Sudan Compliance Report

Generated 2026-09-22

Regulated (Existing Law)

Regulatory Overview

Regulatory Status: Crypto regulated under existing securities/payments/banking law
Key Regulator(s): Central Bank of Sudan Regulations, Bank of Sudan's Stance
Primary Legislation: National Anti-Money Laundering and Combating the Financing of Terrorism Act (201, Sudan National Anti-Money Laundering and Combating the Financing of Terrorism Act 2014, No primary Sudanese legislation, law, decree, or regulation concerning financial, No Sudanese laws, including the Banking Regulation Act, the Anti-Money Launderin, There is no indication in the provided materials that any Sudanese tax circular,, A business seeking to understand Sudanese crypto regulation would face a complet, e.g., the Sudanese Central Bank Act, Anti-Money Laundering Act of 2014, and related regulations, The gap between paper law and practical reality cannot be assessed from these do
Travel Rule: Adopted — Threshold: Implemented

Key Facts

aml 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.
custody 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. 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. Cryptocurrencies are not recognized as legal tender in Sudan. Dealing in them carries significant risks due to volatility, lack of regulation, and potential for fraud or money laundering.
enforcement 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
general No Specific Test for Crypto Securities: Sudan does not employ a "Howey test" equivalent or any other specific legal test to differentiate between utility tokens, security tokens, or payment tokens within the cryptocurrency sphere. 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. Existing Securities Law (Applicability): While Sudan likely has traditional capital market laws governing conventional securities, these laws have not been adapted or interpreted to create a framework for crypto-assets. Therefore, they are not used to classify crypto tokens as securities in a way that would permit their regulated issuance or trading. Undifferentiated Approach: Given the prohibitive stance, Sudanese authorities do not generally differentiate between various types of cryptocurrency tokens (e.g., utility, security, payment, stablecoins) for regulatory purposes related to securities classification. Broadly Viewed as Risky/Prohibited: All cryptocurrencies are broadly viewed as highly speculative, unregulated, and potentially illegal under existing financial and foreign exchange regulations. There is no concept of a "compliant" security token in Sudan's current regulatory landscape. None Exist: Since the issuance, trading, and use of cryptocurrencies are largely discouraged or prohibited, there are no established registration or exemption requirements for token issuers in Sudan. 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. No Specific Rules: As with issuance, there are no specific regulatory rules governing the secondary trading of cryptocurrency tokens in Sudan.
licensing 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. Custody Providers: Similar to exchanges, no specific licenses exist for virtual asset custody providers. Payment Processors (Crypto-related): If a payment processor were to facilitate payments in or using cryptocurrencies, they would again fall outside any dedicated regulatory framework and would likely face similar challenges and risks as exchanges. Traditional payment processors are regulated under banking and financial services laws, but these do not extend to unregulated virtual assets. Neither: As there is no specific framework, there is no established registration or licensing regime for virtual asset service providers (VASPs) in Sudan. Capital Requirements: No crypto-specific capital requirements. However, any formal business registration in Sudan would entail general capital requirements based on the business type and structure. 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).
securities Sudan has no specific legal framework for cryptocurrency or digital asset securities as of 2025–2026, and no regulator has issued licenses or guidance for crypto-related activities. Laws and Regulations | CBOS The Central Bank of Sudan (CBOS) regulates banking and financial institutions under the Banking Business Act, the Foreign Exchange Dealing Act, and the Anti-Money Laundering & Financing of Terrorism Act, none of which mention virtual assets. Laws and Regulations | CBOS The Financial Markets Authority (FMA) supervises capital markets and securities activities, including licensing of brokerage companies, but its published regulations cover only conventional securities and investment funds, not digital assets. Financial Markets Authority – Fair Financial Environment for sustainable investment U.S. sanctions and the Sudanese Sanctions Regulations (31 CFR Part 538) additionally restrict international digital asset transactions involving Sudan, creating extraterritorial compliance barriers for any market participant. Federal Register :: Reporting, Procedures and Penalties Regulations and Sudanese Sanctions Regulations Central Bank of Sudan (CBOS) — the central monetary authority with jurisdiction over banking business, foreign exchange dealing, financial investment institutions, and anti-money laundering compliance; contactable at info@cbos.gov.sd, phone 00249187056000, Port Sudan, P.O 34. Laws and Regulations | CBOS Financial Markets Authority (FMA) — the securities and capital markets regulator for Sudan, responsible for licensing brokerage companies, offering managers, investment funds, and enforcing capital market regulations. Financial Markets Authority – Fair Financial Environment for sustainable investment Khartoum Stock Exchange — operates under the Khartoum Stock Exchange Act, 1994, as part of the securities market infrastructure. Sudan - Trade Financing Banking Business Act — CBOS-enforced statute governing the conduct of banking business in Sudan, with separate regulation titled "Regulation governing Licensing for conducting Banking Business." Laws and Regulations | CBOS
stablecoin The Central Bank of Sudan (CBOS) is the primary financial regulator, publishing its laws, regulations, policies, and circulars on its official website. Laws and Regulations | CBOS The primary laws listed by CBOS include the Banking Business Act, the Anti Money Laundering & the Financing of Terrorism Act, the Electronic Transactions Act, the Foreign Exchange Dealing Act, and the Deposit Guarantee Fund Act. Laws and Regulations | CBOS CBOS has published regulations for foreign exchange dealing, foreign exchange bureaus, banking business licensing, representative offices of foreign banks, financial investment institutions, and financial leasing institutions. Laws and Regulations | CBOS CBOS publishes annual policies, including Central Bank of Sudan Policies for the years 2026, 2025, 2024, and earlier years, which may contain relevant regulatory direction. Central Bank of Sudan CBOS maintains a circulars page for Financial Institution and System Wing Circulars, Anti-Money Laundering and the Financing of Terrorism regulations, and Regulations and Orders of Foreign Exchange Operations. Circulars | CBOS No law, regulation, policy, or circular listed by CBOS specifically addresses stablecoins, virtual assets, or cryptocurrency; no such framework is present in the published regulatory materials. Laws and Regulations | CBOS Sudan's international standing on FATF/Moneyval status is not stated in the CBOS materials provided, and no official source among those listed confirms current membership or evaluation status. Laws and Regulations | CBOS CBOS licenses financial technology companies under two categories: Financial Institution for Mobile Payment (FIMP) and Financial Switch Operator (FSO). Licensed Financial Technology Companies | CBOS
status The provided source documents contain no information whatsoever regarding cryptocurrency, digital assets, virtual assets, or blockchain regulatory frameworks in Sudan. Federal Register :: Extension of the Designation of Sudan for Temporary Protected Status All supplied texts exclusively address U.S. Temporary Protected Status (TPS) designations for Sudan and South Sudan, which is a U.S. immigration matter, not a Sudanese financial regulatory matter. Federal Register :: Termination of the Designation of South Sudan for Temporary Protected Status No Sudanese regulatory authority, licensing body, or financial regulator is mentioned in any of the source documents provided. Temporary Protected Status Designated Country: Sudan | USCIS Based solely on the supplied source materials, it is impossible to determine whether cryptocurrency is legal in Sudan, which entity regulates it, or whether any licenses have been issued. Federal Register :: Extension of South Sudan Designation for Temporary Protected Status A researcher seeking Sudan's actual crypto regulatory framework would need to consult entirely different sources, as the provided documents are irrelevant to this topic. Temporary Protected Status Designated Country: South Sudan | USCIS The source materials provided contain no reference to any Sudanese regulatory body, financial authority, central bank, or securities regulator. Federal Register :: Extension of the Designation of Sudan for Temporary Protected Status No primary Sudanese legislation, law, decree, or regulation concerning financial services, payments, or digital assets is cited in any of the provided documents. Federal Register :: Termination of the Designation of South Sudan for Temporary Protected Status The only laws referenced in the source texts are U.S. federal laws, specifically the Immigration and Nationality Act (INA), cited at INA sec. 244(b)(1), 8 U.S.C. 1254a(b)(1), and INA sec. 244(a)(1)(A), 8 U.S.C. 1254a(a)(1)(A), which pertain exclusively to U.S. immigration policy. Federal Register :: Termination of the Designation of South Sudan for Temporary Protected Status
travel rule Overall Status: No Adoption, General Prohibition/Strong Discouragement Whether Adopted: No. Effective Date: N/A. Threshold Amounts: N/A. Which VASPs are Covered: N/A. Technical Implementation Requirements: N/A. 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. 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.

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-06. View full profile