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Sudan

No Guidance Risk: unknown Updated 79 days ago Research: Grade A

Overview

Sudan operates under a de facto prohibition on crypto assets, with no dedicated VASP licensing framework; the Central Bank of Sudan (Bank of Sudan) has repeatedly issued binding circulars since at least 2018 declaring virtual currencies unrecognized and illegal within the Sudanese banking system, and no activity threshold triggers a licensing pathway. The National Anti-Money Laundering and Combating the Financing of Terrorism Act 2014 provides the broader enforcement basis, under which violations — including holding, trading, or facilitating crypto — can result in fines, asset confiscation, and imprisonment. Enforcement materializes through public warnings and prosecution under general financial crime and currency control statutes rather than crypto-specific regulatory actions against named entities. (loc.gov)

Read the full custody overview → AI-synthesized · 2026-07-12
VASP/CASP Registry: None — no registry data for this jurisdiction

Regulatory Bodies

Central Bank of Sudan Regulations

Central Bank of Sudan Regulations and Directives: The CBOS issues various circulars, regulations, and guidelines that supplement the AML/CFT Law, providing detailed requirements for financial institutions.

Bank of Sudan's Stance

Bank of Sudan's Stance (Reported): The CBoS has issued numerous warnings against the use of cryptocurrencies.

Operating Models

9/9 verdicts

Can specific business models operate in Sudan? Each card answers the operational question for one kind of operator. Curated cells reflect counsel-grade review; AI-generated cells should be confirmed before relying on them.

Compare operating models across jurisdictions on the scenario hub.

Primary Legislation

Law / Regulation Year Scope
National Anti-Money Laundering and Combating the Financing of Terrorism Act (201 2014 National Anti-Money Laundering and Combating the Financing of Terrorism Act (2014): This is the primary legislation for AML/CFT in Sudan.
Sudan National Anti-Money Laundering and Combating the Financing of Terrorism Act 2014 2014 General search term you could use: "Sudan National Anti-Money Laundering and Combating the Financing of Terrorism Act 2014"

Licensing Requirements

No verified facts yet. 20 unverified fact(s) in explorer

AML/KYC Requirements

40%

De Facto Ban: The Central Bank of Sudan (CBOS) has repeatedly warned against the use of cryptocurrencies, citing risks such as money laundering, terrorism financing, price volatility, and consumer protection issues. These warnings have effectively created a ban on their use within the formal financial system.

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40%

No Licensed VASPs: Due to this stance, there are no licensed or regulated Virtual Asset Service Providers (VASPs) operating legally in Sudan. Any entity facilitating crypto transactions would be doing so outside the formal regulatory framework and potentially illegally.

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The Anti-Money Laundering and Combating Terrorism Financing Law of 2014 (Law No. 4 of 2014): This is the primary legislation governing AML/CFT in Sudan. It establishes the legal framework for identifying, investigating, and prosecuting money laundering and terrorism financing offenses.

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Central Bank of Sudan Regulations and Directives: The CBOS issues various circulars, regulations, and guidelines that supplement the AML/CFT Law, providing detailed requirements for financial institutions.

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40%

Individuals: Verifying the identity of customers using reliable, independent source documents, data, or information (e.g., national ID, passport, driving license).

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40%

Legal Entities/Arrangements: Verifying the legal existence and structure of the entity, its legal name, registration details, address, and identifying the natural persons who are beneficial owners.

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40%

Beneficial Ownership Identification: Taking reasonable measures to understand the ownership and control structure of legal entities and identify the natural persons who ultimately own or control the customer.

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40%

Purpose and Intended Nature of Business Relationship: Understanding the purpose and intended nature of the business relationship.

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40%

Ongoing Monitoring: Conducting ongoing due diligence on the business relationship and scrutinizing transactions undertaken throughout the course of the relationship to ensure they are consistent with the institution's knowledge of the customer, their business, and risk profile, including where necessary, the source of funds.

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40%

Enhanced Due Diligence (EDD): Applied in higher-risk situations, such as relationships with Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, or complex transactions. This would likely be a default for crypto if ever legalized, given its inherent risks.

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40%

Obligation to Report: Financial institutions (and potentially other designated non-financial businesses and professions - DNFBPs, if applicable) are obligated to report suspicious transactions to the Financial Information Unit (FIU) of Sudan.

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40%

Indicators: Reports are based on suspicion that funds are derived from illegal activities, intended for terrorism financing, or that the transaction itself is unusual or lacks a clear economic rationale.

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Financial institutions are typically required to retain all records of customer identification data, account files, business correspondence, and transaction records for a specified period (e.g., at least five years) following the termination of the business relationship or the execution of the transaction. This includes:

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Identity documents and verification records.

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40%

Transaction data sufficient to reconstruct individual transactions.

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40%

Records of STRs and their outcomes.

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40%

Role: The primary regulatory and supervisory authority for financial institutions in Sudan. It is responsible for issuing regulations, conducting oversight, and enforcing compliance with AML/CFT requirements in the banking sector.

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40%

Financial Information Unit (FIU) of Sudan:

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40%

Role: The central national agency responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other financial information to competent authorities for investigation and prosecution of money laundering and terrorism financing offenses. The FIU operates under the umbrella of the Central Bank or Ministry of Finance, but functions with operational independence for its core tasks.

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40%

URL: A dedicated, standalone English URL for the FIU of Sudan is not consistently available online. Its functions are often described in reports from the Central Bank or international bodies.

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(2 more unverified fact(s) )

Travel Rule

60%

Overall Status: No Adoption, General Prohibition/Strong Discouragement

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60%

Potential Consequences: These could include fines, asset confiscation, and imprisonment, depending on the specific charges brought under Sudanese law regarding unauthorized financial activities or foreign exchange violations.

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60%

Sudan Tribune (2018): Reported that the CBOS issued a circular warning against dealing with virtual currencies, stating that they are not recognized in the Sudanese banking system and expose users to high risks.

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60%

While a direct, static English URL from the CBOS website is difficult to find and often ephemeral, numerous news outlets reported on these warnings. Example reference (news report): Sudan Tribune - Central Bank warns against dealing in virtual currencies (This specific link from 2018 is no longer live, reflecting the difficulty of citing older, specific news items directly. However, the sentiment and reporting are consistent across various outlets over time.) More recent local reports (in Arabic) continue to echo this stance.

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60%

FATF Public Statement (October 2023): Confirmed Sudan's removal from the grey list.

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60%

URL: FATF Public Statement, October 2023 (Look for the section on "High-Risk Jurisdictions subject to a Call for Action" or "Jurisdictions under Increased Monitoring" and their changes).

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(6 more unverified fact(s) )

Tax Reporting

Tax reporting data collection in progress.

Custody Requirements

No verified facts yet. 10 unverified fact(s) in explorer

Stablecoin Regulation

Stablecoin regulation data collection in progress.

Securities Classification

Securities classification data collection in progress.

Sanctions & Restrictions

Sanctions data collection in progress.

Enforcement Actions

60%

Outright Ban: Unlike many countries that regulate cryptocurrencies, Sudan has a strict prohibition. The Central Bank of Sudan (Bank of Sudan - BOS) has repeatedly issued warnings and reaffirmed its ban on the trading and use of cryptocurrencies, including Bitcoin, stating they are illegal and unregulated within the country. This means there are no licensed entities to regulate or fine in the way there might be in other jurisdictions.

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60%

Lack of Transparency for Individual Cases: Enforcement, when it occurs, typically falls under broader financial crime, currency control, or anti-money laundering laws against individuals rather than specific "crypto" regulations against companies. Information about individual arrests, prosecutions, and specific penalties in Sudan's justice system is generally not publicly detailed or widely reported, especially to international media. It's rare to find specific public records outlining a precise penalty amount or the outcome of such cases for foreign observation.

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60%

Focus on General Warnings: The "enforcement actions" are more often in the form of official warnings and circulars from the Central Bank rather than specific actions against named entities with specified fines.

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60%

Regulator Name: Central Bank of Sudan (Bank of Sudan - BOS)

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Entity Targeted: The general public and financial institutions in Sudan (not a specific company or individual in a formal "enforcement action"). Violation Type: Engaging in or facilitating the trading, holding, or use of cryptocurrencies. This is considered a violation of financial regulations and currency control laws, as cryptocurrencies are deemed illegal tender and an unregulated financial instrument. Penalty Amount: No specific amount for the "warning" itself. Individuals found to be in violation could face penalties under existing financial and anti-money laundering laws, but these are not publicly itemized for crypto-specific offenses.

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Date: Various warnings have been issued over the years, most recently reaffirmed in 2021 and continuing.

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Outcome: Cryptocurrencies remain illegal and unregulated in Sudan. The warnings aim to prevent citizens and financial institutions from engaging in crypto activities.

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Title: Sudan Central Bank Reiterates Ban on Crypto, Warns of Risks

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URL: While Bloomberg is a subscription service, many news aggregators and crypto news sites reported on this. An example summary from a crypto news site that cites this: https://cryptotvplus.com/2021/11/sudan-central-bank-reiterates-ban-on-crypto-warns-of-risks/ (Note: This is a news report about the BOS's actions, not the BOS's official release directly, which are typically in Arabic and harder to access internationally).

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Many reports on cryptocurrency regulation worldwide confirm Sudan's prohibitive stance. For instance, the Library of Congress often compiles global legal information:

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Title: Regulation of Cryptocurrency Around the World

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Date: Regularly updated (last major update around 2021-2022 often includes Sudan)

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(4 more unverified fact(s) )

Regulatory Forecast

high confidence

Likely enforcement action expected around 2026-05-17

Based on 66 historical regulatory events for Sudan, averaging every 25 days, with increasing regulatory activity.

Trend: Increasing Data points: 66 Avg frequency: 25 days Last action: 2026-04-22

Recent Updates

2026-04-22(3 months ago)
high SD

De Facto Ban: The Central Bank of Sudan (CBOS) has repeatedly warned against the use of cryptocurrencies, citing ...

De Facto Ban: The Central Bank of Sudan (CBOS) has repeatedly warned against the use of cryptocurrencies, citing risks such as money laundering, terrorism financing, price volatility, and consumer protection issues. These warnings have effectively created a ban on their use within the formal financial system.

2026-04-22(3 months ago)
medium SD

No Licensed VASPs: Due to this stance, there are no licensed or regulated Virtual Asset Service Providers (VASPs)...

No Licensed VASPs: Due to this stance, there are no licensed or regulated Virtual Asset Service Providers (VASPs) operating legally in Sudan. Any entity facilitating crypto transactions would be doing so outside the formal regulatory framework and potentially illegally.

2026-04-22(3 months ago)
high SD

Central Bank of Sudan Regulations and Directives: The CBOS issues various circulars, regulations, and guidelines ...

Central Bank of Sudan Regulations and Directives: The CBOS issues various circulars, regulations, and guidelines that supplement the AML/CFT Law, providing detailed requirements for financial institutions.

2026-04-22(3 months ago)
high SD

Central Bank of Sudan (CBOS):

Central Bank of Sudan (CBOS):

2026-04-22(3 months ago)
medium SD

Custodial License Requirements: No licenses are issued for cryptocurrency custody as the activity itself is not f...

Custodial License Requirements: No licenses are issued for cryptocurrency custody as the activity itself is not formally recognized or permitted.

2026-04-22(3 months ago)
medium SD

Pending Custody Legislation: There is no publicly known or readily available information about pending legislatio...

Pending Custody Legislation: There is no publicly known or readily available information about pending legislation specifically addressing cryptocurrency custody in Sudan. The focus, where it exists, has primarily been on warnings or prohibitions rather than developing a regulatory framework for virtual assets.

2026-04-22(3 months ago)
high SD

2018 & Beyond: The Central Bank of Sudan has repeatedly warned against cryptocurrency trading. For example, in 20...

2018 & Beyond: The Central Bank of Sudan has repeatedly warned against cryptocurrency trading. For example, in 2018, it reportedly issued a circular prohibiting financial institutions from dealing with cryptocurrencies. This stance has been reiterated in subsequent years.

2026-04-22(3 months ago)
high SD

Regulator Name: Central Bank of Sudan (Bank of Sudan - BOS)

Regulator Name: Central Bank of Sudan (Bank of Sudan - BOS)

2026-04-22(3 months ago)
medium SD

Entity Targeted: The general public and financial institutions in Sudan (not a specific company or individual in ...

Entity Targeted: The general public and financial institutions in Sudan (not a specific company or individual in a formal "enforcement action").

enforcement View article →
2026-04-22(3 months ago)
high SD

De Facto Prohibition/Strong Discouragement: While there might not be an explicit blanket ban in the form of a spe...

De Facto Prohibition/Strong Discouragement: While there might not be an explicit blanket ban in the form of a specific law against holding cryptocurrencies, their use for transactions or the operation of crypto-related businesses is highly discouraged and effectively operates in a legal grey area, if not against CBoS directives.

2026-04-22(3 months ago)
high SD

Exchanges (VASP-like activities): There are no specific licenses for cryptocurrency exchanges in Sudan. Any e...

Exchanges (VASP-like activities): There are no specific licenses for cryptocurrency exchanges in Sudan. Any entity attempting to operate such a business would do so without specific regulatory approval, exposing them to significant legal and operational risks, including potential enforcement actions from the CBoS or other financial authorities under existing banking or financial services laws.

enforcement View article →
2026-04-22(3 months ago)
medium SD

Neither: As there is no specific framework, there is no established registration or licensing regime for virt...

Neither: As there is no specific framework, there is no established registration or licensing regime for virtual asset service providers (VASPs) in Sudan.

2026-04-22(3 months ago)
high SD

Bank of Sudan's Stance (Reported): The CBoS has issued numerous warnings against the use of cryptocurrencies. The...

Bank of Sudan's Stance (Reported): The CBoS has issued numerous warnings against the use of cryptocurrencies. These warnings are often reported by local and international news outlets.

2026-04-22(3 months ago)
high SD

General Prohibition/Discouragement: The existing directives from the Central Bank of Sudan broadly discourage or ...

General Prohibition/Discouragement: The existing directives from the Central Bank of Sudan broadly discourage or prohibit all cryptocurrency-related activities due to their unregulated nature and perceived risks. This means the focus is not on classifying which tokens are securities, but rather on preventing or warning against all forms of cryptocurrency.

2026-04-22(3 months ago)
high SD

Unauthorized Activity: Any entity attempting to issue cryptocurrency tokens within Sudan would likely be operatin...

Unauthorized Activity: Any entity attempting to issue cryptocurrency tokens within Sudan would likely be operating outside the authorized financial system and could face regulatory action or penalties under existing financial and banking laws.

2026-04-22(3 months ago)
high SD

Discouraged/Prohibited: Any trading would occur on unregulated, likely foreign, platforms. Individuals engaging i...

Discouraged/Prohibited: Any trading would occur on unregulated, likely foreign, platforms. Individuals engaging in such activities would be doing so at their own risk and potentially in contravention of Central Bank directives regarding foreign exchange and financial activities.

2026-04-22(3 months ago)
high SD

Bank of South Sudan (BSS):

Bank of South Sudan (BSS):

2026-04-22(3 months ago)
high SD

Consultation is Key: Any VASP considering operating in South Sudan should engage with local legal counsel and pot...

Consultation is Key: Any VASP considering operating in South Sudan should engage with local legal counsel and potentially the Bank of South Sudan directly to understand the current regulatory stance, potential interpretations of existing laws, and any upcoming policy developments.

2026-04-22(3 months ago)
high GLOBAL

Regulator Name: Bank of South Sudan (BSS)

Regulator Name: Bank of South Sudan (BSS)

general
2026-04-22(3 months ago)
medium SD

General Securities Principles (Implied): If a case were to arise, the CBSS or a court would likely refer to the g...

General Securities Principles (Implied): If a case were to arise, the CBSS or a court would likely refer to the general definition of "securities" or "financial products" as defined in existing financial legislation, which typically includes:

enforcement View article →
2026-04-22(3 months ago)
medium SD

No Explicit Classification: No official list or set of criteria has been published by the CBSS or the government ...

No Explicit Classification: No official list or set of criteria has been published by the CBSS or the government of South Sudan to classify specific types of tokens as securities.

2026-04-22(3 months ago)
medium SD

Implied Risk of Classification: Any crypto token that grants ownership rights, rights to future profits, debt ins...

Implied Risk of Classification: Any crypto token that grants ownership rights, rights to future profits, debt instruments, or represents an investment in an enterprise with an expectation of profit from the efforts of others (i.e., strong characteristics of an "investment contract" or traditional security) would likely be treated as a security if the authorities chose to act against it under existing general financial laws. This would be decided on a case-by-case basis through enforcement, rather than proactive classification.

enforcement View article →
2026-04-22(3 months ago)
high SD

General Financial Licensing: Any entity that seeks to issue financial products, raise capital from the public, or...

General Financial Licensing: Any entity that seeks to issue financial products, raise capital from the public, or engage in activities that could be construed as banking, investment banking, or offering financial services, would fall under the existing licensing requirements of the Central Bank of South Sudan (CBSS) or other relevant financial regulators.

2026-04-22(3 months ago)
medium SD

Practical Reality: Given the CBSS's current stance (see Enforcement Examples below), issuing tokens that could be...

Practical Reality: Given the CBSS's current stance (see Enforcement Examples below), issuing tokens that could be deemed securities without explicit regulatory approval would likely be seen as an unauthorized financial activity, potentially leading to immediate prohibition rather than a licensing process.

enforcement View article →
2026-04-22(3 months ago)
high SD

Central Bank Warnings/Prohibitions (Primary Enforcement): The Central Bank of South Sudan (CBSS) has repeatedly i...

Central Bank Warnings/Prohibitions (Primary Enforcement): The Central Bank of South Sudan (CBSS) has repeatedly issued warnings and effectively prohibited the use and trading of cryptocurrencies within the country.

enforcement View article →
2026-04-22(3 months ago)
high SD

Bank of South Sudan: The central financial regulator. Their official website (e.g., https://bankofsouthsudan.org/...

Bank of South Sudan: The central financial regulator. Their official website (e.g., https://bankofsouthsudan.org/) would be the primary source for any future regulations, but as of now, there are no specific VASP or Travel Rule regulations published there.

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