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Sudan -- Securities Classification Regulatory Overview

Published: 2026-04-22 Updated: 2026-08-27 Researched: 2026-08-27 Author: deepseek/deepseek-chat Version 2 Sources cited in: English (8)

Methodology

AI-generated synthesis from web search results.

Limitations

  • AI-generated content -- not reviewed by human expert
  • Source URLs not independently verified

RESEARCH: Sudan Securities Cryptocurrency and Digital Asset Regulatory Requirements

Executive Summary

  • 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
  • No entity has been licensed to conduct cryptocurrency exchange, custody, or digital asset securities business in Sudan; the practical reality is that crypto activity operates in a legal vacuum with significant prohibition risk under foreign exchange laws. Sudan - Trade Financing
  • 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

Regulatory Framework

Primary Regulatory Bodies

  • 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 [email protected], 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

Primary Laws and Regulations

  • 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
  • Anti Money Laundering & the Financing of Terrorism Act — the principal AML/CFT statute administered by CBOS. Laws and Regulations | CBOS
  • Foreign Exchange Dealing Act — regulates all foreign exchange transactions and dealings in Sudan, administered by CBOS. Laws and Regulations | CBOS
  • Foreign Exchange Dealing Regulation — implementing regulation under the Foreign Exchange Dealing Act. Laws and Regulations | CBOS
  • Regulation governing the business of financial investment institutions — CBOS regulation covering investment institutions, which could potentially encompass certain digital asset custody or investment activities by analogy. Laws and Regulations | CBOS
  • Regulation governing the Business of Foreign Exchange Bureaus — CBOS regulation controlling foreign exchange bureau licensing. Laws and Regulations | CBOS
  • The Electronic Transactions Act — Sudan's electronic transactions legislation listed by CBOS, relevant for digital commerce but with no digital asset provisions. Laws and Regulations | CBOS
  • The Informatic Offences (Combating) Act, 2007 — cybercrime legislation listed among CBOS regulations, potentially applicable to digital asset fraud or system intrusions. Laws and Regulations | CBOS
  • The Property Mortgaged to Banks Act — banking collateral law, no relevance to digital assets. Laws and Regulations | CBOS
  • Deposit Guarantee Fund Act — deposit insurance statute, does not extend to virtual assets. Laws and Regulations | CBOS
  • FMA Law — foundational statute creating the Financial Markets Authority and its powers over Sudanese capital markets. ABout FMA – Financial Markets Authority
  • Implementing Regulations (FMA) — a set including: "Licensing Brokerage Companys," "Rules of Privet Placement," "Restructure Brokerage Companies," "Violations and Penalties Regulations for Market Members and Capital Markets for the Year 2021," "Authority Service Charges Guide," "Regulations for the issuance of investment fund units for the year 2022 AD," and "Grievances Committee Regulations for the year 2022." Financial Markets Authority – Fair Financial Environment for sustainable investment
  • Investment Act of 2013 — enshrines the right to repatriate capital and profits provided the investor has opened an investment account at the Central Bank before starting operations. Sudan - Trade Financing

International Standing

Licensing Requirements

Who Needs a License

  • No cryptocurrency or digital asset securities license exists in Sudan as of the available regulatory publications; none of the CBOS or FMA listed laws, acts, or regulations provide for the licensing of virtual asset service providers. Laws and Regulations | CBOS
  • A person or entity seeking to conduct banking business in Sudan requires a license under the "Regulation governing Licensing for conducting Banking Business" — but this regulation does not cover digital assets. Laws and Regulations | CBOS
  • Foreign exchange bureaus must be licensed under the "Regulation governing the Business of Foreign Exchange Bureaus" — cryptocurrency exchange does not appear within this framework. Laws and Regulations | CBOS
  • Financial investment institutions require licensing under the "Regulation governing the business of financial investment institutions" — the scope of "financial investment" does not extend to digital asset services. Laws and Regulations | CBOS
  • Foreign banks seeking representative offices must comply with "Rules for Conducting Business and Licensing of Representative Offices of Foreign Banks." Laws and Regulations | CBOS
  • Brokerage companies in the securities market require FMA licensing under the "Licensing Brokerage Companys" implementing regulation. Financial Markets Authority – Fair Financial Environment for sustainable investment
  • Offering managers and investment funds require FMA approvals; the FMA publishes "Managers & Centers" lists and "Prospectuses & Forms" for companies and investment funds. Financial Markets Authority – Fair Financial Environment for sustainable investment

Activities Requiring Licensing

Capital Requirements

Application Process and Timeline

AML/KYC Requirements

  • Sudan has an Anti Money Laundering & the Financing of Terrorism Act administered by CBOS, which constitutes the foundational AML/CFT obligation for financial institutions. Laws and Regulations | CBOS
  • CBOS publishes separate "Anti-Money Laundering and the Financing of Terrorism" circulars under its "Financial Institution and System Wing Circulars" category, providing operational guidance to financial institutions. Laws and Regulations | CBOS
  • The source text does not detail specific CDD (Customer Due Diligence), EDD (Enhanced Due Diligence), or STR (Suspicious Transaction Reporting) thresholds within the CBOS AML framework. Laws and Regulations | CBOS
  • No provisions in the source text address record retention periods, beneficial ownership definitions, or PEP (Politically Exposed Persons) screening requirements specific to digital assets. Laws and Regulations | CBOS
  • Since no virtual asset service provider category exists, the AML/KYC obligations under the Act apply to traditional financial institutions only; crypto businesses cannot comply through a specific digital asset AML regime because one has not been established. Laws and Regulations | CBOS
  • Foreign companies operating in Sudan require CBOS permission to repatriate profits and foreign currency, and investing parties must open an investment account at the Central Bank before starting operations — a requirement that could apply to any crypto-related investment entity. Sudan - Trade Financing

Enforcement Actions

Tax Treatment

  • No tax guidance has been issued for virtual assets in Sudan. Laws and Regulations | CBOS
  • The available CBOS and FMA publications contain no mention of tax treatment for cryptocurrency gains, capital gains on digital assets, or VAT applicability to virtual asset transactions. Laws and Regulations | CBOS
  • The Investment Act of 2013 provides for repatriation of capital and profits for investments made through approved channels, which could theoretically apply to digital asset investments, but no specific tax rules for crypto exist. Sudan - Trade Financing

Key Gaps & Risks

Regulatory Gaps

Practical Business Risks

  • Foreign exchange violation risk — foreign-currency transactions must comply with the Foreign Exchange Dealing Act; crypto-to-fiat conversions may be treated as unauthorized foreign exchange dealing. Laws and Regulations | CBOS
  • U.S. sanctions exposure — the Sudanese Sanctions Regulations block property of the Government of Sudan and impose conditions on transfers to Sudan; any international crypto exchange serving Sudanese users could face U.S. enforcement. Federal Register :: Reporting, Procedures and Penalties Regulations and Sudanese Sanctions Regulations
  • High reliance on informal channels — "many Sudanese firms still complete a significant number of transactions outside of official channels or complete transactions abroad in U.S. dollars, euros, riyals, or dirhams," indicating widespread circumvention that a compliant crypto business cannot ignore. Sudan - Trade Financing
  • Banking sector weaknesses — Sudan's banks are "under capitalized, deficient in employing modern technology, and lacking in trained and experienced human resources," limiting the ability to establish bank partnerships for digital asset operations. Sudan - Trade Financing
  • No U.S. correspondent banks — "No U.S. banks operate in Sudan" and the Ex-Im Bank does not offer Sudan-specific programs, complicating USD settlement for crypto businesses. Sudan - Trade Financing
  • Regulatory uncertainty — the FMA continues to evolve (e.g., new headquarters in Khartoum, agricultural commodities exchange steering committee), but no crypto-specific policy development is publicly visible. Financial Markets Authority – Fair Financial Environment for sustainable investment

Sources

Source Data

80%

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

80%

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

80%

No entity has been licensed to conduct cryptocurrency exchange, custody, or digital asset securities business in Sudan; the practical reality is that crypto activity operates in a legal vacuum with significant prohibition risk under foreign exchange laws. Sudan - Trade Financing

80%

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

80%

Implementing Regulations (FMA) — a set including: "Licensing Brokerage Companys," "Rules of Privet Placement," "Restructure Brokerage Companies," "Violations and Penalties Regulations for Market Members and Capital Markets for the Year 2021," "Authority Service Charges Guide," "Regulations for the issuance of investment fund units for the year 2022 AD," and "Grievances Committee Regulations for the year 2022." Financial Markets Authority – Fair Financial Environment for sustainable investment

80%

Sudan has an Anti Money Laundering & the Financing of Terrorism Act administered by CBOS, which constitutes the foundational AML/CFT obligation for financial institutions. Laws and Regulations | CBOS

80%

CBOS publishes separate "Anti-Money Laundering and the Financing of Terrorism" circulars under its "Financial Institution and System Wing Circulars" category, providing operational guidance to financial institutions. Laws and Regulations | CBOS

80%

The source text does not detail specific CDD (Customer Due Diligence), EDD (Enhanced Due Diligence), or STR (Suspicious Transaction Reporting) thresholds within the CBOS AML framework. Laws and Regulations | CBOS

80%

No provisions in the source text address record retention periods, beneficial ownership definitions, or PEP (Politically Exposed Persons) screening requirements specific to digital assets. Laws and Regulations | CBOS

80%

Since no virtual asset service provider category exists, the AML/KYC obligations under the Act apply to traditional financial institutions only; crypto businesses cannot comply through a specific digital asset AML regime because one has not been established. Laws and Regulations | CBOS

80%

Foreign companies operating in Sudan require CBOS permission to repatriate profits and foreign currency, and investing parties must open an investment account at the Central Bank before starting operations — a requirement that could apply to any crypto-related investment entity. Sudan - Trade Financing

80%

The FMA has published "Violations and Penalties Regulations for Market Members and Capital Markets for the Year 2021," which establish penalty frameworks for securities market violations, but no crypto-specific enforcement cases are reported in the available sources. Financial Markets Authority – Fair Financial Environment for sustainable investment

80%

U.S. sanctions enforcement is a relevant risk: the Sudanese Sanctions Regulations (31 CFR Part 538) block property of the Government of Sudan and prohibit certain fund transfers to Sudan, creating a risk of U.S. penalties for persons facilitating digital asset transactions with Sudanese parties, though no specific Sudan-crypto enforcement is described in the text. Federal Register :: Reporting, Procedures and Penalties Regulations and Sudanese Sanctions Regulations

80%

The regulation "Rule" in the Federal Register notes that money transmittal services to Sudan are prohibited except as otherwise authorized by general license, and that U.S. financial institutions must block unlicensed funds transfers involving the Government of Sudan. Federal Register :: Reporting, Procedures and Penalties Regulations and Sudanese Sanctions Regulations

80%

No tax guidance has been issued for virtual assets in Sudan. Laws and Regulations | CBOS

80%

The available CBOS and FMA publications contain no mention of tax treatment for cryptocurrency gains, capital gains on digital assets, or VAT applicability to virtual asset transactions. Laws and Regulations | CBOS

80%

The Investment Act of 2013 provides for repatriation of capital and profits for investments made through approved channels, which could theoretically apply to digital asset investments, but no specific tax rules for crypto exist. Sudan - Trade Financing

1 fact(s) collected but awaiting source verification. View in explorer →

References

This article was generated by deepseek/deepseek-chat .

Primary Sources

cbos.gov.sd. (n.d.). cbos.gov.sd. Retrieved April 22, 2026, from https://cbos.gov.sd/

loc.gov. (n.d.). loc.gov. Retrieved April 22, 2026, from https://www.loc.gov/law/help/cryptocurrency/

cbos.gov.sd. (n.d.). Laws and Regulations | CBOS. Retrieved September 6, 2026, from https://cbos.gov.sd/en/content/laws-and-regulations

fma.gov.sd. (n.d.). Financial Markets Authority – Fair Financial Environment for sustainable investment. Retrieved September 6, 2026, from https://fma.gov.sd/

trade.gov. (n.d.). Sudan - Trade Financing. Retrieved September 6, 2026, from https://www.trade.gov/country-commercial-guides/sudan-trade-financing

federalregister.gov. (n.d.). Federal Register :: Reporting, Procedures and Penalties Regulations and Sudanese Sanctions Regulations. Retrieved September 6, 2026, from https://www.federalregister.gov/documents/2005/06/13/05-11637/reporting-procedures-and-penalties-regulations-and-sudanese-sanctions-regulations

fma.gov.sd. (n.d.). ABout FMA – Financial Markets Authority. Retrieved September 6, 2026, from https://fma.gov.sd/bout-fma/

boss.gov.ss. (n.d.). Regulations - BoSS | Bank of South Sudan. Retrieved September 6, 2026, from https://boss.gov.ss/regulations/

Edit History

2026-04-22 — auto-publish-pipeline: published — Auto-published: grade A
2026-09-06 — refresh-from-research: refreshed — Refreshed from _processed/sd-securities.md (researched 2026-08-27); grade A → A

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