that Geu had facilitated broad tax import exemptions and curtailed transparent reporting on revenue collection.223 Geu also made several suspicious bank transfers during his tenure as acting NRA head, according to reporting by Eye Radio, which cites bank documents showing that Geu approved the transfer of taxpayers’ money from an NRA-affiliated bank account.224. The Sentry’s review and analysis of corporate records found that NSS members have held shares in two foreign exchange bureaus: Alok Forex Bureau and Ayen Model Forex Bureau.225, 226 Foreign exchange bureaus can help facilitate quick access to central bank-distributed US dollars, an extremely valuable asset in a country with a weak local currency and a gulf between the official dollar exchange rate and that of the black

market. NSS Brigadier General and Kiir associate Akot Lual Arech is a shareholder in Alok Forex Bureau, alongside his wife, Mary Kuel Arech, as well as Emmanuel Akol Ayii Madut, and Garang Deng Aguer.227
The holdings in foreign exchange bureaus are not the only NSS connections to South Sudan’s banking sec- tor. NSS Brigadier General Napoleon Adok Gai is a shareholder in Harvest Trade and Development Bank.228, 229 Gai is also currently the director-general of the National Communications Authority and has in the past been accused of “illegally” and “unlawfully” monitoring the phone communications of those suspected to be working against the government.230,

International Connections. In South Sudan, international individuals and entities have been among the major facilitators in schemes to misappropriate government spending,232 and The Sentry found that the NSS has significant international connections that may enable its operations in South Sudan and abroad. International enablers often provide access to global networks and connections, as well as to the international financial system to help corrupt individual and entities syphon their ill-gotten funds away from the eyes of the public.233 In the case of the NSS, those international entanglements include joint shareholdings, business relationships with international- al private companies, connections with regional intelligence agencies, and even properties and citizenships in the US.
There are multiple companies with National Security Service officials as shareholders that also have international shareholders. Nationality Kenya. 
Uganda Australia
United Kingdom Eritrea
Number of Shareholders
10 7 7 5 4 4 4 3
United States Ethiopia Egypt Germany
Italy Somalia South Africa Turkey
Number of Shareholders
3 2 1 1 1 1 1 1
Source: The Sentry.

Of the 125 companies revealed by The Sentry to have NSS shareholders, 40 have also had international shareholders. Shareholders from Sudan, Kenya, and Uganda are the most common among those who have held shares in companies alongside NSS staff, but there are also shareholders from the US, Australia, Britain, China, Eritrea, Ethiopia, India, Germany, Italy, South Africa, and Turkey.234 This illustrates the extent to which international actors have been tied to or appeared to be complicit in the NSS’s economic power.  The NSS has used its international connections, especially with neighboring countries, in support of the commission of egregious human rights abuses.235 In one case, the ISB reportedly worked with the Kenyan intelligence service to kidnap human rights lawyer Dong Samuel Luak and opposition official Aggrey Idri from.  The Internal Security Bureau of the National Security Service wrote
a letter to the South
Sudan Ministry of Justice to incorporate Sudd Security Service and to clarify that it serves a different purpose than another company with a similar name that they incorporated. The letter states that both companies are managed by the National Security Service. Photo: South Sudan Ministry of Justice.

Nairobi.236, 237 Colonel John Top Lam, a South Sudanese intelligence officer, claimed in a recorded phone
call that he had direct knowledge of the abduction.238 Lam also solicited a $10,000 bribe from a confidant of
both men to secure his release, apparently implying that the money would be given to the head of Kenya’s
intelligence service, Major-General Philip Wachira Kameru.239 After being kidnapped from Kenya, Dong and
Aggrey were reportedly both executed in an NSS facility.240, 241, 242 Lam was designated for sanctions by the
US Department of the Treasury, along with several others, for his involvement in the kidnapping of the two men.243, 244
The NSS has also formed partnerships with private international businesses. In late 2014, National Security Minister Obuto Mamur Mete, the minister in charge of the NSS who is answerable to the president, request- ed a South Sudan operating license for the South African company, Vukani Aviation, owned by South African Nhlanhla Dube, citing “strategic security programs.”245 Vukani Aviation was incorporated in South Sudan in December 2014 with Mamur Mete as a shareholder.246 The agreement stated that Vukani would operate a charter plane and two helicopters in South Sudan.247 In the months following the formation of this partnership, Vukani became entangled in scandal in South Africa. Members of the South African Parliament and other critics claimed that the company was “putting lives at risk at a government-funded flight training program run at a flight school partially owned by Dube.”248 Dube denied these claims, reportedly telling media outlets that the accusations were “engineered by people with an ulterior motive.” 249, 250 The flight school, South Africa Training Academy, was shut down after the South African Civil Aviation Authority visited the site.251
Through Sudd Security, a company owned by the NSS, the NSS formed partnerships with other private com- panies owned by non-South Sudanese individuals, according to corporate records reviewed by The Sentry. These include Deway Security, a partnership with a Chinese private security firm of the same name, and Pinnacle Security, a partnership with a Ugandan private security firm.252, 253, 254 Pinnacle Security responded to The Sentry’s request for comment and denied that the company had provided services to or entered into a joint venture with Sudd Security.255 Another company based in Seychelles reportedly sold the NSS $264 million worth of heavy weapons, small arms, and ammunition, according to a UN Panel of Experts report.256
In addition to the NSS’s range of international shareholders and connections as an agency, two NSS officers also have US addresses, which likely provide them with access to the US financial system and subject them to US law.257, 258 Jalpan Obyce, the director of legal affairs of the ISB and an NSS brigadier general, 259, 260 has been a US citizen since at least 2012, when he was registered to vote, and has owned property in Texas since 2003.261, 262 Akot Lual Arech, a former secretary of Kiir and reportedly an NSS brigadier general, has been a US citizen since 2002 and has owned property in the US since at least 1995.263, 264, 265, 266, 267 Arech ran a nonprofit called JumpStart South Sudan registered in Kansas City, Missouri, that billed itself as collecting money for humanitarian aid for the Bahr al Ghazal region of South Sudan.268, 269 He was even received by officials at the White House in 2009.270 In a letter sent by Arech to The Sentry in response to our findings, he denied any involvement in the NSS and stated that he was added to the UN Panel of Experts list as a result of his proximity to the president.271

The Consequences of an Unchecked Security Service
The unchecked activities of the NSS have devastating consequences for a country that has suffered close to a decade of civil war and an economic crisis from which there has been little respite. NSS repression ensures that the state’s failings—and the self-serving actions of the elite—go unchallenged and thus perpetuate the cycle of oppression. The rights of citizens, the media, and political opponents are severely suppressed. Freedom of speech and freedom of the press have been brutally curtailed, while punishments for opposing the government are meted out without regard to constitutional rights, national law, or basic standards of due process. Civil society and political plurality have been forcefully or surreptitiously hollowed out, and those organizations that endure do so under persistent existential threat.
The NSS penetration into the economy makes these trends still more concerning. The NSS presence in the oil sector, key financial institutions, and commercial operations throughout the economy embeds the agency in South Sudan’s wealth and power structures in a way that, if left unchecked, will perpetuate, if not deepen, its influence. If this happens, the human rights abuses and unconstitutional behaviors that already endanger the lives and freedoms of South Sudan’s citizens and that have helped create a monolithic and kleptocratic political culture, will continue.
The often-intrusive powers of national security and intelligence operations require comprehensive oversight mechanisms to prevent their abuse. International best practice compiled by the UNHRC states that “an effective system of intelligence oversight includes at least one civilian institution that is independent of both the intelligence services and the executive” and that such oversight institutions should “have the power, re- sources and expertise to initiate and conduct their own investigations, as well as full and unhindered access to the information, officials and installations necessary to fulfil their mandates.”272
Well-functioning systems also feature a role for oversight institutions in assessing the performance of in- telligence services, including “examining whether intelligence services make efficient and effective use of the public funds allocated to them.”273 South Sudan’s legislation on NSS governance does little to ensure independent oversight of the organization. The National Security Service Act of 2014 states that the agency will be headed by the minister of national security service in the Office of the President,274 making the NSS directly responsible to the executive. The minister of national security service is “answerable to the Presi- dent,” the act stipulates.275
The National Security Service Act includes oversight mechanisms that are both weak and vague. The minis- ter of national security service must submit an annual report to parliament “on matters related to the perfor- mance of the Service,” it says,276 without providing any detail as to what this report should include, what basis on which the agency’s performance should be assessed, or what recourse parliament might have when it deems that the NSS has failed to deliver an acceptable level of performance.
The act provides for the establishment of a Complaints Board to which “any person” aggrieved by the actions of an NSS staff member “may make a complaint in respect thereof to the Board in such a manner as may be prescribed.”277 Eight years later, there is neither evidence of an operational Complaints Board, nor of any action having been taken to “prescribe” the manner in which complaints to the NSS might be made. Even if such a complaints body is constituted, the National Security Service Act fails to provide for its independence from the executive. International best practice suggests that complaints bodies should be “independent of

the intelligence services and the political executive,”278 but the National Security Service Act goes the oppo- site way, stipulating that those members of the Complaints Board “shall be appointed by the President.”279
The cycle must be broken. The scope of the NSS must be confined to its constitutional role as a bulwark against genuine threats to the state. Institutions of state must be returned to their proper functions as guard- ians of citizen rights. The media and civil society must be allowed to function free from interference and fear. Due process must be restored to the legal system, and basic human rights must be upheld by the penal system. The private sector must be allowed to function free from state influence or control.
The NSS must undergo significant reforms to transform into an intelligence gathering agency that will protect the people of South Sudan, rather than oppress them.

Dismantling the National Security Service’s hold over the South Sudanese economy is a prerequisite for securing any kind of peace and human rights in South Sudan. The Sentry makes the following recommen- dations for how governments and the private sector can disrupt the global financial networks that make it possible for the NSS to fund their human rights abuses through illicit revenue flows.  The United States, United Kingdom, European Union, Canada, and Australia
Impose targeted network sanctions. The US, UK, EU, Canada, and Australia should urgently investi- gate and, if appropriate, impose coordinated and targeted network actions on the individuals and entities described in this report, particularly the NSS owned or controlled commercial enterprises, as well as Akol Koor Kuc, Jalpan Obyce, Akot Lual Arech, and their enablers and support networks, pursuant to their Global Magnitsky-style or South Sudan-specific sanctions authorities.
Issue a public advisory to financial institutions warning about the money laundering risks associat- ed with South Sudan. The EU, Canada, and Australia should mirror the US Financial Crimes Enforcement Network’s (FinCEN) anti-money laundering advisories on political corruption risks in South Sudan and the UK’s National Crime Agency Amber Alert on illicit finance risks related to South Sudan to warn financial institutions in their jurisdictions about these risks and issue guidance on taking risk-based steps to identify and limit any exposure they may have to funds and other assets associated with South Sudanese corruption and human rights abuses.280, 281 This will allow banks to allocate their resources toward identifying suspicious behavior emerging from South Sudan.
Pursue asset seizure orders on criminally derived assets. Dedicate law enforcement resources to inves- tigating the proceeds of human rights abuses, state corruption, and violence in South Sudan and seeking asset seizures abroad where these perpetrators own property.
Investigate the parties and transactions revealed in this report and enforce relevant laws. The US Department of Justice, in particular the Human Rights and Special Prosecutions Section, should investigate the US persons named in this report and pursue criminal measures under relevant laws.
Support journalists, activists, whistleblowers, and civil society organizations. Support, including fi- nancially when appropriate, South Sudanese and international journalists, activists, whistleblowers, and civil society organizations that seek to unveil perpetrators of human rights abuses and corruption in South Sudan. Think long-term and invest in the organizations and individuals that will contribute meaningfully to securing peace, human rights, and a transparent economy in South Sudan.
Kenya, Uganda, and other regional countries
Enact and enforce sanctions against South Sudanese profiteers and their international collabora- tors. Implement UN sanctions against UN-listed South Sudanese officials, including by enforcing travel bans and freezing physical property, such as homes that should be considered “financial assets” of the sanctioned person


Issue warnings on the money laundering risks associated with South Sudanese corruption. Financial regulators, including the central bank and financial intelligence units in Kenya and Uganda, should issue circulars to the country’s financial institutions warning of the risks of dealing with South Sudanese politically exposed persons (PEPs), especially those with connections to the NSS as identified in this report. South Sudanese corruption-related money flows have often found a home in or flowed through Kenya and Uganda, creating risks of money laundering. The illicit flows will continue to be a threat to the integrity of financial systems and need to be urgently disrupted. These steps are particularly pertinent given Kenya’s recent Eastern and Southern Africa Anti-Money Laundering Group mutual evaluation of its anti-money laundering and countering the financing of terrorism (AML/CFT) framework and Uganda’s ongoing efforts to end the country’s “grey listing” for shortcomings in its AML/CFT rules and regulations. This will also allow domestic banks to identify suspicious transactions and report these to their local financial intelligence units. The banking associations of the respective countries should similarly work with their member banks to assist in addressing these risks.
South Sudan
Strengthen the AML/CFT regime. South Sudan should fulfil its June 2021 political commitment to work with the Financial Action Task Force (FATF) to strengthen the effectiveness of its AML/CFT regime.282 The FATF has recently noted that South Sudan has made limited progress on this front.283. Empower and resource oversight institutions. South Sudan has already developed much of the institutional infrastructure essential for accountability and good governance. However, a lack of independence and human and financial resources hamstrings key oversight institutions such as the Anti-Corruption Commis- sion and the National Audit Chamber. The government should take steps to ensure the proper disbursement of funds promised to the Anti-Corruption Commission and other oversight institutions.284 The government should also pass laws penalising officials who fail to comply with their obligation to declare their wealth under the Asset Declaration Management System. The government should implement measures to give the An- ti-Corruption Commission the right to prosecute transgressors. Lastly, South Sudanese leaders should take steps to ensure that various government agencies comply with the auditor general’s investigations, making cooperation mandatory, since a refusal to cooperate has long hampered probes.
Stop the NSS’s illegal activities. South Sudan’s government should immediately close all NSS detention centers and ensure that the NSS releases all detainees who have not been charged with a crime or given a fair trial.
End NSS access to off-budget revenue. The NSS’s off-budget sources of funding enable impunity man- ifested in egregious human rights abuses and the undermining of the peace agreement. Immediate steps should be taken to stop off-budget sources of revenue for the NSS. The first step is to empower the Com- mittee for Security and Public Order in the National Legislative Assembly, in conjunction with the Public Accounts Committee, to demand a regular and timely audit of the NSS budget and strengthen avenues for oversight on NSS expenditure. The National Legislative Assembly should enforce the Civil Service Act, especially the sections that deal with conflict of interest and that are designed to deter public officials from engaging in ventures that generate off-budget revenue for individuals, their business entities, and the gov- ernment departments that employ them.

Clarify existing laws. Currently, South Sudan’s constitution fails to clearly identify conflicts of interest. Section 120 requires “all executive and legislative constitutional office holders, Justices, and senior Civil Service officials at all levels of government … (to) make confidential declaration of their assets and liabilities including those of their spouses and children in accordance with the law.” In addition, these individuals are barred from engaging in private business.285 High-ranking NSS officials should face the same restrictions, with enforcement by an ombudsman with oversight powers. South Sudan should pass legislation clarifying which roles or types of roles fall under the term “constitutional office holder.”286 The conflicts of interest pro- visions contained within the constitution should be clarified and expanded to include all senior NSS officials.
Ensure an investigation into allegations of NSS abuse. There should be an immediate, transparent, and impartial investigation into all allegations of NSS misconduct, including allegations of torture and sexual vi- olence. The government should ensure that those NSS officials implicated in such crimes are appropriately prosecuted.
Amend the National Security Service Act. The National Security Service Act should be amended to limit the NSS’s role in intelligence gathering and analysis and remove its powers of detention and its ability to collect personal communications data.
Create a public register disclosing shareholders and beneficial owners. Key company ownership in- formation remains inaccessible to the public. This veil of secrecy has served to hide the extent of the NSS’s commercial activities. A public online register—free to access, updated in real time, and with a verification mechanism—would serve as a vital tool to anti-corruption and human rights advocates, civil society, and political parties in demanding accountability from government officials. Moreover, it would demonstrate the government’s commitment to building a more transparent system, a key step in inviting legitimate investors to do business in South Sudan.
Financial institutions
Conduct enhanced due diligence, monitoring, screening, and transaction reviews. Financial institu- tions should take measures to identify accounts held or beneficially owned by members of the NSS, other senior South Sudanese PEPs, and the 125 companies revealed by The Sentry to have NSS shareholders. They should carry out a comprehensive assessment to identify their broader international networks and determine the measures needed to mitigate the risks involved in such accounts and customer relationships. Financial institutions should also undertake enhanced screening, ongoing monitoring, and transaction re- views to identify, investigate, and report potentially suspicious financial activity related to South Sudan, es- pecially with respect to international networks profiting from such activity. An effort should be made to avoid wholesale de-risking and ensure that legitimate economic resources and humanitarian funding continue to flow into the country.
South Sudan National Security Service Act, 2014, provisions on crimes and offences against the state287
7. Crimes and Offences against the State
For the purpose of this Act, the following shall constitute crimes and offences against the state: (1) Crimes and offences against the state as provided in the Penal Code.
(2) Any activity:
(a) relating to espionage, sabotage, terrorism or subversion or intention of any such activity directed against or detrimental to the interest of South Sudan and includes any other activity performed in conjunction with any activity relating to espionage, sabotage, terrorism or subversion;
(b) directed at undermining or intended to bring about the destruction or overthrow of the constitu- tionally established system of the Government by unlawful means;
(c) any act or threat of violence or harm that is directed at or intended to achieve, bring about or pro- mote any constitutional, political, industrial, social or economic objective or change in South Sudan, including any conspiracy, incitement or attempt to commit any such threat or act; and
(d) any foreign-influenced activity within or outside which is related to South Sudan that is: (i) detrimental to the interests of South Sudan; and
(ii) clandestine or deceptive or involves any threat whatsoever to the State or its citizens or any other person resident in South Sudan;
(e) to bring about destruction to industrial installations and physical infrastructures in South Sudan and
(f) Any act of spying or attempting to spy against the State.


. 1 Human Rights Watch, “‘What Crime Was I Paying For?’: Abuses by South Sudan’s National Security Service,” December 14, 2020, available at: sudans-national-security-service#_ftn223
. 2 See note 1.
. 3 South Sudan, The Transitional Constitution of the Republic of South Sudan, 2011, pp. 5-10.
. 4 The Sentry interview with a South Sudanese civil society activist who has been active in the civil society sphere in the 
country for more than a decade, March 2022.
. 5 The Sentry interview with a South Sudanese journalist, January 2022.
. 6 United Nations Security Council, “Final report of the Panel of Experts on South Sudan,” S/2017/326, April 
13, 2017, p. 43, available at: 
. 7 See note 1.
. 8 See note 3.
. 9 UNICEF, “Education in South Sudan,” 2021, available at: 
. 10 Onen Walter Solomon, “South Sudan’s Healthcare Remains Inadequate, Officials Say,” VOA News, July 5, 2021, available at: html
. 11 United Nations Mission in South Sudan, “UNMISS Engineers Renovate Abiemnhom Hopital to Support the Fight Against COVID-19,” May 7, 2020, available at: hospital-support-fight-against-covid-19
. 12 UNICEF South Sudan, “Rain, Roads and Checkpoints,” January 23, 2018, available at: southsudan/stories/rain-roads-and-checkpoints
. 13 OXFAM International, “Clean Water Runs Dry in Juba, South Sudan,” available at: water-runs-dry-juba-south-sudan#:~:text=In%20South%20Sudan%2C%20only%2055,to%20safe%20water%20 even%20further
. 14 The World Bank, “Access to Electricity (% of Population) – South Sudan,” available at: indicator/EG.ELC.ACCS.ZS?locations=SS
. 15 See note 1.
. 16 The Sentry interview with a South Sudanese civil society activist who has been active in the civil society sphere in the 
country for more than a decade, March 2022.
. 17 Deng Ghai Deng, Manyang David Mayar, and Michael Atit, “Reporting Under Attack in South Sudan,” VOA News, May 
4, 2022, available at:
. 18 Ordinary Resolution, Sudd Services and Investment Company Ltd, June 13, 2016.
. 19 See note 1.
. 20 See note 1.
. 21 Amnesty International, “South Sudan: ‘These Walls Have Ears’: The Chilling Effect of Surveillance in South Sudan,” 
February 2, 2021, available at:
. 22 See note 1.
. 23 See note 17.
. 24 See note 3, p. 61.
. 25 See note 3, p. 61.
. 26 See note 6.
. 27 United Nations Security Council, “Final report of the Panel of Experts on South Sudan submitted pursuant to paragraph 
19(e) of resolution 2428 (2018),” S/2019/301, April 9, 2019, pp. 17, 52, available at: https://www.securitycouncilreport. 
. 28 The Sentry interview with a South Sudanese civil society activist who has been active in the civil society sphere in the country for more than a decade, March 2022.
. 29 See note 27, p. 17.

. 31 Brian Adeba, “Oversight Mechanisms, Regime Security, and Intelligence Service Autonomy in South Sudan,” Intelligence and National Security, 35.6, April 26, 2020, p. 8, available at: 24
. 32 Ibid.
. 33 After Malong was fired as army chief of staff in 2017, he fled into exile. In 2018, he announced the formation of a rebel 
movement to lead the nation to peace, saying Kiir could not be trusted to do so. For more information, see:
The Defense Post, “Former South Sudan Military Chief Paul Malong Launches New Rebel Group,” April 9, 2018 available at: Sudan Tribune, “S. Sudan Rebels Threaten Military Operations Against Government,” August 15, 2022, available at:
. 34 Organization of African Unity (now the African Union), “African (Banjul) Charter on Human and People’s Rights,” June 27, 1981, p. 4, available at:
. 35 Ibid., p. 2.
. 36 See note 1.
. 37 See note 17.
. 38 Human Rights Council, “Human Rights Violations and Related Economic Crimes in the Republic of South Sudan,” A/ 
HRC/48/CRP.3, September 23, 2021, p. 6, available at: 
. 39 United Nations General Assembly Human Rights Council, “Compilation of Good Practices on Legal and Institutional Frameworks and Measures That Ensure Respect for Human Rights by Intelligence Agencies While Countering Terrorism, Including on Their Oversight,” May 17, 2010, p. 7, available at:
. 40 Ibid., p. 12.
. 41 African Union, “2nd Africa Forum on Security Sector Reform,” October 22-24, 2018, on file with The Sentry.
. 42 South Sudan, National Security Service Act, 2014, p. 12.
. 43 See Annex 1 for the “Crimes and Offences Against the State,” as defined in Section 7 of the National Security Act, 
. 44 See note 39, p. 24.
. 45 See note 39, pp. 24-25.
. 46 See note 34, p. 3.
. 47 See note 34, p. 3.
. 48 See note 1.
. 49 See note 39, p. 26.
. 50 See note 39, p. 26.
. 51 See note 1.
. 52 See note 1.
. 53 See note 34, pp. 2, 4.
. 54 Amnesty International, “Urgent Action: Man Held in Poor Conditions, Denied Family Visits,” AFR 65/7283/2017, October 
19, 2017, available at:
. 55 Denis Dumo, “South Sudan Sentences Rebel Leader’s Spokesman to Death,” Reuters, February 12, 2018, available 
. 56 The Sentry interview with James Gatdet Dak, April 2019.
. 57 See note 54.
. 58 European Commission for Democracy Through Law (Venice Commission), “Internal Security Services in Europe,” 
March 7, 1998, p. 10, available at:
. 59 See note 54.
. 60 See note 55.
. 61 Sudan Tribune, “South Sudanese Authorities Release SPLM-IO’s James Dak,” November 2, 2018, available at: https://
. 62 Human Rights Watch, “South Sudan: Government Critics Held on Dubious Charges,” March 1, 2022, available at:
. 63 Kafuki Jada, “One Year Later, Kuel Aguer Appears in Court,” Eye Radio, October 3, 2022, available at: https://www. 

64 See note 62.
65 See note 63.
66 See note 63.
67 Amnesty International, “South Sudan: Member of Peace Agreement Body Detained: Kanybil Noon,” June 23, 2020,
available at:
68 Amnesty International, “South Sudan: Detained Youth Activist Denied Family Visits: Michael Wetnhialic,” July 10, 2019,
available at:
69 Amnesty International, “South Sudan: Former Governor Detained Without Charge: Joseph Bangasi Bakosoro,”
February 10, 2016, available at:
70 Radio Tamazuj, “Bakosoro Forms Political Movement,” January 7, 2017, available at:
71 Sudan Tribune, “Amnesty International Calls for Release of All in NSS Detention in Juba,” April 30, 2016, available at:

Amnesty International calls for release of all in NSS detention in Juba

72 Radio Tamazuj, “Bakosoro Held for Third Day Without Access to Lawyer: Family,” December 24, 2015, available at:
73 See note 69.
74 Sudan Tribune, “Former W. Equatoria Governor Survive Kidnap Attempt in Uganda,” January 18, 2018, available at:
75 Jale Richard, “Bakosoro Returns Home After Five Years,” Eye Radio, December 20, 2020, available at: https://www.
76 Ibid.
77 See note 39, p. 13.
78 See note 39, p. 13.
79 See note 39, p. 13.
80 African Union, “African Union Convention on Preventing and Combating Corruption,” July 11, 2003, on file with The
81 United Nations, “Free Press ‘a Cornerstone’ of Democratic Societies, UN Says,” May 3, 2021, available at: https://news.
82 Sarah Repucci, “Media Freedom: A Downward Spiral,” Freedom House, 2019, available at:
83 See note 3, p. 8.
84 South Sudan, Media Authority Act 2013, p. 1, on file with The Sentry
85 VOA News, “Journalists Report Harassment From South Sudan’s Media Authority,” September 10, 2019, available at:
86 Reporters Without Borders, “South Sudan,” available at:
87 United Nations Human Rights Office of the High Commissioner, “Human Rights Council Discusses Situation of Human
Rights in South Sudan, Cambodia and Sudan Under Its Agenda Item on Technical Assistance and Capacity Building,” Press Release, October 6, 2021, available at: discusses-situation-human-rights-south-sudan-cambodia
88 United Nations Human Rights Office of the High Commissioner, “Human Rights Council Discusses Situation of Human Rights in South Sudan, Cambodia and Sudan Under Its Agenda Item on Technical Assistance and Capacity Building,” Press Release, October 6, 2021, available at: discusses-situation-human-rights-south-sudan-cambodia
89 See note 27, p. 17. 90 See note 27, p. 17. 91 See note 27, p. 17. 92 See note 86.
93 The Sentry interview with a South Sudanese journalist, January 2022.
94 Gai Alier John, “Impunity and Intimidation: The Muzzling of Independent Journalism in South Sudan,” Ethical
Journalism Network, available at: 95 See note 86.
96 Amnesty International, “The Price of Silence,” July 2014, available at:

. 97 Ibid.
. 98 Reports Without Borders, “South Sudan Expels Another Journalist, Second in Two Weeks,” November 7, 2019, 
available at:
. 99 Committee to Protect Journalists, “South Sudanese Security Forces Threaten, Briefly Detain 8 Journalists,” 
February 25, 2022, available at: 
. 100 See note 99.
. 101 Sudans Post, “9 Journalists Including Sudans Post Reporter Briefly Detained by NSS for Covering SPLM-IO Press 
Conference,” June 13, 2022, available at: 
. 102 Ibid.
. 103 Journalists working for the Juba Monitor, South Sudan’s leading newspaper, earned about $45 a month in 2017, 
according to Oliver Modi, the chairman of South Sudan Union of Journalists. See:
Parach Mach, “South Sudan Media in Tatters as Economic Crisis Deepens,” Anadolu Agency, September 1, 2017, available at:
. 104 See note 94.
. 105 Viktorija Mickute, “Being a Journalist in South Sudan,” Al Jazeera, December 18, 2018, available at: https://www.
. 106 See note 94.
. 107 The Sentry interview with a South Sudanese journalist, January 2022.
. 108 The Sentry interview with a South Sudanese journalist, January 2022.
. 109 See note 17.
. 110 The Sentry interview with a South Sudanese journalist, January 2022.
. 111 South Sudan Ministry of Justice, Ownership Change for News Corporation Ltd, June 13, 2016.
. 112 NSS official list, on file with The Sentry.
. 113 South Sudan Ministry of Justice, Memorandum and Articles of Association of News Corporation Ltd., December 1, 
. 114 See note 111.
. 115 South Sudan Ministry of Justice, Memorandum and Articles of Association of Telegraph Media Co Ltd, January 20, 2014.
. 116 See note 112.
. 117 Deng Machol, “New Daily Paper ‘The Juba Telegraph’ Debuts in South Sudan,” The Niles, September 9, 2014, on file 
with The Sentry.
. 118 Radio Tamazuj, “New Newspaper Linked to S Sudan President’s Office to Promote ‘National Sovereignty,’” September 
13, 2014, available at: 
. 119 See note 112.
. 120 See note 118.
. 121 See note 113.
. 122 Emmanuel Monychol, LinkedIn profile, available at:
. 123 Emmanuel Monychol Akop has previously been detained by the National Security Service. See: 
Committee to Protect Journalists, “Emmanuel Monychol Akop,” available at: monychol-akop/
Human Rights Watch, “South Sudan: Free Arbitrarily Detained Journalist,” November 28, 2019, available at: https://
. 124 The Sentry interview with a South Sudanese civil society activist who has been active in the civil society sphere in the country for more than a decade, March 2022.
. 125 The Sentry interview with a South Sudanese civil society activist who has been active in the civil society sphere in the country for more than a decade, March 2022.
. 126 See note 81.
. 127 United Nations Human Rights Office of the High Commissioner, “OHCHR and Protecting and Expanding Civic Space,” 

available at:
. 128 Ibid.
. 129 See note 1.
. 130 The Sentry interview with a South Sudanese civil society activist who has been active in the civil society sphere in the 
country for more than a decade, March 2022.
. 131 The Sentry interview with a South Sudanese civil society activist who has been active in the civil society sphere in the 
country for more than a decade, March 2022.
. 132 The Sentry interview with a South Sudanese civil society activist who has been active in the civil society sphere in the 
country for more than a decade, March 2022.
. 133 The Sentry interview with a South Sudanese civil society activist who has been active in the civil society sphere in the 
country for more than a decade, March 2022.
. 134 United Nations Security Council, “Final report of the Panel of Experts on South Sudan,” S/2018/292, April 
12, 2018, p. 20, available at: 
. 135 See note 112.
. 136 See note 134.
. 137 TVC News, “South Sudan Govt Hikes Registration Fees for Aid Agencies,” May 2017, available at: https://www.
. 138 The Sentry interview with a South Sudanese civil society activist who has been active in the civil society sphere in the country for more than a decade, March 2022.
. 139 The Sentry interview with international human rights analyst and South Sudan expert, September 2022.
. 140 The Sentry, “Untapped and Unprepared: Dirty Deals Threaten South Sudan’s Mining Sector,” April 2020, available at:
. 141 The Sentry, “Fueling Atrocities: Oil and War in South Sudan,” March 2018, available at: 
. 142 The Sentry, “The Taking of South Sudan: The Tycoons, Brokers, and Multinational Corporations Complicit in Hijacking the World’s Newest Nation,” September 2019, available at:
. 143 See note 27.
. 144 See note 112.
. 145 Sudan People’s Liberation Army Command Council Secretariat, “The National Dialogue Security Forces Contribution,” 
August 5, 2017, on file with The Sentry.
. 146 Talk of Juba, “Kiir Reconstitutes Nilepet’s Board,” April 23, 2021, available at: 
. 147 David Mayen, “Salva Kiir Sacks Finance Minister Amid Economic Crisis,” allAfrica, September 17, 2020, available at:
. 148 See note 112.
. 149 Internews, “Eye Radio Exposes Corruption at National Revenue Authority,” February 18, 2020, available at: https://
. 150 See note 140.
. 151 See note 142.
. 152 See note 3, p. 43.
. 153 The Sentry interview with Olympio Attipoe, October 2021.
. 154 The Sentry interview with a South Sudanese civil society activist who has been active in the civil society sphere in the 
country for more than a decade, March 2022.
. 155 The Sentry interview with a South Sudanese journalist, January 2022.
. 156 The Sentry interview with Olympio Attipoe, October 2021.
. 157 Ministry of Finance and Economic Planning, “Approved Budget Book FY2019/20,” available at: http://www.mofep-grss. 
. 158 Global Witness, “Capture on the Nile,” April 2018, available at: 
. 159 See note 141.
. 160 International Crisis Group, “Oil or Nothing: Dealing With South Sudan’s Bleeding Finances,” October 6, 2021, available 

. 161 Nile Petroleum Corporation, “About Us,” available at:
. 162 See note 160.
. 163 United Nations Security Council, “Final report of the Panel of Experts on South Sudan submitted pursuant to resolution 
2471 (2019),” S/2020/342, April 28, 2020, p. 3, available at:
. 164 See note 141.
. 165 The Sentry interview with oil sector employee, April 21, 2022.
. 166 The Sentry interview with oil sector employee, April 21, 2022.
. 167 The Sentry interview with oil sector employee, April 21, 2022.
. 168 The Sentry analysis of corporate records cross-referenced with an NSS official list, March 2022.
. 169 The Sentry, “Cash Grab: How a Billion-Dollar Credit Scam Robbed South Sudan of Fuel, Food, and Medicine,” October 
2022, available at:
. 170 Kush Petroleum, “Home,” available at:
. 171 The Sentry interview with oil sector employee, April 21, 2022.
. 172 See note 38, p. 6.
. 173 See note 146.
. 174 See note 160.
. 175 See note 146.
. 176 See note 38, p. 6.
. 177 See note 38, p. 6.
. 178 See note 158.
. 179 See note 158.
. 180 United Nations Security Council, “ Final report of the Panel of Experts on South Sudan established pursuant to Security 
Council resolution 2206 (2015),” S/2016/70, January 26, 2016, p. 22, available at: 
. 181 See note 158.
. 182 See note 158.
. 183 See note 180, p. 22.
. 184 See note 158.
. 185 Africa Intelligence, “The First Collateral Damage of the War: The State Budget,” March 27, 2015, available at: https:// 
. 186 Ibid.
. 187 See note 180, p. 22.
. 188 United States Department of State, “2016 Country Reports on Human Rights Practices: South Sudan,” 2016, p. 2, 
available at:
. 189 See note 158, p. 3.
. 190 The Small Arms Survey, “The Conflict in Upper Nile State,” March 2016: HSBA-Conflict-Upper-Nile-March-2016.pdf
. 191 See note 38, pp. 6, 51.
. 192 Nilepet, “Leading the Transformation: Nilepet in the Oil and Gas Industry of South Sudan,” on file with The Sentry.
. 193 See note 38.
. 194, “Nile Drilling Services Co. Ltd,” available at: (last accessed 
September 30, 2022).
. 195 See note 112.
. 196 Mariak Deng Marial, “Why General Manasa Machar Bol Should Replace General Akol Koor,” Sudans Post, 2020, available at:
. 197 The Sentry communication with Kogweno & Bubi Advocates, LLP, November 14, 2022.
. 198 South Sudan Ministry of Justice, Memorandum and Articles of Association of Kush Petroleum Limited, March 22, 2007.
. 199 South Sudan Ministry of Justice, Memorandum and Articles of Association for Transco Energy Co, March 11, 2014.
. 200 South Sudan Ministry of Justice, Memorandum and Articles of Association for Nile Investment Partners, December 

. 201 See note 170.
. 202 The letters of credit program took place between 2012 and 2015, when the South Sudanese government received a credit line of nearly one billion dollars from Qatar National Bank and CfC Stanbic Bank. The credit line was meant to help local companies pay for imports of much needed fuel, food, and medicine. In practice, contracts were awarded to foreign run companies, inexperienced middlemen, and businesses with connections to the ruling class. Companies with NSS shareholders received a total of $13 million. See note 169.
. 203 South Sudan National Audit Chamber, “Report of the Auditor General to the National Legislative Assembly on the Audit of Performance and Management of Letters of Credit From the Year 2012 to 2015,” November 2015, pp. 73, 168, 247, and 261.
. 204 See note 198.
. 205 See note 203, pp. 73, 168, 247, and 261.
. 206 Kenyan Export data, 2013-2015, reviewed by the Sentry
. 207 The Sentry communication with Kogweno & Bubi Advocates, LLP, November 14, 2022.
. 208 South Sudan Ministry of Justice, Special Resolution of Conex Energy Co. Ltd., August 20, 2014
. 209 South Sudan Ministry of Justice, Memorandum and Articles of Association of South Gas Energy Limited, April 29, 2014.
. 210 South Sudan Ministry of Justice, Corporate Documents, August 7, 2022, on file with The Sentry.
. 211 Cable From United Nations New York to Secretary of State (South Sudan), “Subject: USUN’S FRANK EXCHANGE 
WITH SOUTHERN SUDAN LEADERS,” WikiLeaks, April 3, 2009, available at: 
. 212 The Sentry communication with Akot Lual Arech, July 29, 2022.
. 213 See note 208.
. 214 See note 163, p. 3.
. 215 Trinity Energy, Payroll for July 2018, on file with The Sentry.
. 216 The Sentry communication with Ann Kathure Rutere, November 8, 2022.
. 217 The Sentry interview with Olympio Attipoe, October 2021.
. 218 The Sentry interview with an employee at the National Revenue Authority, March 2022.
. 219 Radio Tamazuj, “Finance Minister Defends Termination of Olympio’s Contract,” August 29, 2019, available at: https://
. 220 Joakino Francis, “Kiir’s Office Acknowledges Dismissal of NRA Boss Amid Criticism,” Eye Radio, August 27, 2019, available at:
. 221 See note 147.
. 222 See note 149.
. 223 See note 163.
. 224 Ayuen Panchol, “Acting NRA Boss Makes Suspicious Bank Transfers,” Eye Radio, November 22, 2019, available at:
. 225 South Sudan Ministry of Justice, Memorandum and Articles of Association of Ayen Model Forex PLC, July 27, 2010.
. 226 South Sudan Ministry of Justice, Memorandum and Articles of Association of Alok Forex Bureau, August 24, 2010.
. 227 Ibid.
. 228 South Sudan Ministry of Justice, Memorandum and Articles of Association of Harvest Trade and Development Bank 
Ltd, April 5, 2013.
. 229 See note 112.
. 230 The Citizen, “EACO Committed to Firm Management of Communication Services in EAC,” June 28, 2022, available at: 
. 231 Sudan Tribune, “South Sudan’s High Court Unmasks Renowned Spymaster” December 14, 2016, available at: https://
. 232 See note 142.
. 233 Oliver Windridge, “Constructing Corruption: Identifying the Enablers Helping Build Violence Kleptocracies,” The Sentry, 
September 2022, p. 5, available at:
. 234 The Sentry analysis of corporate records cross-referenced with an NSS official list, March 2022.
. 235 See note 142. 

236 See note 27, pp. 14-15.
237 Justin Lynch, “Revealed: The Spies Helping Push South Sudan to Genocide,” The Daily Beast, September 11, 2017,
available at:
238 Daily Nation, “Court Told Spies Holding Missing South Sudanese,” February 19, 2017, available at: http://mobile.nation.
239 See note 237.
240 See note 27, pp. 14-15.
241 See note 238.
242 Denis Dumo, “U.S. Sanctions Five South Sudan Officials Over Killings of Government Critics,” Reuters, December
11, 2019, available at:
243 United States Department of the Treasury, “Treasury Sanctions Individuals for Roles in Atrocities and Other Abuses,” December 10, 2019, available at:
244 United States Department of the Treasury, “Treasury Sanctions South Sudanese First Vice President for Role in Serious Human Rights Abuse,” January 8, 2020, available at:
245 See note 142, p. 21.
246 South Sudan Ministry of Justice, Memorandum and Articles of Association for Vukani Aviation, December 18, 2014, on
file with The Sentry. 247 See note 142.
248 See note 142, p. 21.
249 See note 142, p. 21.
250 Donovan Foley, “Giving Wings to Disadvantaged Youth,” IOL, December 13, 2015.
251 Sabelo Skiti and Simon Allison, , “‘JZ’s Pilot’ Joins South Sudan’s Gestapo,” Mail & Guardian, September 19, 2019,
available at: 252 See note 142.
253 South Sudan Ministry of Justice, Memorandum and Articles of Association of Pinnacle Security Limited, April 12, 2016. 254 South Sudan Ministry of Justice, Memorandum and Articles of Association of Deway Security Company Limited, July
23, 2015.
255 See note 142.
256 See note 6.
257 LexisNexis, “Person Report- Jalpan Obyce Nyawello,” on file with The Sentry.
258 Nexus, “Person Report- Akot Lual Arech,” on file with The Sentry
259 See note 112.
260 Human Rights Watch, “Letter for Request for Appointment,” December 2, 2019, on file with The Sentry
261 See note 257.
262 Collin Central Appraisal District, “Property ID: 2502556,” on file with The Sentry.
263 JumpStart Sudan, “JumpStart Sudan Was Founded by One of the Lost Boys of Sudan,” available at: https://web. (last accessed August 20, 2008). 264 Linda Cruse, “Refugee Will Return to War-Torn Sudan on Mission,” The Kansas City Star, August 14, 2004.
265 See note 258.
266 See note 112.
267 Johnson County Government, “Location Services,” on file with The Sentry.
268 Open Corporates, “Jumpstart South Sudan,” available at:
269 GuideStar, “JumpStart Sudan, Inc,” available at:
270 Sudan Tribune, “Sudan SPLM Delegation received at White House, State, and Pentagon,” April 4, 2009, available at:

Sudan SPLM delegation received at White House, State, and Pentagon

271 The Sentry communication with Akot Lual Arech, July 29, 2022. 272 See note 39, pp. 8-9.
273 See note 39, p. 9.
274 See note 42, pp. 7, 9.
275 See note 42, p. 9. 276 See note 42, p. 14.

277 See note 42, p. 15.
278 See note 39, p. 11.
279 See note 42, p. 15.
280 Financial Crimes Enforcement Network, “Advisory on Political Corruption Risks in South Sudan,” September 6, 2017,
available at:
281 National Economic Crime Centre, “Amber Alert South Sudan: Illicit Finance Risks,” March 2020, available at: https://
282 Financial Action Task Force, “Jurisdictions under Increased Monitoring – June 2021,” June 2021, available at: https://
283 Ibid.
284 Brian Adeba, “A Hope From Within? Countering the Intentional Destruction of Governance and Transparency in
South Sudan,” Enough Project, July 27, 2016, available at:
285 See note 3, section 120, clauses 1 and 2.
286 As an example of already existing legislation with more precise wording, the Civil Service Act of 2011 specifies that “a
civil servant, official or employee shall not have any direct or indirect interest in any public or private organization liable to create a conflict between their private interests and the duties associated with their official duties and functions.” See:
South Sudan, Civil Service Act, 2011.
287 See note 42, pp. 8-9.



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