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South Sudan

Executive Summary

Trade and investment conditions in South Sudan have slightly improved in the past year, but many challenges remain.  In September 2018, parties to the country’s civil war signed a new peace agreement. While implementation of the agreement is still underway, as of April 2019 hostilities had ceased in most parts of the country.  However the country continues to be plagued by large-scale displacement, widespread food insecurity, severe human-rights abuses, restricted humanitarian access, and harassment of aid workers and journalists.

South Sudan is one of the most oil-dependent economies in the world, but the sector is fraught with corruption.  In March 2018, the United States Department of Commerce added the Ministry of Petroleum, the Ministry of Mining, and state-owned oil company Nilepet to the Entity List, barring export of certain U.S. goods or technologies to them due to their contribution to the conflict.

Humanitarian and development aid is a major source of employment in South Sudan.  Difficulties of changing regulations, multiple layers of taxation, and labor harassment faced in this sector may provide insight to difficulties private investors would face.  Bureaucratic impediments faced by NGOs include recruitment interference, airport obstructions, and duplicate registration and permit issues by different levels of authority.

The government has made efforts to simplify and centralize taxation, with the creation of the National Revenue Authority.  The Bank of South Sudan has launched a website where it posts key financial data. However, the legal system is ineffective, underfunded, overburdened, and subject to executive interference and corruption.  High-level government and military officials are immune from prosecution and parties in contract disputes are sometimes arrested and imprisoned until the party agrees to pay a sum of money, often without going to court and sometimes without formal charges.

Other factors inhibiting investment in South Sudan include limited physical infrastructure and a lack of both skilled and unskilled labor. The World Bank’s 2019 Doing Business report ranked South Sudan 185 out of 190 economies on overall ease of doing business. The legal framework governing investment and private enterprises remained underdeveloped as of April 2019.

The U.S. Department of State maintains a Travel Advisory warning against travel to South Sudan due to critically high risks from crime, kidnapping, and armed conflict.

Table 1: Key Metrics and Rankings

Measure Year Index/Rank Website Address
TI Corruption Perceptions Index 2018 178 of 180 
World Bank’s Doing Business Report 2019 185 of 190
Global Innovation Index 2018 N/A of 126 
U.S. FDI in partner country ($M USD, stock positions) 2018 N/A 
World Bank GNI per capita 2018 N/A 

1. Openness To, and Restrictions Upon, Foreign Investment

Policies Towards Foreign Direct Investment

As of April 2019, the government was actively seeking foreign direct investment, but had not undertaken meaningful steps to facilitate it.  Reported unfair practices have included effective expropriation of assets, inconsistent taxation policies, harassment by security services, extortion attempts, and a general perception that foreigners are not afforded fair results in court proceedings or labor disputes.

The country makes few investment facilitation efforts. The South Sudan Investment Authority (SSIA) has been established as has, in theory, a One Stop Shop Investment Center.  However, both organizations are poorly resourced and neither maintains an active web site. There is no business registration website. The ministries that handle company registration include the Ministry of Trade and Industry, Ministry of Finance, and Ministry of Justice. There is no single window registration process, and an investor must visit all the above mentioned agencies to complete the registration of a company.  It is estimated that the registration process could take several months.

In January 2018, South Sudan joined the African Trade and Insurance Agency (ATI), which provides export insurance and other assistance to foreign investors and traders.  Several local lawyers are willing to advise investors and guide them through the registration process, for a fee. The government has held investment conferences and organized an investment roadshow.  There is a private-sector Chamber of Commerce. There is no ombudsman.

Limits on Foreign Control and Right to Private Ownership and Establishment

Foreign and domestic private entities have the right to establish and own business enterprises and engage in all forms of remunerative activity, as well as freely establish, acquire and dispose of interests in business enterprises.  Under the investment law, the government of South Sudan leases land to foreign investors for limited periods of time, generally not to exceed 30-60 years, with the possibility of renewal. In the case of leases for mining or quarrying, the lease shall not exceed the life of the mine or quarry.  Under the 2009 Land Act, non-citizens are not allowed to own land in South Sudan.

For investors who wish to start a business in South Sudan, there is a local shareholder requirement but the foreign investor can usually retain majority control.  For foreign-based companies who wish to establish a subsidiary in South Sudan, the local shareholder requirement does not apply. South Sudanese businesses are given priority in several areas, including micro-enterprises, postal services, car hire and taxi operations, public relations, retail, security services, and the cooperative services.  Exact details, and the extent of enforcement of these requirements, are sometimes unclear.

Subject to the Private Security Companies Rules and Regulations of 2013, registering and setting up a protection services security company in South Sudan requires a South Sudanese citizen to hold at least 51 percent of the company.  Companies in the extractives sector must also have a South Sudanese national as part owner, but the exact percentage of ownership required is not always clear.

According to the Investment Act, foreign investors must apply for an investment certificate from the South Sudan Investment Authority to ensure that the investment will be beneficial to the economy or general benefit of South Sudan.

Other Investment Policy Reviews

In the past three years, the government has not undergone any third-party investment policy reviews.

Business Facilitation

The Government’s fiscal and economic strategy sees government facilitating investment in economic priority sectors, particularly in agriculture, transport infrastructure, petroleum, mining, and energy, to unlock South Sudan’s economic potential and boost diversified growth.  Investment incentives exist but the exact procedures are somewhat opaque.

There is no business registration website.  The process to register a business is lengthy and complex, and involves visiting multiple offices at the national, state, and local levels.  The Chamber of Commerce recommends hiring a local lawyer to register a business.

Outward Investment

The Government of South Sudan does not have a policy for promoting or incentivizing outward investment.  The government does not have a policy restricting domestic investors from investing abroad.

2. Bilateral Investment Agreements and Taxation Treaties

South Sudan signed a Bilateral Investment Treaty (BIT) with Morocco in 2017 but it is not in force.

In November 2018 a South African government fund signed an agreement with South Sudan pledging USD 1 billion for oil exploration and construction of a refinery.  The agreement was made between two state-owned companies but is not a general BIT.

South Sudan does not have a bilateral taxation treaty with the United States and does not have a tax agreement with any other countries.  Contacts have reported that in practice, business owners can be subject to a range of unexpected taxes from a variety of levels of authority.

4. Industrial Policies

Investment Incentives

The Investment Promotion Act provides for various tax incentives, including capital allowances ranging from 20 to 100 percent of eligible expenditures, deductible annual allowances ranging from 20 to 40 percent, and depreciation allowances ranging from 8 to 10 percent.  A foreign tax credit is granted to any resident company paying foreign taxes on income from business activities outside South Sudan. In practice, the exact incentive structure is somewhat unclear.

Applications for fiscal incentives are made to the Ministry of Finance, Commerce, Investment and Economic Planning through the One Stop Shop Investment Centre (OSSIC).  Tax exemptions and concessions on machinery, equipment, capital and net profits are approved for stated periods by the Ministry of Finance, at its discretion. Fiscal incentives also include capital allowances, deductible annual allowances and annual depreciation allowances.

The government has been known to guarantee foreign direct investment projects with oil deliveries.  However, due to a lack of transparency at the Ministry of Petroleum, it is unclear to what extent the country’s oil production has been leveraged and thus it is impossible to ascertain the likelihood of the country being able to honor such commitments.

Foreign Trade Zones/Free Ports/Trade Facilitation

South Sudan has not established any free trade zones. On June 22, 2013 the government of South Sudan announced the construction of Juba Specialized Economic Zone (SEZ) near the capital.  It was intended to be an industrial area for business and investment activities but development of the area has not progressed.

Performance and Data Localization Requirements

South Sudan’s 2017 Labor Act dictates that 80 percent of staff at all levels of management must be South Sudanese nationals.  Additionally, authorities in some areas of the country have demanded that NGOs employ people local to a specific area, or from a specific ethnic group, although there is no basis for this practice in South Sudanese law.  The law makes no specific mention of senior management and boards of directors. The government requires work permit fees for foreign nationals. These are typically several thousand dollars per employee, but the exact amounts change regularly.  Foreigners are also subject to a variety of registration requirements, which also change regularly and unpredictably.

In consideration of entitlement to an investment certificate, the Investment Act encourages, but does not require, technology transfer, increase in foreign exchange through exports or import substitution, production and use of local raw materials and supplies, and contributions to the local community.  For entitlement to an investment certificate, the Investment Authority is required by law to assess if the investment will create employment for South Sudanese, acquire new skills of technology for South Sudanese, and contribute to tax revenues. The use of domestic content in goods or technology is encouraged, but not required.

The Investment Authority may revoke an investment certificate due to breach of performance requirements, with 30 days notice.  There are no provisions regarding maintenance, increase, or decrease of performance requirements.  The Investment Act applies these requirements equally to domestic and foreign investors.

There are no known requirements for foreign IT providers to turn over source code or provide access to encryption.  No measures are known to exist to prevent companies from transferring customer or other business data outside the country.  There are no known rules on maintaining data storage within the country.

5. Protection of Property Rights

Real Property

There was no progress in 2018 towards comprehensive land reform. Laws on mortgages, valuation, and the registration of titles have not been drafted.  While the 2009 Land Act and the 2009 Investment Promotion Act both state that non-citizens can access land for investment purposes, by leasing the land but not owning it, clear regulations governing how a business acquires land were not available in 2018.

Currently, some businesses lease land from the government, while others lease land directly from local communities and/or individuals. Under the Land Act, investment in land acquired from local communities must contribute economically and socially to the development of the local community.  Businesses will often sign a memorandum of understanding with the local communities in which they agree to employ locals or invest in social services in exchange for use of the land. Land negotiations with communities often require several months or longer to complete. South Sudan ranked 179 out of 185 countries for ease of registering property in the World Bank’s 2019 Doing Business Report.

Ownership of land is often unclear, with communities and government both claiming the same property. In some cases, multiple individuals hold registration certificates demonstrating sole ownership of the same piece of land.

As of April 2019, over 4 million South Sudanese were still displaced from their homes due to conflict.  During the five-year civil war, many of their houses were illegally occupied and likely remain so. Property owners or public authorities may file for an order to evict unauthorized occupants under the Land Act.  While the rightful owners may hold clear land titles, it is unclear if the legal system is equipped to handle their claims and it is likely that land ownership will be regularly disputed throughout large parts of the country in the foreseeable future.

Intellectual Property Rights

The legal structure for intellectual property rights (IPR) is weak and enforcement is lax.  Recorded instances of intellectual property theft are rare. While the Investment Act of 2009 includes an article on the protection of IPR, implementing legislation on trademarks, copyrights, and patents has not yet been passed.  To date, the only intellectual property law which has been put forward to the legislature is the Trade Marks Bill of 2013. No new IP-related laws or regulations were enacted in 2018.

South Sudan does not track or seize counterfeit goods.  There has been no known prosecution of IPR violations and there are no estimates available for traffic of counterfeit goods. There was one report of an unauthorized public screening of a U.S. film in 2018.

South Sudan is not included in the United States Trade Representative (USTR) Special 301 Report or the Notorious Markets List.

For additional information about national laws and points of contact at local IP offices, please see WIPO’s country profiles at

6. Financial Sector

Capital Markets and Portfolio Investment

The Investment Act mentions portfolio investment, but South Sudan does not have a functioning market for financial assets.  South Sudan does not have a stock market or related regulatory system. There are no known policies for promotion of investment into product and factor markets.

South Sudan’s formal financial system offers few financial products. It is difficult for foreign investors to get credit on the local market due to the shortage of hard currency, the lack of accurate means of obtaining reliable figures or audited accounts, the absence of a credit reference bureau, and South Sudan’s failure to document land ownership properly.  According to the World Bank, 50 percent of all South Sudanese firms cite access to finance as a constraint.

Banks are often unwilling to lend due to the lack of adequate laws to protect lenders and difficulties related to personal identification.  After the Bank of South Sudan confiscated commercial banks’ reserves on deposit at the central bank in 2015, diverting them to the use of the government, companies and individuals had difficulty accessing their funds.  This made depositors reluctant to trust their funds to the banking system.

The Bank of South Sudan launched treasury bills on August 18, 2016 for purchase by members of the public, companies and commercial banks.  This lasted until April 2017, when people stopped investing in the bills due to high inflation and a lack of a secondary market for them. The bank had previously issued treasury bills in 2012 without success.

Money and Banking System

Activity in the banking system grew after independence for a period until it deteriorated in 2014 due to civil conflict and the reduction of oil exports. The economy of South Sudan is cash-based, with limited use of demand deposits. The IMF has categorized South Sudan’s financial sector as small and undeveloped.  South Sudan has recently introduced mobile money. Informal unauthorized transfer services already exist, but mobile money services should allow for greater access to domestic banking services.

There is limited information to assess the health of this sector and figures are unreliable.  The Bank of South Sudan, the country’s central bank, has limited assets. There are a total of nine foreign-owned banks.  There are no known additional regulations for foreign banks. There are no known restrictions on a foreigner’s ability to establish a bank account.

Foreign Exchange and Remittances

Foreign Exchange

Foreign investors cannot remit funds through the parallel market. They are required by law to remit through banks or foreign exchange bureaus at an exchange rate that is far below the market rate.

The 2009 Investment Promotion Act guarantees unconditional transferability in and out of South Sudan “in freely convertible currency of capital for investment; payments in respect of loan servicing where foreign loans have been obtained; and the remittance of proceeds, net of all taxes and other statutory obligations, in the event of sale or liquidation of the enterprise.” In reality, the ability to exchange local currency for foreign currency is severely restricted.

South Sudan maintained a fixed exchange rate for the South Sudanese Pound until December 2015 when it moved to a managed floating exchange rate regime.  Since then, the local currency has depreciated significantly due to deficit spending by the government, printing of money, and a lack of hard currency. The current official exchange rate can be found from the Bank of South Sudan or from commercial banks in Juba.  There is a large spread between this rate and the unofficial parallel market rate.

Remittance Policies

There have been no recent changes to investment remittance policies, and no known waiting periods on remittances.

Sovereign Wealth Funds

The Petroleum Revenue Management Act of 2013 created a sovereign wealth fund (SWF) to set aside surplus profits from oil sales.  The law established the Oil Revenue Stabilization Account to act as a buffer against volatility in oil prices and the Future Generations Fund to set aside some funds for future generations.  The SWF is supposed to distribute 10 percent of oil profits into the Oil Revenue Stabilization Account and 15 percent to the Future Generations Fund. To date, however, neither has received any financing.  The Comprehensive Peace Agreement (CPA) that ended the civil war with Sudan set a 2 percent share of oil revenue that is supposed to be given to the oil producing states along with 3 percent revenue allocation to the local communities.  However, in August 2017, the government announced that it would stop giving the 3 percent and 2 percent share to states. The September 2018 peace agreement calls for the accounts to be funded. The SWF does not follow any good practices and being unfunded, does not invest domestically (although it is intended to).

8. Responsible Business Conduct

The idea of responsible business conduct is new in South Sudan, and there is little awareness of standards in this area.  The few large international firms operating in South Sudan sometimes offer some basic benefits to local communities, but on an irregular basis. The 2009 Land Act requires investment activities carried out on land acquired from local communities to “reflect an important interest for the community or people living in the locality,” and to contribute economically and socially. There are complaints in the media about the number of foreign-owned companies and the lack of hiring of South Sudanese employees.  International observers have argued that many of the oil producing companies do not practice responsible behavior in regard to environmental damage in the oil fields.

The government has taken no steps towards RBC.  The recently signed peace agreement and some national laws (such as the Petroleum Act) contain RBC provisions but they are unenforced.  The environmental and human rights impact of oil pollution has been severe but the government has not responded to widespread damage to the environment and displacement of people.  The government has demonstrated little capacity or will to enforce laws on human rights, labor rights, consumer protection, environmental protections, and other laws/regulations intended to protect individuals from adverse business impact.  The government has not put in place corporate governance, accounting, and executive compensation standards to protect shareholders.

NGOs have promoted RBC, particularly in the environmental domain, but activists and reporters in this field have reported that they are subject to government harassment.

The government does not encourage adherence to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Afflicted and High-Risk Areas, and there are no functioning domestic measures related to such due diligence.  South Sudan is a source of minerals originating from conflict-affected areas and there is little oversight to the extractive industries such as gold.

The government does not participate in the Extractive Industries Transparency Initiative (EITI) and while the law requires the disclosure of payments made to the government in regard to oil sales, in reality disclosure is weak or nonexistent.

9. Corruption

South Sudan has laws, regulations, and penalties to combat corruption, but there is a near total lack of enforcement and considerable gaps exist in legislation.  As a result, corruption is pervasive.

Companies are reportedly asked to pay extralegal taxes and fees.  Security officials have been reported to impose business conditions including payment of fees, salaries, and logistical support to their operations.  In practice, politically connected people are immune to prosecution. There are no laws that prevent conflict of interest in government procurement.

The government does not encourage or require private companies to establish internal codes of conduct that, among other things, prohibit bribery of public officials.  There is no indication that private companies use internal controls, ethics, and compliance programs to detect and prevent bribery of government officials.

The South Sudan Anti-Corruption Committee (SSACC) was established in accordance with the 2005 Constitution and the 2009 SSACC Act. The five commission members and chairperson are appointed by the President with approval by a simple majority in the parliament. The commission is tasked with protecting public property, investigating corruption, and submitting evidence to the Ministry of Justice for necessary action.  In addition, the commission is tasked with combatting administrative malpractice in public institutions, such as nepotism, favoritism, tribalism, sectionalism, gender discrimination, bribery, embezzlement, and sexual harassment.

In reality, the SSACC lacks the resources or political capital to investigate corruption.  It has no capacity to address state corruption as it can only relay its findings to the Ministry of Justice for prosecution.  There were no significant anti-corruption cases investigated or prosecuted in 2018.

South Sudan acceded to the United Nations Convention against Corruption on January 23, 2015 but has not yet ratified it.  The country is not a party to the OECD Anti-Bribery Convention and is not reported to be a participant in regional anti-corruption initiatives.

The country provides no protection to NGOs involved in investigating corruption.  NGOs of all types are routinely subject to government harassment.

All major sectors including the extractive sector, hotels, airlines, banking, and security sectors are subject to interference from the security sector including recruitment interference, and payment of fees and salaries.

Corruption appears to be pervasive at all levels of government and society. The regulatory system is poor or non-existent, and dispute settlement is weak and subject to influence.

Resources to Report Corruption

National Audit Chamber
P.O. Box 210
Juba, South Sudan
Tel: +211 (0) 955 481 021

Honorable Ngor Kulong Ngor
South Sudan Anti-Corruption Commission
P.O Box 312
Juba, South Sudan

Honorable Awad Masha Zigizo
South Sudan Anti-Corruption Commission
P.O Box 312
Juba, South Sudan

Contact at “watchdog” organizations:

UN Panel of Experts on South Sudan
Mr. David Biggs (Senior Committee Secretary)
Tel: (212) 963-5598

Transparency International
Alt-Moabit 96
10559 Berlin
Telephone: +49 30 3438 200
Fax: +49 30 3470 3912

The Sentry
c/o The Enough Project
1420 K Street, NW, Suite 200
Washington, DC 20005

10. Political and Security Environment

There is a long history of politically motivated violence in South Sudan.  The warring parties concluded a peace agreement in September 2018 to stop the civil war that has wrought the country since 2013.  Limited fighting continues in some parts of the country as of April 2019, but in general, the ceasefire has held. The effects of the war on the economy and investment will be evident for some time.

Previous violence during conflict with Sudan resulted in damage to installations in one of the major oil producing areas in the country, shutting down production in that region.  Repairs to these facilities began in 2018, allowing for an increase in oil production.

The environment remains insecure but hopes of peace have been rekindled with signing of a new peace agreement in September 2018.  The parties, however, remain behind in implementation as of April 2019.

There were 1.9 million Internally Displaced Persons (IDPs) in South Sudan, and an additional 2.3 million South Sudanese refugees in neighboring countries as of April 2019.  The government has not yet developed the conditions that would allow the IDPs and refugees to safely return home. Political opposition leaders faced illegal detention and travel restrictions in 2018.  The government has temporarily shut down several newspapers and detained journalists it accused of printing articles opposing policies or actions undertaken by the government.

The conflict severely disrupted trade, markets, and agricultural activities, claimed thousands of lives and spurred one of the world’s most serious humanitarian crises. The conflict was marked by grave human rights abuses, especially pervasive gender-based violence.  Out of a population of approximately 12 million, some 6.5 million people are in need of food assistance in South Sudan. During 2018, the bulk of U.S. and the international community’s support efforts were directed at the immediate needs of the ongoing humanitarian crisis brought on by the civil conflict.  Other development assistance has been significantly reduced.

NGOs complain of harassment, and aid convoys have come under attack in 2018.  South Sudan was named the most dangerous country in the world for aid workers in 2018.  Armed cattle raids claimed hundreds of lives in 2018, and several ambushes and kidnappings have taken place on the country’s main highway, the Juba-Nimule road.  The Department of State currently warns against travel to South Sudan due to the critically high risk of crime, kidnapping, and armed conflict.

11. Labor Policies and Practices

South Sudan has a shortage of both skilled and unskilled workers across most areas in the formal sector.  According to the 2008 census, 84 percent of those employed are in non-wage work. Unskilled labor in the service and construction sectors is often performed by immigrants from neighboring countries.  This is in large part due to a lack of basic skills training. South Sudan has one of the worst adult literacy rates in the world: about 27 percent.

The five-year civil war has resulted in large swaths of people displaced from their homes (over 4 million are displaced or refugees as of April 2019) and has devastated the economy.

Government enforcement of existing labor laws has been absent. Most small South Sudanese businesses operate in the informal economy, where labor laws and regulations are widely ignored.

The Labor Act of 2017 requires that 80 percent of staff hired by foreign employers at all levels of management be nationals of South Sudan.  Government security offices have been reported to interfere with hiring in some cases. The Ministry of Labor thoroughly reviews all work permit applications in an attempt to determine whether a position could be filled by a South Sudanese national.  Some foreign-owned companies reported long delays in receiving work permits for expatriate staff, and many expatriates are issued work permits for just one to three months, rather than the standard one year. State and local authorities have also been reported to charge additional fees and attempt to restrict employment to people from a certain place or of a certain ethnic group.

The Labor Act establishes an “employment exchange” scheme for unemployed people that reserves vending, hawking, driving, office support staffing and other manual labor for nationals only.  No social safety net programs exist in practice. The Labor Act allows for Termination for Redundancy “due to changes in the operational requirements of the employer” with certain conditions, and requires severance pay.  The law differentiates between this and several other forms of termination.

There are no special labor provisions in order to attract or retain investment.  No formal functioning collective bargaining systems exist. Disputes are handled by the Ministry of Labor, by courts, and informally/extrajudicially.  Foreign employers have reported being at a significant disadvantage in such disputes.

In July 2018, a mob of hundreds described as local youths attacked NGO facilities causing millions of dollars in damages in Maban.  The government was slow to respond or investigate, and ultimately released the attack’s ringleaders shortly after arresting them. In 2018, some international organizations reported labor strikes from day wage-earners.  Some international organizations reported strikes or blockages where locals protested against the employment of South Sudanese from different ethnic groups perceived to be receiving favored treatment.

Child labor is rampant and the government does not enforce child labor laws through inspections or fines.

The most recent change to labor law was the Labor Act signed by the South Sudanese President in December 2017.

12. OPIC and Other Investment Insurance Programs

There is a potential for successful OPIC operations in South Sudan if the security environment continues to improve.  The Overseas Private Investment Corporation (OPIC) has been open to business in South Sudan since 2012. South Sudan ratified its Investment Incentive Agreement (IIA) with OPIC in 2013.  South Sudan is a member country of the Multilateral Investment Guarantee Agency.

13. Foreign Direct Investment and Foreign Portfolio Investment Statistics

Table 2: Key Macroeconomic Data, U.S. FDI in Host Country/Economy

Host Country Statistical Source USG or International Statistical Source USG or International Source of Data:
BEA; IMF; Eurostat; UNCTAD, Other
Economic Data Year Amount Year Amount
Host Country Gross Domestic Product (GDP) ($M USD) N/A N/A 2016 $2,904   
Foreign Direct Investment Host Country Statistical Source USG or International Statistical Source USG or International Source of Data:
BEA; IMF; Eurostat; UNCTAD, Other
U.S. FDI in partner country ($M USD, stock positions) N/A N/A N/A N/A BEA data available at  
Host country’s FDI in the United States ($M USD, stock positions) N/A N/A N/A N/A BEA data available at  
Total inbound stock of FDI as % host GDP N/A N/A N/A N/A UNCTAD data available at    


Table 3: Sources and Destination of FDI

Data not available.

Table 4: Sources of Portfolio Investment

Data not available.

14. Contact for More Information

Economic/Commercial Officer
U.S. Embassy, Kololo Road, Juba, South Sudan
(U.S.) +1 (202) 216-6279, ext 215

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