Executive summary

Since the escalation of the conflict in April 2023, Sudan has been engulfed in a massive human rights and humanitarian crisis. The fighting between the Sudanese Armed Forces (SAF) and the Rapid Support Forces (RSF) and their allies has killed over 16,650 people and displaced millions of others making Sudan the largest internal displacement crisis globally. All parties to the conflict are using a wide variety of arms to commit serious violations of international human rights and humanitarian law, in some instances amounting to war crimes and crimes against humanity.  

This conflict is being fuelled by an almost unimpeded supply of weapons into Sudan by states and corporate actors around the world. Nearly all neighbouring countries are used by various armed groups and states as supply lines to transfer weapons into and around Sudan.  

The response of the international community, and particularly the UN Security Council (UNSC), has been woefully inadequate. The current UN arms embargo is both too narrowly focused – covering only the Darfur region – and too poorly implemented to have any meaningful impact on curbing these weapons flows. It took almost a year for the UNSC to adopt a resolution calling for immediate cessation of hostilities and unhindered humanitarian access. Despite this, fighting continues across the country with no effective measures to end violations or protect civilians.  

This report reveals the true extent of these failures: despite the mandatory UNSC embargo which has been in place for two decades, recently manufactured weapons and military equipment from countries such as Russia, China, Türkiye, and the United Arab Emirates (UAE) are being imported in large quantities into Sudan, and then diverted into Darfur. Weapons and ammunition are also being smuggled into the country directly through Darfur including after April 2023. An assessment of visual evidence places some of these weapons directly in the hands of parties to the conflict who stand accused of serious human rights abuses. 

The research has also identified recently-manufactured or recently-transferred small arms and ammunition from countries such as Serbia, Yemen, and China being used on the battlefield by various parties to the conflict. Advanced drone jammers, mortars and anti-materiel rifles manufactured in China have been used by both sides of the conflict, including in Darfur. A variety of recently-manufactured armoured personnel carriers from the UAE have been used by the RSF, also in Darfur. Shipment-level trade data indicates that hundreds of thousands of blank guns have been exported to Sudan in recent years, along with millions of blank cartridges. Amnesty International believes that these are being converted en masse into lethal weapons in Sudan. 

One disturbing trend identified by Amnesty International is the diversion of small arms normally sold into the civilian market to government forces and armed opposition groups.  Companies in Türkiye and in Russia have exported variants of small arms such as Tigr designated marksman rifles (DMR)s or Saiga-MK rifles, manufactured by Kalashnikov Concern and normally marketed to civilian gunowners, to arms dealers with strong links to the Sudanese Army. Türkiye’s main weapons manufacturer, Sarsilmaz, supplies the Sudanese Armed Forces, while Turkish hunting shotguns and rifles normally made for the civilian market and manufactured by small companies like Derya Arms, BRG Defense or Dağlıoğlu Silah, largely escape export control regulations and have been exported en masse to Sudan in recent years. Both the Russian and Turkish arms are used by parties to the conflict.  

The UN Security Council must take urgent measures to stop the flow of arms and protect civilians. The existing arms embargo that currently applies only to Darfur, and which is poorly implemented and frequently violated, is completely inadequate. Since its inception in 2004, Amnesty International has been urging the UNSC to expand the arms embargo regime to the rest of Sudan and to strengthen its monitoring and verification mechanisms. This call, given the escalating violence across the country, is now more urgent than ever. The expansion of the arms embargo must be adequately resourced to be able to effectively monitor and prevent international transfers and illicit diversion of arms to the country. It must cover the widest possible scope of weapons to combat the widespread diversion of shotguns, hunting rifles, blank guns and related ammunition into the conflict. 

Irrespective of whether the UNSC arms embargo is extended to cover the whole of Sudan, all states and corporate actors must immediately cease supplies of all arms and ammunition to Sudan. This includes the direct or indirect supply, sale or transfer of arms and military materiel, including related technologies, parts and components, technical assistance, training, financial or other assistance. States must also explicitly prohibit the transfer to Sudan of firearms marketed to civilians – such as shotguns or hunting rifles – which Amnesty International has repeatedly documented in the hands of parties to the conflict. 

States parties to the Arms Trade Treaty, which include Serbia (since December 2014) and China (since October 2020) have a legal obligation not to authorize any transfer of conventional arms if they have knowledge at the time of authorization that the arms or items would be used in the commission of genocide, crimes against humanity or war crimes. States Parties must also conduct an objective and non-discriminatory assessment of all exports of conventional arms and deny export authorization if there is a substantial risk that the arms could be used to commit or facilitate a serious violation of international human rights or humanitarian law.  

As a part of their obligation to respect and ensure respect for international humanitarian law (IHL), all states are prohibited from transferring or permitting private actors to transfer weapons to a party to an armed conflict – whether a state or non-state armed group – where there is a clear risk that this would contribute to the commission of IHL violations. Corporate actors involved in the transfer of weapons to Sudan may also contribute to IHL violations when they act with a sufficient connection to the conflict which, if they were aware that said weapons will likely be used to commit international crimes, may entail criminal responsibility. 

There is a clear global consensus that companies have a responsibility to respect human rights throughout their global operations including with respect to the manufacture, export, import, and sale of arms that may be used to commit serious human rights violations. Although States have an obligation to regulate the arms industry, the corporate responsibility to respect human rights exists over and above obligations to comply with national laws and regulations. This responsibility requires companies to conduct human rights due diligence throughout their entire value chain to identify, prevent, and mitigate any actual or potential involvement in human rights abuses. The standard of human rights due diligence required is heightened with respect to business activity impacting conflict-affected areas.  

In light of the substantial risk that all arms and ammunition being transferred to Sudan – including those marketed to civilians – will be used by parties to the conflict to commit grave human rights abuses, companies must immediately cease their involvement in this supply of arms to avoid causing or contributing to these abuses. If a company identifies that the products they sold have contributed to such abuses, they should provide for or cooperate in remediation process to any persons harmed as a result.  

To conduct research into these weapon flows, Amnesty International investigators analyzed 1,900 shipment records from two different shipment-level trade data providers, and open source and digital evidence, including about 2,000 verified photos and videos, showing recently manufactured or recently imported weapons in use by parties to the conflict in Sudan including in Darfur, and remote sensing techniques. The organization also interviewed 17 regional arms and Sudan experts between February and March 2024 to corroborate data analysis and understand key weapons supply lines used by various groups. 

Intense fighting erupted in Sudan in April 2023 between the SAF and the RSF paramilitaries.² Over the following 15 months, other armed groups and actors joined the conflict, aligning themselves either with the SAF or the RSF.³ The fighting came after months of tensions between the two groups over security force reforms, proposed as part of the negotiations for a new transitional government, among other issues.⁴ 

Impact of the conflict on civilians  

The clashes, which initially started in the capital Khartoum, quickly spread to other areas of Sudan, including Darfur, North Kordofan and later Gezira state.⁵ The conflict has led to massive civilian suffering and large-scale destruction.⁶ More than 16,650 people have been killed nationwide since April 2023.⁷ Amnesty International has documented civilian casualties in both indiscriminate strikes and direct attacks on civilians.⁸ Some of the violations by parties to the conflict amount to war crimes. Many civilians were caught in the crossfire as members of the SAF and RSF, often using explosive weapons with wide area effects, launched frequent and indiscriminate attacks in and from densely populated civilian neighbourhoods.⁹ People were consequently killed inside their homes, or while desperately searching for food and other necessities. Others were killed and injured while fleeing from the violence, and in places where they had sought safety.¹⁰ 

The crisis has also led to massive civilian displacement. According to the UN, over 7.3 million people have been internally displaced since April 2023. Sudan now has over 11 million internally displaced people making it the largest displacement crisis in the world.¹¹ Among those displaced are refugees from other countries, especially Ethiopia, Eritrea and South Sudan, who had sought refuge in Sudan.¹² In addition, over 2.1 million people have fled to neighbouring Central African Republic, Chad, Egypt, Ethiopia and South Sudan, where they live in dire conditions.¹³ 

Humanitarian organizations are warning that the war in Sudan is pushing the country toward famine and to a catastrophic loss of life, especially among children.¹⁴ According to the latest data released by the Nutrition Cluster in Sudan, more than 2.9 million children in Sudan are acutely malnourished and an additional 729,000 children under five are suffering from severe acute malnutrition, the most dangerous and deadly form of extreme hunger. In addition, Save the Children, a humanitarian NGO, estimates that nearly 230,000 children, pregnant women, and new mothers could die in the coming months due to hunger.¹⁵ 

Rampant human rights and humanitarian law violations in Darfur

The new escalation of violence in Sudan coincided with the 20^th anniversary of the Darfur conflict that has caused immense human suffering in the region.¹⁶ Since 2003, civilians in Darfur have been subjected to extreme violence.¹⁷ Civilian populations, of specific ethnic groups, accused of supporting armed insurgent groups, have previously been targeted by the Sudanese government.¹⁸ Amnesty International has documented crimes under international law committed in Darfur including large-scale violations and abuses, including war crimes and crimes against humanity.¹⁹  

Since the renewal of the conflict in April 2023, Amnesty International, has documented numerous human rights and humanitarian law violations in Darfur. Civilians were killed and injured in targeted attacks in West Darfur, where the RSF and allied militias carried out ethnically-motivated attacks against the Masalit and other non-Arab communities, killing and injuring thousands of civilians and displacing hundreds of thousands.²⁰ Amnesty International documented these ethnically motivated attacks in the towns of Ardamata,²¹ El Geneina, Misterei and Tandelti of West Darfur.²² In Nyala, South Darfur, Amnesty International documented indiscriminate attacks that killed and injured civilians and destroyed civilian infrastructure.²³ In Kabkabiya, North Darfur, indiscriminate attacks killed and injured humanitarian workers.²⁴ Women and girls in Darfur continued to be subjected to conflict-related sexual violence, including rape, by members of the warring sides, mainly RSF and allied militias.²⁵ Fighters, mostly RSF and allied militia, continued to engage in widespread looting of homes, businesses and public institutions, including hospitals, humanitarian organizations’ warehouses, and banks in the Darfur region.²⁶ 

Inadequate regional and international response

The regional and international response has been woefully inadequate.²⁷ Diplomatic and other efforts by key actors have so far failed to end the violence, protect civilians, provide sufficient humanitarian aid, or hold perpetrators to account.²⁸  In the past year, a growing list of global and regional powers, including Egypt, Saudi Arabia, United Arab Emirates (UAE) and USA have initiated individual and/or joint processes to resolve the conflict, with the Jeddah process standing out as the most prominent. ²⁹ At the same time, multilateral institutions, including the African Union (AU),³⁰ the Intergovernmental Authority on Development (IGAD),³¹ the UN, and the League of Arab States, have actively sought to intervene, with the AU and IGAD developing separate roadmaps toward the resolution of the conflict. Often at odds or in competition with each other, all of these multiple actors, processes, and roadmaps have had limited success.³² In addition, the international humanitarian response to Sudan remains significantly underfunded despite humanitarian organizations warning of famine.³³ As of June, the UN’s appeal was only 16 percent funded seriously undermining delivery of much needed emergency aid and services.³⁴ 

It took almost a year for the United Nations Security Council to adopt a resolution on Sudan that called for the “immediate cessation of hostilities” and for “all parties to ensure the removal of any obstructions and enable full, rapid, safe, and unhindered humanitarian access…” but despite the resolution, fighting continues throughout the country with no measures of protecting civilians being put in place.³⁵ 

UN embargo on Darfur and weapons supply lines

The UN Security Council imposed an arms embargo on non-governmental entities in Darfur in 2004.³⁶ This was strengthened the following year to cover all parties to the N’djamena Ceasefire Agreement, which included the Sudanese government forces in Darfur.³⁷ The current measures require states (including the Government of Sudan) to take “all necessary measures” to prevent the sale or transfer of arms and/or technical assistance and training to non-governmental entities or individuals and to the Sudan government.³⁸ These measures only apply to the five states in Darfur. Transfers of weapons to other parts of Sudan are permitted under the embargo, provided they supply the necessary end user documentation to ensure compliance with previous embargo resolutions. In addition to the UNSC sanctions regime on Darfur, there has been an EU arms embargo on the whole of Sudan since 1994.³⁹ 

Amnesty International and other organizations have strongly criticized both the scope and the implementation of the UNSC embargo since its imposition in 2004 and called on the UNSC to both extend the embargo to the whole of Sudan, and adequately invest in its full implementation.⁴⁰ In previous reports related to the conflict in Darfur, Amnesty International has documented substantial flows of weapons into Sudan with onward diversion into Darfur.⁴¹ Some states and other actors have been fueling the current conflict in Sudan by supplying weapons and ammunitions to the warring sides, including in the Darfur region.⁴² In January 2024, the UN Panel of Experts on the Sudan noted that the transfers of arms and ammunition into Darfur during the ongoing conflict constituted violations of the arms embargo.⁴³ 

These weapons follow numerous supply lines into Sudan, some of them directly supplying Darfur.⁴⁴ Based on the analysis of flight-tracking and remote-sensing data, independent researchers⁴⁵ and media outlets⁴⁶ identified the Am Djarass airport in eastern Chad as an avenue used by the UAE to transfers weapons into Darfur, an allegation further supported by the UN Panel of Experts.⁴⁷ These findings were also corroborated by local journalists and security experts during interviews conducted by Amnesty International.⁴⁸  

In late March 2024, the Permanent Representative of Sudan to the United Nations accused the UAE of committing an act of aggression against Sudan, in part for providing weapons, armored military vehicles, drones, provisions, food, ammunition, and other forms of military support to the RSF.⁴⁹ It also accused Chad of allowing its territory, particularly the airports of Am Djarass and Abéché, to be used to transport weapons and materiel and to evacuate injured RSF fighters to the Zayed Military Hospital in Abu Dhabi.⁵⁰ On 21 April 2024, the United Arab Emirates rejected the allegations made by the Permanent Representative of Sudan.⁵¹ 

The UN Panel of Experts also identified supply lines for weapons, vehicles and fuel from South Sudan, Libya and the Central African Republic, again corroborated by Amnesty International interviews.⁵² In addition, media reports indicate⁵³ drones manufactured in Iran have been supplied to the Sudanese Armed Forces via Port Sudan.  Weapons are also flowing from Eritrea and Ethiopia, documented by media sources and confirmed during Amnesty International interviews with Sudanese journalists and security experts.⁵⁴ The Sudanese authorities regularly seize small arms from smugglers in Kassala, near the Eritrean border.⁵⁵  

By analyzing the records of more than 1,900 shipments of commodities categorized as HS 93+, Amnesty International was able to profile several of the country’s most important importers as well as some of their main foreign partners. This analysis not only reveals the magnitude of Sudan’s weapons trade, but also sheds light on some concerning trends, including the likely large-scale diversion of civilian weapons to armed groups, as well as possible large-scale conversion of less lethal weapons into lethal ones.  

Sudan’s import of foreign small arms

Entities that import significant quantities into Sudan can be broadly divided into two categories: companies that have close links with the Sudanese army or arms industry, and smaller importers that mostly target the civilian market. As discussed above, there is ample evidence to show that civilian weapons are being used by all sides in the current conflict. A careful analysis of the trade data indicates that some companies act as proxies for the parties to the current conflict. 

On the importing side, based on available open-source data, the largest importer of weapons into Sudan is a company called Marble Engineering,¹⁵³ which was already flagged in the 2016 UN Panel of Experts report as a likely front company used by the Government of Sudan to import military aircraft into the country.¹⁵⁴ According to trade records, the company only appears to have procured commodities categorized as HS 93+ from the Indian company Ashoka Manufacturing (the largest supplier of weapons to the Sudanese market, as detailed below),  labelled ”munition metal components”, many of them parts for S-8 80mm rockets.¹⁵⁵ These S-8 rockets are launched from B-8M1 rocket pods, which are mounted on SAF aircraft, or on pick-up trucks and used in various parts of the country, including near Khartoum.¹⁵⁶ The second largest Sudanese importer, Target Multiactivities co. Ltd., also procured exclusively from Ashoka Manufacturing, between 2016 and 2018, but there is no available information about the nature of the shipments.¹⁵⁷ Target Multiactivities is a subsidiary of the GIAD conglomerate,¹⁵⁸ whose structural links with SAF and the Sudanese arms manufacturing are well-documented.¹⁵⁹ Al-Shagara Industrial Complex, an entity within the State-owned Military-Industry Corporation (MIC), imports large quantities of weapons from civilian companies in both Russia and Türkiye. Some of the shipments strongly suggest attempts at circumventing UNSC resolutions or export control laws.  

Wail Shams Trading, the fifth largest Sudanese weapons-importing entity based on open-source records,¹⁶⁰ procures large quantities of weapons and rifles labelled as hunting, sports or targeting rifles from various companies in Russia and Türkiye. Its main supplier is Kalashnikov Concern, and the value of some shipments are above USD 500,000.¹⁶¹  Wail Shams Trading, in particular, is a large importer of Tigr DMRs and Saiga-MK rifles, which have been identified by Amnesty International as being used in conflict areas of Sudan, including in Darfur, by both the SAF and the RSF. According to shipment level trade data, until at least 2020, Wail Shams Trading was headquartered at the Military Officers’ Club in Khartoum, an elite and exclusive venue owned by the Sudanese Army.¹⁶² In a response to Amnesty International, the General Manager of Wail Shams Trading claimed that the company was only headquartered at the Army Officer’s Club until 2016. In 2021, a weapons shipment originating from Russia, but transiting through Addis Ababa, was blocked by the Sudanese customs administration at Khartoum airport. It was later cleared by the Ministry of the Interior, despite formal protests from the Public Prosecution in Sudan.¹⁶³ Observers claimed that Public Prosecution was worried about potential transfers to forces loyal to ousted President Omar Al-Bashir.¹⁶⁴ 

Responding to Amnesty International, Wail Shams Trading claimed that it complies with all international laws and regulations regarding the sale of arms and equipment to Sudan and stated that the RSF was responsible for the diversion of the weapons imported, arguing that its store and warehouse were robbed by the RSF after the outbreak of the conflict. Amnesty International is unable to verify this additional information shared by Wail Shams Trading. 

On the exporting side, besides Ashoka Manufacturing, the largest exporters to Sudan are Kalashnikov Concern and Molot. Together the two companies have exported at least USD 5.8 million worth of small arms to Sudan since 2019. These small arms manufacturers are partially owned by Rostec, Russia’s state-owned defense conglomerate. Both of these companies seem to trade with a limited number of Sudanese partners, and mostly export firearms under specific HS codes that relate to “sporting, hunting or target rifles”. These “sporting, hunting or target rifles” are frequently seen being used in conflict settings by both the RSF and the SAF. 

Turkish exports to Sudan come from a much wider diversity of suppliers, mostly small defense companies manufacturing predominantly handguns, 12-gauge shotguns designed for hunting, and so-called blank guns.

Blank guns and rounds

Shipment-level trade data reveals Turkish exports of very large quantities of blank guns and ammunition to Sudan.¹⁶⁶ Due to the magnitude of the trade, similar patterns established elsewhere in the Sahel, and the specific models that are imported in large numbers less-lethal weapons are massively converted into lethal small arms in Sudan. 

CONVERSION OF TURKISH BLANK GUNS AND AMMUNITION INTO LETHAL WEAPONS

The term “blank gun” usually refers to less lethal firearms (usually handguns) that generate the typical flash and sound of lethal weapons, but do not fire a projectile. As opposed to lethal weapons that are designed to kill, blank guns are primarily designed for self-defense, but do normally not cause injury.¹⁶⁷ Since these blank guns are not designed to injure or kill, they can be very easily procured.  

While the conversion of blank guns into lethal weapon is not a new phenomenon, it has been increasingly scrutinized over the last decade due to increased awareness of the security risk it constitutes, especially in jurisdictions with strict gun control regulations, as in much of Europe. Turkish blank guns have already been flagged as the most prevalent source of converted firearms in Europe.¹⁶⁸ 

Blank guns are often easy to procure and closely resemble existing lethal handguns models, while only costing a fraction of the price, often less than USD 50. They can be sold, once converted, at a much higher price, up to USD 200 for Turkish blank guns in the Horn of Africa region.¹⁶⁹ According to research papers based on the identification of seized converted firearms by the Turkish police, there are two main ways in which blank guns can be converted: ¹⁷⁰ 
either by the complete re-barreling of the blank gun (by either sleeving the existing barrel or entirely replacing it), which requires adapted tools, or by removing or destroying the obstruction/restraint piece located in the barrel, to clear the way for projectile. ¹⁷¹ 
While in most cases re-barreled converted handguns can be loaded with standard lethal ammunition, with the new barrel withstanding the increased pressure, blank guns that have been converted using the second technique can only be loaded with converted blank rounds. Again, various techniques can be used, one of the most common one being the removal of the plastic wad and the addition of a metal sphere as projectile, often a buckshot pellet, as depicted in the pictures below.  

Left: an unmodified blank round; right: a blank round converted through the addition of a metal sphere.¹⁷² 

Blank weapons must be loaded with special ammunition that either does not contain a projectile, or shoots rubber projectiles or tear gas capsules that do not always require an export license. This has contributed to their widespread presence in numerous Sahelian and North African countries.¹⁷³  

Conservative calculations based on shipment-level trade data indicate that between 2020 and 2023 at least 239,309 blank guns have been exported by a limited number of Turkish companies to Sudan.¹⁷⁴ In addition, nearly 26 million blank rounds have been imported by entities registered in Sudan.¹⁷⁵ Among these entities is the Al-Shagara Industrial Complex, a company within Sudan’s State-owned defence conglomerate MIC. Between 2019 and 2023, Al-Shagara imported at least 2,400 blank guns from Türkiye, as well as 200,000 rounds of blank ammunition.¹⁷⁶ One single Khartoum armorer, Al-Bayarg, imported no less than 5.1 million blank rounds between 2020 and 2023.¹⁷⁷ While social media profiles of the Al-Bayarg shop in Khartoum do show several blank guns advertised for sale, the sheer magnitude of imports of blank weapons and ammunition, a rather niche market for products that have no use in a conflict setting, calls for closer scrutiny.¹⁷⁸ 

There are two main non-exclusive explanations for these massive imports: mass conversion and/or mislabelling of shipments. While MIC-affiliated companies have the proven capacity to manufacture small arms, including handguns, importing less lethal weapons from Türkiye and re-barrelling them would allow for quicker and cheaper production. As for the ammunition, this is unlikely to be the case as the low precision and unreliability of converted ammunition makes it unsuitable for military use. Amnesty International calls for further investigation and closer scrutiny on the concrete use of these large shipments of blank rounds to Sudan. 

Many of the specific models of blank guns and blank rounds imported from Türkiye have a track record of smuggling into North African and Sahelian States.¹⁷⁹ The company Özkursan, which is headquartered in Istanbul and currently is the largest supplier of blank rounds to Sudan,¹⁸⁰ was already highlighted in a sanctions violation case regarding UN sanctions on Libya, seeking to export 2,500 blank guns and 500,000 rounds of blank ammunition to the Libyan civilian market.¹⁸¹ Voltran, another company that exports to Sudan large numbers of blank guns under the brand Ekol, was also identified by the UN Monitoring Group on Somalia and Eritrea as the supplier of a large shipment of blank guns off-loaded in the Eritrean port of Massawa, allegedly en route to Sudan in 2017.¹⁸² Several investigative press reports suggest that Voltran products are still in high demand by weapons traffickers involved in Libya.¹⁸³ A large number of the most commonly exported Turkish blank guns to Sudan–Ekol handguns manufactured by Voltran, Zoraki pistols manufactured by Atak Arms, or Retay products,¹⁸⁴ for instance–are among the most commonly converted firearms seized in Europe.¹⁸⁵ This is due to their low prices and easy convertibility as tutorial videos are widely available on major social media platforms. Several of the specific models imported by the Al-Shagara Industrial Complex, in particular Retay 84FS¹⁸⁶ and Retay Mod 92, have been seized by law enforcement units in various countries, after having been converted and sold on the black market.¹⁸⁷ 

Civilian weapons diverted en masse?

Shipment-level trade data analyzed by Amnesty International reveals a very large number of shipments labelled as “hunting”, “civilian”, “target” or “sporting” weapons, suggesting that they are destined to the market.¹⁸⁹ In addition to the ample evidence of these “civilian” weapons being diverted to the battlefield, the careful analysis of some of these shipments strongly suggests diversion techniques aimed at circumventing export control regulations. 

Broad categories such as “civilian”, “hunting” or “sporting ” can include various types of weapons and calibers, but, at least for Turkish exports, mostly relate to smooth-bore 12GA shotguns, which are excluded from the official Turkish list of controlled items.¹⁹⁰  Available open-source trade data (2014-2023) includes only 21 different shipments categorized under the specific HS Code 930330000000, which encompasses “other sports, hunting or target rifles”. Seventy-five shipments encompassing 16,254 shotguns and rifles include the word “hunting“ in the product description, and these ”hunting” rifles very frequently make their way into the hands of the RSF, the SAF, or their networks of proxies and allies. The State-owned Al-Shagara Industrial Complex imported large quantities of hunting rifles from Türkiye between 2020 and 2023 from one single supplier, Ebru Seymanur Ozman.¹⁹¹ The same supplier also provided 400 blank guns and 200,000 blank rounds. Another 3,073 hunting rifles were supplied to the Al-Shagara complex, 2,320 of them were a mix of M16-pattern shotguns or breech-loading double barrel shotguns. While an uncommon sight, double barrel shotguns have been seen in use by the RSF in West Darfur,¹⁹² other types of shotguns and ”hunting rifles” are very often used by all sides of the conflict as documented in various cases above. 

States must comply with international law in overseeing the transfer of arms from their territory to that of other states, particularly those subject to armed conflict. The Arms Trade Treaty places various duties upon States to control and assess whether their arms exports and transfers might be used to carry out crimes under international law or serious human rights violations. All states parties, including China and Serbia, and signatories, including Türkiye and the UAE, have specific obligations. 

Under Article 6 of the Arms Trade Treaty, states parties are prohibited from authorizing any transfer (i.e export, import, transit, trans-shipment and brokering) of arms, ammunition and parts and components that would violate UN Security Council Chapter VII measures, in particular arms embargoes, or a state party’s existing relevant treaty obligations. In addition, transfers are prohibited where a state has knowledge that the arms being considered for authorisation would be used in the commission of genocide, crimes against humanity, or grave breaches of the Geneva Conventions of 1949.¹⁹³ 

Once a state party establishes that a transfer is not prohibited under Article 6, it must carry out an objective and non-discriminatory assessment of each proposed arms export as required by Article 7. This includes assessing whether there is a substantial risk that the arms or related items could be used to commit or facilitate a serious violation of international human rights law or international humanitarian law. If this risk cannot be effectively addressed and mitigated, then the transfer should not take place.¹⁹⁴ 

Under Article 11, an exporting state party must take measures to prevent the diversion of conventional arms covered by Article 2(1) of the treaty. If a state party detects a diversion of conventional arms the state party must take measures to address this, such as alerting potentially affected state parties, examining diverted shipments and taking follow-up measures through investigation and law enforcement.¹⁹⁵ 

Signatories to the ATT must refrain from acts which would defeat the object and purpose of the treaty outlined in Article 1.¹⁹⁶ This includes establishing “the highest possible common international standards for regulating or improving the regulation of the international trade in conventional arms”, eradicating “the illicit trade in conventional arms and prevent their diversion” for the purpose of “contributing to international and regional peace, security and stability”, “reducing human suffering” and “promoting cooperation, transparency and responsible action by States Parties in the international trade in conventional arms…”.¹⁹⁷ 

As a part of their obligation to respect and ensure respect for international humanitarian law (IHL), all states are prohibited from transferring or permitting private actors to transfer weapons to a party to an armed conflict – whether a state or non-state armed group – where there is a clear risk that this would contribute to the commission of IHL violations. Common Article 1 of the Geneva Conventions requires all states to “undertake to respect and to ensure respect for the present Convention in all circumstances.”¹⁹⁸  According to the International Committee of the Red Cross’s (ICRC) commentary on Article 1 this requires that states “refrain from transferring weapons if there is an expectation, based on facts or knowledge of past patterns, that such weapons would be used to violate the Conventions.”¹⁹⁹IHL does not just bind states, but also private actors including armed groups and corporations whose activities have a nexus to an armed conflict.²⁰⁰ Therefore, corporate actors involved in the transfer of weapons to Sudan may also contribute to IHL violations which, if implemented with knowledge that said weapons will likely be used to commit international crimes, may also entail criminal responsibility.²⁰¹ 

There is a clear global consensus that companies have a responsibility to respect human rights throughout their global operations including with respect to the manufacture, export, import, and sale of arms that may be used to commit serious human rights violations, as reflected in the UN Guiding Principles on Business and Human Rights.²⁰² Although States have an obligation to regulate the arms industry,²⁰³ the corporate responsibility to respect human rights exists over and above obligations to comply with national laws and regulations.²⁰⁴ This responsibility requires companies to conduct human rights due diligence throughout their entire value chain to identify, prevent, and mitigate any actual or potential involvement in human rights abuses.²⁰⁵  

In light of the substantial risk that all arms and ammunition being transferred to Sudan – including those marketed to civilians – will be used by parties to the conflict to commit grave human rights abuses, companies must immediately cease their involvement in this supply of arms to avoid causing or contributing to these abuses. If a company identifies that they sold have contributed to such abuses, they should provide for or cooperate in remediation process to any persons harmed as a result.²⁰⁶ 

The standard of human rights due diligence required is heightened with respect to business activity impacting conflict-affected areas.²⁰⁷ In such cases, heightened human rights due diligence requires that companies conduct an ongoing assessment of the conflict more broadly including by reviewing independent reporting on the conflict by inter-governmental organizations, international and local NGOs, and community groups to identify and log all instances of involvement of their products in incidents of suspected violations of international human rights and humanitarian law. Companies also need to assess further risks to human rights on an ongoing basis including the risk of harm to vulnerable populations and the risk of arms diversion, which are rife with respect to the conflict in Sudan.²⁰⁸  

The corporate responsibility to respect human rights applies equally to all companies in the arms industry regardless of how directly involved they may be in the transfer of arms to Sudan.²⁰⁹ For instance, where an arms manufacturer receives information or otherwise identifies that weapons they produced have been used to commit grave human rights abuses in Sudan, their products may be directly linked to these abuses within the meaning of the UN Guiding Principles on Business and Human Rights.²¹⁰ The term “directly linked” is defined to exclude extremely loose connections to a company‘s operations, products or services; as such, a human rights harm may be directly linked to a company’s products via indirect business relationships beyond the first tier.²¹¹  

An arms manufacturer is required to conduct due diligence throughout their entire value chain, from the point of origin to the end users, in order to determine whether and how their arms ended up in the hands of the party to the conflict that committed these abuses. Once they have mapped this value chain, the manufacturer must use their leverage with the relevant business relationships – whether those are customers, dealers, distributors, brokers, transporters, financiers, or others – to prevent future arms transfers to Sudan. For instance, a condition that end users will comply with international human rights and humanitarian law in using the company’s products and services should be built into commercial contracts, with the possibility of products and services being suspended or withdrawn if this condition is not clearly met.²¹² If the manufacturer lacks the requisite leverage to prevent these transfers, they can seek to increase their leverage by offering incentives or engaging with state actors, or alternatively they can consider end the business relationship.²¹³ 

Given the longstanding, widely documented, serious violations of international human rights and humanitarian law that have plagued Sudan for over two decades, and the escalating violence which has triggered thousands of civilian deaths and massive displacement, all states must cease arms transfers to the whole of Sudan, and exercise extreme caution when considering arms exports to the wider region. 

To SAF and RSF

• Immediately end all deliberate attacks on civilians and civilian objects as well as indiscriminate attacks and attacks disproportionately affecting civilians and civilian objects, including the use of explosive weapons with wide area effects, including imprecise projectiles, in the vicinity of civilians. 
• Allow and facilitate rapid and unhindered access for humanitarian actors to ensure aid reaches all those in need, as well as protect humanitarian relief personnel and facilities, and end all attacks on humanitarian workers. 
• Immediately end rape and other sexual violence against women and girls across the country and ensure there are credible investigations, adequate punishment of perpetrators, treatment, and full reparation for survivors. 
• Ensure accountability for past and recent crimes under international law and other serious violations and abuses in Sudan, including by surrendering the suspects wanted by the International Criminal Court and by fully cooperating with the UN fact-finding mission on Sudan. 

To all countries sending arms and ammunitions and other supplies to the SAF and RSF and other armed groups in Sudan

• Immediately cease supplies of all arms and ammunition to Sudan, including the direct or indirect supply, sale or transfer of arms and military materiel, related technologies, parts and components, technical assistance, training, financial or other assistance.  
• Urgently investigate the transfer of weapons aimed at the civilian market, such as shotguns, hunting rifles, blank guns and related ammunition, to parties to the conflict, and ensure all these weapons are explicitly covered by national arms control regimes, and that all future transfers to Sudan are prohibited. 
• Take all measures necessary to regulate the arms industry by implementing rigorous licensing procedures for the export, transit and import of arms on a case-by-case basis, including full details of the brokers, transporters, and financiers involved in each transaction, whereby a license is only issued if the proposed arms transfers will not be delivered or diverted to Sudan. In this regard, companies should be required to conduct and share the findings of their human rights due diligence to receive a license to transfer arms as a matter of national legislation. 
• Take all measures necessary to prevent the diversion of arms, including by exercising extreme caution in relation to arms transfers to the wider region, and through information sharing, investigation and law enforcement.  

To all companies in the arms industry, including those named above

• Immediately cease any involvement in the transfer of arms and ammunition to Sudan, directly or indirectly, including of weapons marketed for civilian use. 
• Urgently conduct heightened human rights due diligence throughout the company’s value chain to identify, prevent, and mitigate any actual or potential involvement in human rights abuses that are directly linked to the arms a company manufactures, exports, imports, or sells. 
• Use all leverage at a company’s disposal via business relationships with customers, dealers, distributors, brokers, transporters, financiers, and others identified throughout a company’s value chain to prevent the supply or diversion of any arms or ammunition to Sudan, including by inserting a condition that end users will comply with international human rights and humanitarian law in using the company’s products and services into commercial contracts. 
• Publicly communicate the company’s policies and practices for preventing and mitigating actual or potential adverse human rights impacts identified throughout their value chain including by providing frequent updates on measures taken to address ongoing developments with respect to the armed conflict in Sudan, to the greatest extent possible under the law.  
• Provide for or cooperate in remediation processes where the company has identified that they have caused or contributed to human rights abuses using weapons they have manufactured, exported, imported, sold, or otherwise transferred, directly or indirectly, into Sudan. 

To The UN Security Council

• Expand the arms embargo regime that currently applies to Darfur to the rest of Sudan – given the significant escalation of the violence and its impact on civilians, and the flagrant violation of the existing embargo by various actors who are fuelling the Sudan conflict. The expansion of the arms embargo must be accompanied by a comprehensive and effective mechanism to prevent international sales and prevent illicit transfers of arms to Sudan. Ensure that adequate human and other resources are allocated to the UN Panel of Experts and the UN Secretariat to conduct investigations to help ensure compliance with the UN arms embargo on Sudan. 
• Thoroughly investigate all breaches of the arms embargo, including evidence of systematic diversion of weapons designed for the transfer of weapons aimed at the civilian market, such as shotguns, hunting rifles, blank guns and related ammunition, to parties to the conflict both during ongoing conflict and before April 2023. 
• As a step towards an extended embargo, call on all countries to respect and enforce the current UN Security Council’s arms embargo regime on Darfur by ending all transfers of weapons and ammunition to the SAF, the RSF and other armed actors. Ensure that all countries and entities that have violated the Darfur arms embargo are held accountable. 
• Expand the referral of the situation in Darfur to the ICC to also include investigation and prosecution of crimes under international law, in the rest of Sudan.  
• Provide funding to the ICC for the investigation and prosecution of crimes under international law in Sudan including those committed in the context of the current conflict.  

To the African Union Peace and Security Council

• Support and work with the UN Security Council to expand and enforce the arms embargo regime that currently applies to Darfur to the rest of Sudan – given the significant escalation of the violence and its impact on civilians, and the flagrant violation of the existing embargo by various actors who are fuelling the Sudan conflict. 
• Call on all countries to immediately cease supplies of all arms and ammunition to Sudan, including the direct or indirect supply, sale or transfer of arms and military materiel, related technologies, parts and components, technical assistance, training, financial or other assistance. 
• As a step towards the extension of the UNSC embargo to the whole of Sudan, call on all countries to respect and enforce the UN Security Council’s arms embargo regime on Darfur by ending and refraining from transfers of weapons and ammunition to the SAF, the RSF and other armed actors. Ensure that all countries and entities that have violated the Darfur arms embargo are held accountable. 
• Call on all parties to the conflict in Sudan to end all attacks on civilians and civilian infrastructure and ensure unhindered and immediate humanitarian access.  
• Publicly support the Fact-Finding Mission established by the United Nations Human Rights Council in October 2023 and call on the Sudanese authorities to fully cooperate with the mission including by facilitating access to the country. 

To Sudan’s neighbouring countries, notably Chad, Egypt, Central Africa Republic (CAR), South Sudan, Ethiopia, Eritrea and Libya

• Immediately cease and refrain from facilitating the transfer of weapons and ammunitions to Sudan’s SAF and RSF and other armed actors. Ensure all individuals and entities in your countries that  are facilitating the transfer of weapons and ammunitions to Sudan are held accountable. 
• Keep the borders open and remove movement restrictions and ensure those fleeing the conflict are not rejected at the borders, are protected against refoulement, and have prompt access to asylum procedures.  
• Ensure unimpeded humanitarian access for aid organizations and others that are responding to those fleeing the conflict in Sudan. 

To Sudan’s international partners, including the EU, KSA, UK, US, and others

• Call on all countries to immediately cease supplies of all arms and ammunition to Sudan, including the direct or indirect supply, sale or transfer of arms and military materiel, related technologies, parts and components, technical assistance, training, financial or other assistance. 
• Work with the UN Security Council to expand the arms embargo regime that currently applies to Darfur to the rest of Sudan – given the significant escalation of the violence and its impact on civilians, and the flagrant violation of the existing embargo by various actors who are fueling the Sudan conflict.  
• As a step towards the extension of the UNSC embargo to the whole of Sudan, call on all countries to respect and enforce the UN Security Council’s arms embargo regime on Darfur by ending and refraining from transfers of weapons and ammunition to the SAF, the RSF and other armed actors. Ensure that all countries and entities that have violated the Darfur arms embargo are held accountable. 
• Call on parties to the conflict in Sudan to end all attacks on civilians and civilian infrastructure and ensure unhindered and immediate humanitarian access.  
• Open safe and legal pathways and ensure protection and support for people fleeing Sudan. Refrain from returning Sudanese nationals to Sudan or to any third country where they may be at risk of being returned to Sudan.  
• Increase emergency funding for humanitarian response in Sudan, as well as in refugee camps in neighbouring countries. Ensure specific support for putting in place protection, care, treatment, and support mechanisms for survivors of sexual violence.  
• Protect and promote the work of human rights defenders, activists, journalists, and civil society actors still in Sudan and at risk of attacks and violence. This should include concrete support and emergency travel documentation for those who need to leave Sudan for their safety. In parallel, pro-actively foster contact and ensure longer-term support to Sudanese Human Rights Defenders (HRDs) in exile to be able to continue their important work.  

To the UN Human Rights Council

• Extend the mandate of the Fact-Finding Mission on Sudan for at least one year to allow it to pursue its important documentation and reporting work. 
• Ensure that the Fact-Finding Mission is properly staffed and resourced to be able to fulfil its mandate.