Sudan

**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.

**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.

**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.

**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.

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

**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.

**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.

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

**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.

**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.

**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.

**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.

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:

Identity documents and verification records.

Transaction data sufficient to reconstruct individual transactions.

Records of STRs and their outcomes.

**Central Bank of Sudan (CBOS):**

**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.

**Financial Information Unit (FIU) of Sudan:**

**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.

**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.

**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.

**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.

**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.

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

**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.

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

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

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

**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).

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

**Title:** Regulation of Cryptocurrency Around the World

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