Sudan -- Travel Rule Implementation Regulatory Overview

The implementation of the FATF Travel Rule in Sudan is effectively non-existent due to the country's general stance on virtual assets.

Here's a breakdown:

• Overall Status: No Adoption, General Prohibition/Strong Discouragement Sudan has not formally adopted the FATF Travel Rule. This is primarily because the Central Bank of Sudan (CBOS) has historically issued strong warnings and effectively prohibited the use and trading of cryptocurrencies and other virtual assets within the country. As virtual assets themselves are largely not recognized or permitted, there is no regulatory framework for Virtual Asset Service Providers (VASPs), let alone specific rules like the Travel Rule.

• Whether Adopted: No. The FATF Travel Rule (Recommendation 16) applies to virtual assets and VASPs. Since virtual assets are not regulated or permitted in Sudan, the specific requirements of the Travel Rule have not been adopted.

• Effective Date: N/A. There is no effective date as the rule has not been adopted.

• Threshold Amounts: N/A. No thresholds have been set as there's no framework. The Travel Rule generally applies to transactions above certain thresholds (e.g., USD/EUR 1,000 for inter-VASP transfers, no threshold for cross-border non-VASP transfers, and lower for domestic non-VASP transfers in some jurisdictions).

• Which VASPs are Covered: N/A. VASPs are not formally recognized or licensed in Sudan. Any entity attempting to operate as a VASP would likely be deemed operating illegally.

• Technical Implementation Requirements: N/A. No technical requirements exist.

• Penalties for Non-Compliance: While there are no specific penalties for non-compliance with the Travel Rule in Sudan, individuals or entities found to be dealing in virtual assets could face penalties under broader financial regulations, currency control laws, or anti-money laundering (AML) / combating the financing of terrorism (CFT) laws for operating an unregulated financial service or conducting unauthorized financial transactions.

  • 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.

Relevant Context and References:

1. Central Bank of Sudan (CBOS) Warnings: The CBOS has repeatedly warned the public against dealing with cryptocurrencies, stating they are not regulated and are illegal within Sudan. For example:

   • 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.
     • 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.

2. FATF Grey Listing and Delisting: Sudan was on the FATF grey list for several years but was removed in October 2023. While this indicates significant progress in its broader AML/CFT framework, the focus of its action plan was on other identified deficiencies, not specifically on virtual asset regulation or the Travel Rule, given the country's prohibitive stance.

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

Conclusion:

As of late 2023 and early 2024, Sudan maintains a restrictive approach to virtual assets. This means the foundational environment for adopting and implementing the FATF Travel Rule (or any comprehensive virtual asset regulation) simply does not exist. Any engagement with virtual assets in Sudan carries significant legal and financial risks due to their unregulated and generally prohibited status.