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Sudan

No virtual-asset law; the Central Bank of Sudan warned in March 2022 that cryptocurrencies are not money or property and carry high risk — only the Electronic Transactions Act 2007 (pre-Bitcoin) plus AML circulars apply. Payments and e-money are controlled by the CBOS via the state-owned Electronic Banking Services (EBS) switch under the Banking Business Act and revised post-2020 e-money regulations. Gambling is criminally prohibited under the Sudan Criminal Act 1991 and Sharia. The country is in active armed conflict since April 2023 with fractured financial infrastructure and severe sanctions exposure.

Available licences

Crypto / Virtual Assets — none (no framework; CBOS warning)

No crypto or VASP licence exists. The CBOS warned in 2022 that crypto is not money/property and is high-risk; only the Electronic Transactions Act 2007 and AML circulars apply; a draft FinTech Bill is unenacted.

Payments / E-money & Mobile-money Licence (CBOS / EBS)

Licensing of banks, financial-services providers and mobile-money operators by the CBOS, integrated through the state-owned EBS switch, under the Banking Business Act and revised post-2020 e-money regulations.

Banking / Foreign-Exchange Licence (CBOS)

Banking and FX licensing by the CBOS under the Banking Business Act, the Foreign Exchange Dealing Act and associated regulations (interest-free / Islamic-banking model); FX-bureau and representative-office rules apply.

Gambling — none (criminally prohibited)

No gambling licence exists or can be issued. All gambling is criminalised under the Sudan Criminal Act 1991 (Chapter 19), consistent with Sharia.

Detailed overview

Sudan at a glance

Sudan (population estimated in the range of 47–50 million pre-war; low internet penetration historically ~31% — figures not separately primary-verified and materially disrupted by the conflict) has been in active armed conflict since April 2023, with formal financial services largely unavailable in conflict zones, EBS-centralised data centres/operations damaged early in the war, and parallel administrative structures. The economy runs on hyperinflation, hawala and informal channels, and the country carries severe US/UN sanctions exposure.

Crypto regime — no framework, CBOS warning:

  • No virtual-asset/crypto statute; crypto is "not classified as money or even private money and property" per the CBOS
  • CBOS warning (March 2022, via SUNA) — citizens advised against all types of cryptocurrency; cited financial crime, electronic piracy and loss of value; flagged legal risk
  • Electronic Transactions Act 2007 — only adjacent statute; predates Bitcoin; addresses e-signatures, e-contracting and data secrecy, not virtual assets
  • AML/CFT circulars (2019–2024) — banks and mobile-money operators must file suspicious-transaction reports on crypto-linked transfers above a threshold reported around USD 8,000 (≈ SDG 4.8 million)
  • Draft FinTech Bill — reported to introduce VASP licensing tiers, local data hosting and a cash-out levy; unenacted; parliamentary progress disrupted by the war
  • Informal stablecoin/P2P and USSD-wallet activity persists (sanctions, remittance backlogs, hyperinflation) — entirely outside any legal framework

Payments and e-money regime (CBOS / EBS-centralised):

  • Banking Business Act — core banking law; Anti-Money Laundering & Financing of Terrorism Act; Foreign Exchange Dealing Act and FX-bureau/representative-office regulations; Deposit Guarantee Fund Act
  • Electronic Banking Services (EBS) — CBOS-owned; the national central switch, clearing house, ATM switch and SWIFT gateway (connected 2005); until late 2020 the only entity permitted to issue e-money
  • Revised e-money regulations (post-2020) — opened mobile-money issuance beyond EBS; legacy and new models still run in parallel with critical EBS dependencies
  • The financial system is interest-free/Islamic-banking based; the CBOS operates a managed official exchange rate alongside a far weaker parallel market
  • Conflict impact: EBS power/operations loss early in the war took down much of the mobile-money ecosystem; formal services largely unavailable in conflict areas

Gambling regime — criminally prohibited:

  • Sudan Criminal Act 1991 — Chapter 19; gambling/lottery offence commonly cited around Section 237; betting or operating gambling premises is an offence (imprisonment commonly cited up to ~6 months to one year, plus fines per the scale of offence)
  • Sharia — Islam shapes Sudanese legislation; games of chance (maisir/qimar) forbidden
  • No national lottery, no regulator, no licensing route, no player protection; all forms (casino, sports betting, lottery, sweepstakes, informal) prohibited

Last verified: May 2026. Reference rate: USD 1 = SDG 600 (official/quoted; 1 SDG ≈ USD 0.00167). This is a managed official rate with near-zero quoted volatility; the wartime parallel-market rate is materially weaker and the official rate is unreliable for real transactions — re-verify against the CBOS published rate and the prevailing parallel rate for any filing.

Sudan is a conflict-and-sanctions jurisdiction that is closed for crypto (no framework, CBOS warning) and gambling (criminally prohibited under the 1991 Criminal Act and Sharia); the only nominal licensing path is CBOS/EBS-centralised payments, in a war-fractured, capital-controlled, severely sanctions-exposed environment.

Is there a crypto licence in Sudan?

No. There is no crypto or virtual-asset framework or licence in Sudan. The Central Bank of Sudan warned in 2022 that crypto is not money or property and is high-risk. Only the Electronic Transactions Act 2007 (pre-Bitcoin) and AML circulars apply; a draft FinTech Bill is unenacted.

The legal foundation:

  • No virtual-asset/crypto statute; crypto not classified as money or property (CBOS)
  • CBOS warning (March 2022, via SUNA) — against all crypto; financial-crime, piracy, loss-of-value and legal risk
  • Electronic Transactions Act 2007 — adjacent only; predates Bitcoin
  • AML/CFT circulars (2019–2024) — STR obligations on crypto-linked transfers above ~USD 8,000 (≈ SDG 4.8 million)
  • Draft FinTech Bill — VASP licensing tiers, local hosting, cash-out levy; unenacted

Structure:

  • No VASP/exchange/custody/mining authorisation exists; no licensing route
  • Activity is informal (P2P/USDT, USSD wallets, hawala cash-out) — outside legal protection; sanctions cause widespread geoblocking of Sudan
  • Tax authorities treat crypto gains under general income rules (miscellaneous income) by analogy — no crypto-specific code

Operational reality:

  • A regulatory vacuum compounded by active armed conflict and severe sanctions exposure — not a viable market-entry jurisdiction for regulated crypto activity
  • Any framework depends on the unenacted FinTech Bill and a return to functioning governance — neither is reliably timed
  • Independent sanctions screening and current verification with the CBOS are essential before any consideration

Payments & E-money (Central Bank of Sudan / EBS)

Best for institutions prepared to operate within the CBOS/EBS-centralised system and to absorb extreme operational and country risk.

What it is: CBOS licensing of banking, financial-services and mobile-money activity, integrated through the state-owned EBS switch, under the Banking Business Act and revised post-2020 e-money regulations.

Who it suits: Domestic banks, financial-services providers and mobile-money operators able to integrate with EBS and operate under interest-free banking and CBOS supervision (in practice severely constrained by the conflict).

Covers: Bank accounts, cards, ATM/POS, mobile money and e-money, routed through the EBS central switch/clearing house; FX activity requires separate CBOS licensing under the Foreign Exchange Dealing Act.

Operational requirement: Local entity; CBOS licensing and EBS technical integration; compliance with the Banking Business Act, AML/CFT Act and FX regulations; interest-free/Islamic-banking model; KYC per CBOS rules; acute operational dependency on EBS availability and conflict conditions.

Headline figures

  • Core laws: Banking Business Act; AML/CFT Act; Foreign Exchange Dealing Act; Deposit Guarantee Fund Act; Electronic Transactions Act 2007
  • Switch/issuer: EBS (CBOS-owned national switch/clearing house; sole e-money issuer until late 2020; opened post-2020)
  • Market cost estimate: ~US$10.5 million over three years to fintech profitability (independent estimate, not an official fee)
  • AML threshold (reported): STR on crypto-linked transfers above ~USD 8,000 (≈ SDG 4.8 million)
  • FX: managed official rate vs far weaker parallel rate; all FX activity CBOS-licensed

Is there a gambling licence in Sudan?

No. All gambling is criminally prohibited in Sudan under the Sudan Criminal Act 1991 (Chapter 19; gambling/lottery offence commonly cited around Section 237), consistent with Sharia. There is no national lottery, no regulator, no licence and no player protection.

The legal foundation:

  • Sudan Criminal Act 1991 — Chapter 19; betting or operating gambling premises is an offence; imprisonment commonly cited up to ~6 months to one year plus fines per the scale of offence
  • Sharia — Islam shapes Sudanese legislation; games of chance (maisir/qimar) forbidden
  • No national lottery; no licensing statute; comprehensive ban across casino, sports betting, lottery, sweepstakes and informal gambling

Structure:

  • No regulator, no licensing category, no legal route to operate any gambling product (land-based or online)
  • Enforcement is religiously and criminally grounded; no liberalisation effort signalled
  • Offshore access is informal and at users' legal risk

Gambling — not available (prohibited)

Not applicable — there is no gambling licence in Sudan and none can be issued.

What it is: There is no gambling authorisation in Sudan; all gambling is a criminal offence.

Who it suits: No operator — market entry is not legally possible.

Covers: Nothing; all gambling (land-based and online) is prohibited.

Operational requirement: Not applicable; engaging in or operating gambling exposes individuals and operators to criminal penalties under the Sudan Criminal Act 1991.

Headline figures

  • Status: criminally prohibited (Sudan Criminal Act 1991, Chapter 19; Sharia)
  • Penalty (commonly cited): imprisonment up to ~6 months to one year, plus fines
  • Regulator / licence / player protection: none
  • Liberalisation outlook: none signalled (Sharia-grounded prohibition; no national lottery)

Costs and timelines at a glance

  • Crypto: no framework; CBOS 2022 warning (not money/property, high-risk); only Electronic Transactions Act 2007 + AML circulars; draft FinTech Bill unenacted
  • Crypto AML (reported): STR on crypto-linked transfers above ~USD 8,000 (≈ SDG 4.8 million)
  • Payments core laws: Banking Business Act; AML/CFT Act; Foreign Exchange Dealing Act; Deposit Guarantee Fund Act; Electronic Transactions Act 2007
  • Payments switch/issuer: EBS (CBOS-owned; sole e-money issuer until late 2020; opened post-2020)
  • Payments cost estimate: ~US$10.5m over 3 years to fintech profitability (market estimate)
  • FX: managed official rate (~SDG 600/USD) vs far weaker parallel rate; all FX CBOS-licensed
  • Gambling: criminally prohibited (Sudan Criminal Act 1991, Chapter 19; Sharia); no licence; no national lottery
  • Conflict: active armed conflict since April 2023; EBS infrastructure damaged; formal services largely unavailable in conflict zones
  • FX rate: USD 1 = SDG 600 (official/quoted; 1 SDG ≈ USD 0.00167)

Who Sudan suits and who it does not

Suitable for

  • (Severely constrained) domestic banks and mobile-money operators already integrated with EBS and able to operate under CBOS interest-free banking supervision despite conflict conditions — realistically only with extreme risk tolerance and on-the-ground capacity
  • Humanitarian/development-linked payment programmes coordinating with the CBOS and EBS for cash-transfer disbursement, with appropriate sanctions clearance
  • Groups with exceptional country-risk capacity and independent counsel able to assess active-conflict, sanctions and parallel-authority exposure and verify all requirements directly with the CBOS

Not suitable for

  • Any crypto/virtual-asset business — there is no framework or licence, the CBOS has warned against crypto, and sanctions cause widespread geoblocking
  • Any gambling operator — all gambling is a criminal offence under the Sudan Criminal Act 1991; no regulator, licence or route exists
  • Payment/fintech firms needing stable infrastructure, reliable SWIFT/FX access, a credible single official rate, or operations outside conflict zones
  • Operators sensitive to active armed conflict, parallel/competing administrations, a fractured central-bank/EBS infrastructure, or severe US/UN sanctions exposure
  • Anyone expecting near-term liberalisation of crypto or gambling — neither is reliably signalled and gambling prohibition is Sharia-grounded

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