Crypto ATM / kiosk operator in Sudan

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.

No Legal Tender Status: Cryptocurrencies are not recognized as legal tender in Sudan.

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.

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

AML/KYC Requirements: This is perhaps the most critical aspect. While not crypto-specific, Sudan is a member of the Middle East & North Africa Financial Action Task Force (MENAFATF) and is committed to combating money laundering and terrorist financing (AML/CFT).

General AML/CFT Laws: Sudan has general AML/CFT legislation, such as the National Anti-Money Laundering and Combating the Financing of Terrorism Act (2014). Any financial institution or designated non-financial business and profession (DNFBP) operating in Sudan is obligated to adhere to these laws, including implementing customer due diligence (KYC) and reporting suspicious transactions.

Implication for Crypto: Should a crypto business attempt to operate, they would be expected by international standards (FATF recommendations) and potentially by local authorities (even without specific crypto laws) to implement robust AML/KYC measures. Failure to do so would expose them to significant legal repercussions under existing AML/CFT laws.

Local Presence: Any legally registered business in Sudan typically requires a local presence (registered office, local management/directors) as per general company law requirements.

Non-existent: There is no established application process for cryptocurrency or virtual asset licenses or registrations in Sudan because the framework does not exist.

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.

National Anti-Money Laundering and Combating the Financing of Terrorism Act (2014): This is the primary legislation for AML/CFT in Sudan. While it predates the widespread recognition of virtual assets, its principles would apply to any financial activity.

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.

Identification and Verification:

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.

Financial Information Unit (FIU) of Sudan:

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.

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.

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