Sudan

The regulatory status of cryptocurrency in Sudan is best classified as a 'Gray-Zone.' While there is no single piece of legislation that explicitly criminalizes the mere possession of Bitcoin or other digital assets by individuals, the government's stance is openly hostile. The Central Bank of Sudan (CBOS) issued a definitive warning in March 2022, disseminated through the Sudan News Agency (SUNA), which advised citizens to 'steer clear' of cryptocurrencies. The CBOS justified this stance by citing high risks of financial crimes, electronic piracy, and volatility, explicitly stating that virtual assets are not classified as money or even private property under the republic's laws.

This lack of legal classification has profound implications. Because the *Electronic Transactions Act of 2007*—the country's main digital commerce law—predates cryptocurrency, it does not offer any regulatory framework or protection. Consequently, crypto assets exist in a legal void. If a citizen is defrauded or their assets are stolen, the judicial system may refuse to hear the case on the grounds that the asset in question does not legally exist as property. Furthermore, the CBOS warning acts as a de facto ban on the formal banking sector, preventing licensed financial institutions from offering custody, exchange, or transfer services for crypto assets.

Despite these restrictions, a significant underground market exists, driven largely by the need to hedge against the rapid devaluation of the Sudanese Pound and to facilitate cross-border remittances in a sanctions-heavy environment. Reports indicate that Sudanese nationals use peer-to-peer (P2P) platforms and informal 'hawala' networks to trade, bypassing the formal banking blockade. However, this activity carries the constant threat of enforcement under broad anti-money laundering (AML) and foreign exchange statutes, which authorities can leverage to freeze accounts or seize assets suspected of being linked to 'illegal' financial flows.

It is crucial to distinguish between 'unregulated' and 'gray-zone' in this context. In an unregulated market, the government might be passive or indifferent. In Sudan, the government is actively warning against the asset class and denying it legal status, creating a hostile operating environment. While we have not seen a specific law imposing jail time solely for holding a wallet (as seen in strictly banned jurisdictions like Nepal), the combination of banking prohibitions, legal non-recognition, and the threat of AML enforcement places Sudan firmly in the Gray-Zone.