Centralized exchange 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.

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.

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

Lack of Specific Legislation: As noted, there is no dedicated licensing framework.

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

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.

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.

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

Segregation of Client Assets Rules: Without a legal framework for digital assets, there are no rules mandating the segregation of client assets.

Insurance/Bonding Requirements: There are no insurance or bonding requirements for crypto custodians, as no such entities are formally permitted to operate.

Cold Storage Mandates: No mandates exist for cold storage or any other security protocols for digital asset custody.

Qualified Custodian Definitions: There is no legal definition of a "qualified custodian" for digital assets in 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.

Identification and Verification:

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.

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:

Overall Status: No Adoption, General Prohibition/Strong Discouragement

Whether Adopted: No.

Penalties for Non-Compliance:

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.

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.

Bloomberg (referencing earlier warnings):

Cryptocurrencies are not recognized as legal tender in Sudan.

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.

Central Bank of Sudan (CBOS):