Crypto Overview in Sudan

Regulatory data is for informational purposes only and may not reflect the most current legal developments. Always consult qualified professionals before making decisions.

Legal Classification and Regulatory Framework

Cryptocurrency Status

Cryptocurrency in Sudan occupies a regulatory grey zone. The Central Bank of Sudan (CBOS, بنك السودان المركزي) has issued repeated formal warnings, most recently in 2022 and through subsequent AML circulars, that virtual assets are not classified as money, private money, or property under Sudanese legislation and regulations. Holding cryptocurrency and engaging in peer-to-peer trading are tolerated in practice; using crypto to settle invoices is not permitted because payments must be made in Sudanese pounds or approved foreign currencies. Crypto mining is explicitly prohibited. No criminal penalties exist for individual ownership, and no comprehensive virtual asset statute has been enacted.

Sudan has been in civil war since April 2023, with the country effectively divided between Sudanese Armed Forces (SAF) and Rapid Support Forces (RSF) controlled territory. The CBOS has relocated to Port Sudan and does not operate as a unified regulator across both zones. In RSF-controlled areas, no published crypto policy exists, and the de facto position is one of non-regulation rather than active prohibition.

Sudan’s primary digital commerce law, the Electronic Transactions Act of 2007, covers e-signatures and data processing but predates Bitcoin entirely and does not address virtual assets. There is no regulatory authority that currently operates a dedicated crypto licensing regime, and the overall framework relies on a combination of general financial law, CBOS circulars, and AML obligations rather than any purpose-built virtual asset legislation.

Tax Treatment

Sudan has no dedicated cryptocurrency tax code. Where crypto income is captured under existing rules, it is treated as miscellaneous income or as proceeds from an intangible asset under the general Income Tax Act of 1986. Individual income tax brackets and a corporate income tax rate of approximately 35 percent apply in principle to realised gains and crypto-related business income. Crypto-to-crypto trades are conceptually treated as taxable disposals at fair market value, though no published guidance from the Taxation Chamber addresses this specifically.

In practice, the tax administration has been severely degraded by the war. Enforcement against retail crypto activity is essentially nil. Specific rates and thresholds that circulate in secondary commentary should be treated as indicative rather than authoritative until the Taxation Chamber issues primary guidance.

Regulatory Oversight

Oversight sits across several SAF-aligned bodies. The CBOS supervises licensed banks and mobile-money operators, issues AML circulars, and can direct banks to freeze accounts linked to suspect transfers. Under CBOS AML circulars covering the period 2019 to 2024, banks and mobile-money operators are required to file Suspicious Transaction Reports for crypto-linked transfers above approximately SDG 4 million (roughly USD 8,000). CBOS Circular 9/2024 further provides for administrative penalties of up to 200 percent of underpaid amounts, with interest, and for fiat account freezes. The Ministry of Finance and the Taxation Chamber manage fiscal policy. The Digital Transformation Agency leads the national e-payments agenda, and the Ministry of Telecommunications and Digital Economy administers the Cyber-Crime Act and licenses internet service providers.

Business Environment

Banking Relationships

Banking access for crypto businesses is effectively closed. Sudan was under comprehensive United States sanctions until October 2017 and remained on the State Sponsor of Terrorism list until December 2020. The targeted sanctions program under Executive Order 14098, signed in 2023, imposes asset blocks on persons destabilising Sudan. Significant designations have continued through 2024 to 2026, covering both SAF and RSF affiliated commanders, weapons procurement networks, and financial backers. In January 2025, the US Treasury sanctioned both SAF commander Abdel Fattah Al-Burhan and RSF leader Mohammad Hamdan Daglo Mousa (Hemedti). Banking infrastructure has collapsed across large parts of the country, and surviving retail banks treat crypto exposure as off-limits. Sudanese users typically rely on cash, peer-to-peer trades, or accounts held in third countries to access exchanges.

Innovation Support

Sudan does not currently operate a regulatory sandbox or a state-led blockchain initiative. Pre-war discussions explored stablecoin-based remittance rails aimed at reducing diaspora corridor fees, and CBOS has made exploratory mentions of a regulatory sandbox for blockchain pilots in agriculture, traceability, and land registries. No public pilot has been launched. The CBOS has not announced a central bank digital currency program, and recent monetary policy attention has focused on physical banknote reissue and emergency currency stabilisation rather than digital innovation.

Crypto License in Sudan

Sudan has no virtual asset service provider licensing framework in force. The country is operating without any statutory VASP regime, meaning no entity can be licensed or authorised to provide crypto exchange, custody, or brokerage services domestically. All activity is either informal or conducted through global peer-to-peer platforms and over-the-counter channels outside the reach of Sudanese law.

Current Status

There is no VASP licensing regime in force in Sudan. No domestic exchanges are authorised by the CBOS, and no other regulatory body issues virtual asset licences. Activity is concentrated on global P2P platforms such as Binance P2P, and informal OTC groups operating through messaging applications. A draft FinTech Bill that has been discussed in public reporting would, if enacted, introduce VASP licensing tiers, data localisation requirements, and a cybersecurity levy on fiat cash-in transactions. With the legislature non-functional during the ongoing conflict, any such bill is realistically deferred until a political settlement is reached and institutions are reconstituted.

Why No Framework

Three structural factors explain the absence of a domestic licensing regime. First, Sudan’s primary financial legislation, the Electronic Transactions Act of 2007 and the AML/CFT Act of 2014, were drafted before virtual assets became a significant financial phenomenon and contain no VASP-specific provisions. Second, the civil war that began in April 2023 has paralysed legislative activity: parliament has not been functioning, and the CBOS has been preoccupied with emergency monetary stabilisation and relocation rather than financial innovation policy. Third, the persistence of US-led targeted sanctions under Executive Order 14098 creates significant compliance barriers for any international counterparty that might otherwise engage with a newly licensed Sudanese virtual asset sector, reducing the short-term incentive for regulators to invest in building that infrastructure.

What Operators Should Know

Foreign operators providing services to Sudanese users should be aware that accessing the Sudanese market carries AML and sanctions compliance obligations under their home jurisdiction rules. The CBOS AML circulars in effect through 2024 impose Suspicious Transaction Report requirements on Sudanese banks and mobile-money operators for crypto-linked transfers above approximately USD 8,000. CBOS Circular 9/2024 provides for administrative penalties and account freezes. Any future FinTech Bill, if passed, is expected to introduce formal VASP categories, and operators with existing user bases in Sudan would likely need to apply for licensing within a transition period. Until legislation is enacted, there is no lawful domestic licensing pathway for virtual asset businesses, and no safe harbour for crypto service providers operating from or into Sudan.

Market Characteristics

Adoption Patterns

Despite the absence of a formal framework, ground-level crypto adoption has grown significantly during the war. The Sudanese pound has lost over 80 percent of its value against the US dollar since 2020, making dollar-pegged stablecoins an attractive store of value and remittance instrument. USDT on the Tron network functions as a parallel store of value and as a settlement layer for remittances, savings, and small business payments. On-chain analytics indicate that crypto transaction volumes related to Sudan more than doubled year-on-year in 2024 to 2025, driven primarily by stablecoin peer-to-peer trading and offshore exchanges accessed through VPNs. Peer-to-peer order books and messaging-app OTC groups handle most local volume.

Stablecoins increasingly compete with hawala for remittance flows from the Sudanese diaspora. Hawala costs have risen significantly during the conflict, and USDT transfers have become a lower-cost alternative for diaspora members sending value into the country. The broader Sub-Saharan Africa context is relevant: stablecoins accounted for approximately 43 percent of all crypto transaction volume in the region in 2024, and the region as a whole saw on-chain value grow by 52 percent year-on-year in the period July 2024 to June 2025.

Industry Focus

The Sudanese crypto market is overwhelmingly retail and remittance-driven. There is no recognised onshore exchange industry, no domestic custody sector, and no licensed brokerage activity in digital assets. Mining is not only explicitly prohibited but also impractical given chronic power outages, sanctions constraints on specialised hardware procurement, and the security situation across most of the country. Industry development is effectively on hold while basic financial infrastructure is being rebuilt in the conflict’s aftermath.

Regulatory Evolution

Sudan is a member of the Middle East and North Africa Financial Action Task Force (MENAFATF) and is not currently on the FATF list of jurisdictions under increased monitoring, as confirmed in FATF plenary statements through 2025. The CBOS established the Financial Information Unit (FIU) under the AML/CFT Act of 2014, and the FIU joined the Egmont Group of FIUs in June 2017. Sudan was removed from FATF enhanced follow-up in October 2015 after demonstrating sufficient progress on its action plan. A second-round mutual evaluation has not been published, and on-site assessments have been complicated by the conflict. Future regulatory direction will depend heavily on the outcome of the civil war, the reconstitution of legislative institutions, the trajectory of US and international targeted sanctions, and whether the draft FinTech Bill can be advanced through a restored parliament.