South Sudan

**Report: Retail Cryptocurrency Trading Status in South Sudan**

**Date:** April 12, 2025

**Topic:** Retail_Trading_Status (Cryptocurrency)

**Description:** Assessment of the legal and regulatory environment for individual citizens and residents in South Sudan regarding the buying, selling, and holding of cryptocurrencies, including applicable regulations like KYC/AML and official warnings.

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**1. Current Status:** `Allowed-UnRegulated`

**2. Detailed Narrative Explanation:**

South Sudan currently lacks a specific legal or regulatory framework explicitly governing cryptocurrencies and their trading by retail users. While not formally recognized or regulated, there is no outright legal prohibition preventing individuals from buying, selling, or holding digital assets like Bitcoin. This places cryptocurrency activities in a legal grey area within the country.

The Bank of South Sudan (BoSS), the nation's central bank, has made its position clear through official communications. In October 2022, BoSS issued a press release and public warnings advising citizens against investing in or transacting with virtual currencies. The bank explicitly stated that cryptocurrencies like Bitcoin "do not have legal tender status in South Sudan." It highlighted significant risks associated with these assets, including high volatility, the potential for financial loss due to lack of consumer protection, and the risk of misuse for illicit activities such as money laundering and terrorism financing.

Crucially, BoSS confirmed that "Providers of virtual currencies in South Sudan are neither regulated nor supervised by the Bank of South Sudan," and there are no legislative provisions under the bank's purview offering protection to consumers engaging with these assets. This lack of oversight means users interact with cryptocurrency platforms and services at their own risk, without recourse through official channels in case of fraud or platform failure.

Despite these strong warnings and the lack of legal tender status, the central bank's statements did not constitute an explicit ban on the *use* or *possession* of cryptocurrencies by individuals. Therefore, retail trading remains technically allowed, albeit entirely unregulated and strongly discouraged by the financial authorities.

South Sudan does have an Anti-Money Laundering and Counter-Terrorism Act (2012), which was amended in 2024, and operates a Financial Intelligence Unit (FIU). The country is also working to address deficiencies noted by the Financial Action Task Force (FATF), which placed it on the grey list in 2021. While these frameworks exist to combat financial crime generally, they do not currently include specific provisions targeting cryptocurrency exchanges or users for registration, licensing, or detailed transaction reporting beyond general suspicious activity reporting applicable to all financial transactions. The BoSS warning did, however, explicitly link the anonymity of virtual currency transactions to potential AML/CFT risks.

Practically, some international cryptocurrency exchanges and peer-to-peer (P2P) platforms may allow South Sudanese residents to register and trade, often requiring standard Know Your Customer (KYC) procedures. However, the overall adoption is likely hindered by infrastructural challenges, including limited internet access and a developing financial system, alongside the risks highlighted by the central bank.

In summary, retail cryptocurrency trading in South Sudan is not illegal but exists in a complete regulatory vacuum. The central bank strongly advises against it due to significant risks and the absence of any regulatory oversight or consumer protection mechanisms.

**3. Relevant Text Excerpts:**

*   **On Lack of Regulation:** "South Sudan currently has no regulatory framework for cryptocurrency, which creates uncertainty for investors and hinders the industry's growth."
    *   *Source:* Tech In Africa (2023-04-08) [3]
*   **On Lack of Specific Laws:** "Currently, South Sudan has no specific laws or regulations that address the use of cryptocurrencies. The Bank of South Sudan has not issued any official statements regarding the legal status of digital currencies. This lack of regulation means that there is no formal framework to govern cryptocurrency use, but it also implies there are no explicit bans either."
    *   *Source:* Carlos Maiz Blog (Undated, accessed 2025) [9]
*   **On Central Bank Warning & Legal Status:** "Virtual currencies such as Bitcoin are a digital representation of the value that can be digitally traded and functions as a medium of exchange within a specified online community but does not have legal status in South Sudan... Ohisa issued a statement prohibiting citizens from dealing with virtual currencies, particularly bitcoins saying they don't have legal status in the country." *(Note: While the article uses "prohibiting citizens from dealing", the official BoSS statement [5] focuses on advising risks and clarifying lack of legal tender/regulation, not an outright ban on individual dealing/possession).*
    *   *Source:* Sudans Post (2022-10-06) [4]
*   **On Lack of Supervision and Protection (BoSS Statement):** "Providers of virtual currencies in South Sudan are neither regulated nor supervised by the Bank of South Sudan and there is currently no legislative provision under the Banks' purview that provides protection to customers for losses arising from the use of virtual currencies."
    *   *Source:* Bank of South Sudan Press Release (2022-10-07) [5]
*   **On AML/CFT Risks (BoSS Statement):** "Transactions involving virtual currencies are subjected to a high degree of anonymity. As such, there is the potential for misuse of virtual currency to conduct criminal activity, including money laundering or terrorism financing..."
    *   *Source:* Bank of South Sudan Press Release (2022-10-07) [5]
*   **On AML Legislation:** "The primary legislation governing KYC/AML in South Sudan is the Anti-Money Laundering and Counter-Terrorism Act 2012." (Note: Amended in 2024 [16])
    *   *Source:* Smile ID (Undated, accessed 2025) [12]

**4. Source URLs:**

*   **[3] Tech In Africa (Cryptocurrency in South Sudan):** `https://techinafrica.com/cryptocurrency-in-south-sudan-opportunities-and-challenges/` (Link derived from search result context)
*   **[4] Sudans Post (Central Bank Warning):** `https://www.sudanspost.com/south-sudan-central-bank-warns-citizens-against-use-of-bitcoin/` (Link derived from search result context)
*   **[5] Bank of South Sudan Press Release (PDF):** `https://boss.gov.ss/wp-content/uploads/2022/10/Press-Release-7.10.22.pdf` (Link derived from search result context - *Note: Direct PDF link*) or via BoSS website publications section if available.
*   **[6] ECA (AML/CFT Workshop):** `https://www.uneca.org/press-releases/eca-and-fiu-south-sudan-lead-groundbreaking-workshop-on-aml/cft-in-juba` (Link derived from search result context)
*   **[7] Kotigi.com (Pi Network Legality):** `https://kotigi.com/is-pi-network-legal-in-south-sudan-must-read/` (Link derived from search result context)
*   **[9] Carlos Maiz Blog (Buy Bitcoin in South Sudan):** `https://carlosmaiz.com/en/buy-bitcoin-south-sudan/` (Link derived from search result context)
*   **[12] Smile ID (Digital Identity Verification):** `https://usesmileid.com/countries/kyc-south-sudan` (Link derived from search result context)
*   **[16] Eye Radio (FIU Efforts):** `https://eyeradio.org/south-sudan-steps-up-intelligence-efforts-to-fight-financial-crimes/` (Link derived from search result context)
*   **[19] Bank of South Sudan (Regulations Page):** `https://boss.gov.ss/regulations/` (Link derived from search result context)