South Sudan

Retail_Trading_Status

Allowed-Unregulated High Confidence

Status Changed

Previous status: Gray-Zone

Reconciled from live analysis after human review confirmed status as Allowed-UnRegulated. The original new analysis incorrectly classified as Gray-Zone. The corrected status reflects that while the Bank of South Sudan has issued strong warnings and restricted banking sector involvement, no law explicitly criminalizes individual retail trading, making it allowed but unregulated. New information from the latest analysis (enforcement actions, banking prohibition, FATF status) was incorporated as factual support for the unregulated and high-risk environment.

Analysis ID: #873
Version: Latest
Created: 2025-12-13 07:29
Run: 5097b13e...
History: View all versions
Workflow Stage: Reconciled

Executive Summary

Retail cryptocurrency trading in South Sudan is allowed but entirely unregulated. The Bank of South Sudan (BoSS) has warned against the use of cryptocurrencies due to associated risks and lack of legal tender status, and has prohibited regulated financial institutions from processing crypto-related transactions. Key requirements such as licensing and specific AML/KYC regulations targeting cryptocurrency exchanges are absent, although the Anti-Money Laundering and Counter-Terrorism Act (2012, amended 2024) exists. The BoSS does not supervise or regulate cryptocurrency providers and strongly advises against their use due to significant risks. Authorities have conducted enforcement actions against unlicensed crypto investment firms.

Key Pillars

Primary Regulator: The Bank of South Sudan (BoSS), which has issued warnings against cryptocurrency use and prohibits financial institutions from facilitating crypto transactions, but does not regulate or supervise providers. Financial Intelligence Unit (FIU): Tasked with AML/CFT monitoring, though capacity is limited. Core Compliance: The Anti-Money Laundering and Counter-Terrorism Act (2012, amended 2024) governs KYC/AML but does not specifically target cryptocurrency exchanges or users. Licensing and Registration: There are currently no licensing or registration requirements for cryptocurrency exchanges or users.

Landmark Laws

Anti-Money Laundering and Counter-Terrorism Act (2012, amended 2024): This act governs KYC/AML in South Sudan but does not include specific provisions targeting cryptocurrency exchanges or users beyond general suspicious activity reporting.
Bank of South Sudan Public Warning on Virtual Currencies (2022-10-06): A press statement by Governor Johny Ohisa Damian declaring that virtual currencies like Bitcoin have no legal status in South Sudan and advising citizens against dealing in them. The statement warns that providers are unregulated and unsupervised.
Bank of South Sudan Act, 2011 (Act No. 10 of 2011): The primary banking law which grants the BoSS authority to regulate the financial sector and issue currency. It is the basis for the Central Bank's authority to declare crypto as non-legal tender.

Considerations

Cryptocurrencies are not recognized as legal tender in South Sudan.
The Bank of South Sudan highlights significant risks associated with cryptocurrencies, including high volatility and the potential for financial loss due to the lack of consumer protection, as well as the risk of misuse for money laundering and terrorism financing.
Operational challenges include limited internet access and a developing financial system.
Strict capital controls and foreign exchange restrictions in South Sudan indirectly hamper crypto-fiat on-ramps.
Enforcement actions have been taken against unlicensed crypto businesses, such as the raid on Silicone Valley Shares in September 2022, indicating that authorities are willing to act against commercial entities perceived as operating without proper authorization.
South Sudan is on the FATF 'Jurisdictions under Increased Monitoring' list (grey list), increasing pressure to improve AML/CFT frameworks, which may influence future regulation.

Notes

The Bank of South Sudan (BoSS) issued a press release and public warnings in October 2022 advising citizens against investing in or transacting with virtual currencies. Despite the lack of regulation, 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. The Financial Action Task Force (FATF) placed South Sudan on the grey list in 2021. Enforcement actions, such as the raid on Silicone Valley Shares, appear targeted at unlicensed financial intermediaries rather than individual users. The central bank's warning is a regulatory advisory, but there is no specific legislation criminalizing private possession of cryptocurrencies.

Remaining Uncertainties

Whether the 'prohibition' mentioned by the Central Bank Governor is backed by a specific penal code provision or if it is purely a regulatory directive.
The specific legal grounds used for the arrest of the Silicone Valley Shares staff (e.g., fraud, operating without a license, or specific crypto violation).
Current status of P2P trading enforcement—whether individual traders are actively targeted or only corporate entities.

Detailed Explanation

Retail cryptocurrency trading in South Sudan is allowed but entirely unregulated. The Bank of South Sudan (BoSS) serves as the primary financial regulator and has taken a cautious stance toward cryptocurrencies, issuing explicit warnings about their risks while not implementing specific regulatory frameworks for cryptocurrency exchanges or service providers. In October 2022, Governor Johny Ohisa Damian issued a press statement declaring that virtual currencies like Bitcoin have no legal status in South Sudan and strongly advising citizens against dealing in them. This warning highlighted that cryptocurrency providers operate without supervision and emphasized the significant risks including high volatility, potential for financial loss, and susceptibility to money laundering and terrorism financing. The Bank of South Sudan has prohibited regulated financial institutions from processing cryptocurrency-related transactions, creating a significant barrier to formal crypto-fiat on-ramps. The regulatory landscape is governed by the broader Anti-Money Laundering and Counter-Terrorism Act of 2012, amended in 2024, which establishes general KYC/AML requirements but does not contain specific provisions targeting cryptocurrency exchanges or users. There are currently no licensing or registration requirements for cryptocurrency exchanges operating in South Sudan, and the BoSS does not supervise or regulate cryptocurrency providers. Despite the lack of formal regulation, authorities have demonstrated willingness to take enforcement actions against unlicensed crypto investment firms, as evidenced by the raid on Silicone Valley Shares in September 2022. South Sudan's placement on the FATF 'Jurisdictions under Increased Monitoring' list (grey list) in 2021 creates additional pressure to improve AML/CFT frameworks, which may influence future cryptocurrency regulation. Operational challenges such as limited internet access, a developing financial system, and strict capital controls further complicate cryptocurrency adoption and regulation in the country.

Summary Points

I. Regulatory Status
* Allowed but entirely unregulated for retail trading
* Bank of South Sudan (BoSS) has issued warnings against cryptocurrency use
* No specific licensing or registration requirements for cryptocurrency exchanges
* Cryptocurrencies are not recognized as legal tender

II. Key Regulatory Bodies
* Bank of South Sudan (BoSS): Primary financial regulator that has prohibited financial institutions from processing crypto transactions but does not regulate cryptocurrency providers
* Financial Intelligence Unit (FIU): Tasked with AML/CFT monitoring, though capacity is limited

III. Important Legislation
* Anti-Money Laundering and Counter-Terrorism Act (2012, amended 2024): Governs general KYC/AML but lacks specific provisions for cryptocurrencies
* Bank of South Sudan Act, 2011 (Act No. 10 of 2011): Grants BoSS authority to regulate financial sector and issue currency, basis for declaring crypto as non-legal tender
* Bank of South Sudan Public Warning on Virtual Currencies (2022-10-06): Official statement advising against cryptocurrency use

IV. Compliance Requirements
* No specific cryptocurrency licensing requirements
* No registration requirements for exchanges or users
* General AML/CFT obligations under existing legislation apply

V. Notable Restrictions or Limitations
* BoSS prohibits regulated financial institutions from processing cryptocurrency-related transactions
* Strict capital controls and foreign exchange restrictions hamper crypto-fiat on-ramps
* Enforcement actions taken against unlicensed crypto businesses (e.g., raid on Silicone Valley Shares, September 2022)
* Limited internet access and developing financial system create operational challenges

VI. Recent Developments or Notes
* South Sudan placed on FATF 'grey list' in 2021, increasing pressure to improve AML/CFT frameworks
* BoSS emphasizes significant risks including volatility, financial loss, and potential for money laundering/terrorism financing
* Some international exchanges and P2P platforms may allow South Sudanese residents to register with standard KYC procedures
* Central bank's warning is advisory, no legislation criminalizing private possession of cryptocurrencies

Full Analysis Report

Report on Retail_Trading_Status in South Sudan

Date: 2025-06-26 (Updated with latest information)

Topic: Retail_Trading_Status

Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

Retail_Trading_Status

Identified Status: Allowed-UnRegulated

Detailed Narrative Explanation:

Retail cryptocurrency trading in South Sudan is allowed but exists in a complete regulatory vacuum. There is no specific legal framework that bans or criminalizes the buying, selling, or holding of cryptocurrencies by individuals. However, the Bank of South Sudan (BoSS), the country's central bank, has issued explicit public warnings against the use of virtual currencies.

In October 2022, the BoSS published a press release stating that virtual currencies like Bitcoin "do not have legal tender status in South Sudan" and that "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" (BoSS Press Release, 2022-10-07). Media reports at the time quoted the Governor as "prohibiting citizens from dealing with virtual currencies" (Sudans Post, 2022-10-06), but the official statement itself uses cautionary language rather than enacting a statutory ban. The BoSS has also effectively barred regulated financial institutions from processing cryptocurrency transactions, isolating the activity from the formal banking sector.

Enforcement actions have targeted commercial crypto businesses. In September 2022, security operatives raided the offices of 'Silicone Valley Shares', a company trading in cryptocurrencies, arresting staff and seizing funds, despite the company's claims of being registered (Sudans Post, 2022-09-18). This indicates authorities are willing to act against entities they perceive as operating unlicensed financial services, but it does not constitute a ban on individual retail trading.

The broader legal framework includes the Anti-Money Laundering and Counter-Terrorism Act (2012, amended 2024), which imposes general AML/CFT obligations but does not contain specific provisions for cryptocurrency exchanges or users. South Sudan's Financial Intelligence Unit (FIU) operates under this act. The country remains on the FATF 'grey list' (Jurisdictions under Increased Monitoring) as of October 2025, indicating ongoing deficiencies in its AML/CFT regime (FATF, 2025-10-24).

Practically, some international cryptocurrency exchanges and peer-to-peer (P2P) platforms may allow South Sudanese residents to register and trade, subject to the platforms' own KYC procedures. However, adoption faces significant challenges, including limited internet penetration, a developing financial system, strict capital controls, and the central bank's persistent warnings.

In conclusion, while the Bank of South Sudan strongly discourages cryptocurrency use and has taken steps to restrict its integration with the formal financial system, there is no law that explicitly makes individual retail trading illegal. Therefore, the activity is allowed but entirely unregulated, carrying significant risk due to the absence of consumer protections and oversight.

Specific, Relevant Text Excerpts:

Bank of South Sudan (October 7, 2022): "Virtual currencies such as Bitcoin is a digital representation of the value that can be digitally traded and functions as medium of exchange within a specified online community but does not have legal tender status in South Sudan."
Bank of South Sudan (October 7, 2022): "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."
Sudans Post (October 6, 2022): "Ohisa issued a statement prohibiting citizens from dealing with virtual currencies, particularly bitcoins saying they don't have legal status in the country."
Sudans Post (September 18, 2022): "Security operatives in Juba have seized their funds and arrested an undisclosed number of office staff... Silicone Valley Shares is a legally registered and licensed company in South Sudan."
Cexfinder (January 1, 2025): "In short, crypto buying in South Sudan is legal. There are no laws prohibiting citizens from buying, selling or trading cryptocurrency assets. However, crypto is not legal tender."
UPay Blog (March 12, 2025): "Cryptocurrency adoption in South Sudan is still in its early stages, with no official legal framework in place. The Central Bank has issued warnings about the risks of digital currencies due to their volatility and lack of regulation."

Direct, Accessible URL Links to Sources:

## Report on Retail_Trading_Status in South Sudan

**Date:** 2025-06-26 (Updated with latest information)

**Topic:** Retail_Trading_Status

**Description:** Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

---

### Retail_Trading_Status

**Identified Status:** Allowed-UnRegulated

**Detailed Narrative Explanation:**

Retail cryptocurrency trading in South Sudan is allowed but exists in a complete regulatory vacuum. There is no specific legal framework that bans or criminalizes the buying, selling, or holding of cryptocurrencies by individuals. However, the Bank of South Sudan (BoSS), the country's central bank, has issued explicit public warnings against the use of virtual currencies.

In October 2022, the BoSS published a press release stating that virtual currencies like Bitcoin "do not have legal tender status in South Sudan" and that "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" (BoSS Press Release, 2022-10-07). Media reports at the time quoted the Governor as "prohibiting citizens from dealing with virtual currencies" (Sudans Post, 2022-10-06), but the official statement itself uses cautionary language rather than enacting a statutory ban. The BoSS has also effectively barred regulated financial institutions from processing cryptocurrency transactions, isolating the activity from the formal banking sector.

Enforcement actions have targeted commercial crypto businesses. In September 2022, security operatives raided the offices of 'Silicone Valley Shares', a company trading in cryptocurrencies, arresting staff and seizing funds, despite the company's claims of being registered (Sudans Post, 2022-09-18). This indicates authorities are willing to act against entities they perceive as operating unlicensed financial services, but it does not constitute a ban on individual retail trading.

The broader legal framework includes the Anti-Money Laundering and Counter-Terrorism Act (2012, amended 2024), which imposes general AML/CFT obligations but does not contain specific provisions for cryptocurrency exchanges or users. South Sudan's Financial Intelligence Unit (FIU) operates under this act. The country remains on the FATF 'grey list' (Jurisdictions under Increased Monitoring) as of October 2025, indicating ongoing deficiencies in its AML/CFT regime (FATF, 2025-10-24).

Practically, some international cryptocurrency exchanges and peer-to-peer (P2P) platforms may allow South Sudanese residents to register and trade, subject to the platforms' own KYC procedures. However, adoption faces significant challenges, including limited internet penetration, a developing financial system, strict capital controls, and the central bank's persistent warnings.

In conclusion, while the Bank of South Sudan strongly discourages cryptocurrency use and has taken steps to restrict its integration with the formal financial system, there is no law that explicitly makes individual retail trading illegal. Therefore, the activity is allowed but entirely unregulated, carrying significant risk due to the absence of consumer protections and oversight.

**Specific, Relevant Text Excerpts:**

*   **Bank of South Sudan (October 7, 2022):** "Virtual currencies such as Bitcoin is a digital representation of the value that can be digitally traded and functions as medium of exchange within a specified online community but does not have legal tender status in South Sudan."
*   **Bank of South Sudan (October 7, 2022):** "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."
*   **Sudans Post (October 6, 2022):** "Ohisa issued a statement prohibiting citizens from dealing with virtual currencies, particularly bitcoins saying they don't have legal status in the country."
*   **Sudans Post (September 18, 2022):** "Security operatives in Juba have seized their funds and arrested an undisclosed number of office staff... Silicone Valley Shares is a legally registered and licensed company in South Sudan."
*   **Cexfinder (January 1, 2025):** "In short, crypto buying in South Sudan is legal. There are no laws prohibiting citizens from buying, selling or trading cryptocurrency assets. However, crypto is not legal tender."
*   **UPay Blog (March 12, 2025):** "Cryptocurrency adoption in South Sudan is still in its early stages, with no official legal framework in place. The Central Bank has issued warnings about the risks of digital currencies due to their volatility and lack of regulation."

**Direct, Accessible URL Links to Sources:**

*   [Bank of South Sudan Press Release (October 7, 2022)](https://boss.gov.ss/wp-content/uploads/2022/10/Press-Release-7.10.22.pdf)
*   [Sudans Post - South Sudan central bank warns citizens against use of bitcoin (October 6, 2022)](https://www.sudanspost.com/south-sudan-central-bank-warns-citizens-against-use-of-bitcoin/)
*   [Sudans Post - Controversial cryptocurrency dealer Silicone Valley Shares claims security operatives seized their assets (September 18, 2022)](https://www.sudanspost.com/controversial-cryptocurrency-dealer-silicone-valley-shares-claims-security-operatives-seized-their-assets/)
*   [FATF - Jurisdictions under Increased Monitoring - October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Increased-monitoring-october-2025.html)
*   [Cexfinder - Best South Sudan Crypto Exchanges in 2025](https://cexfinder.com/country/south-sudan)
*   [UPay Blog - Crypto Adoption Around the World: South Sudan (March 12, 2025)](https://upay.blog/crypto-adoption-around-the-world-south-sudan/)
*   [Bank of South Sudan - Regulations Page](https://boss.gov.ss/regulations/)
*   [Bank of South Sudan Act, 2011](https://boss.gov.ss/wp-content/uploads/2021/02/Bank-of-South-Sudan-Act-2011.pdf)

Source Evidence

Primary and secondary sources cited in this analysis

Bank of South Sudan Press Release (October 7, 2022) primary

2022-10-07

"Virtual currencies such as Bitcoin is a digital representation of the value that can be digitally traded and functions as medium of exchange within a specified online community but does not have legal tender status in South Sudan."

South Sudan central bank warns citizens against use of bitcoin secondary

2022-10-06

"Ohisa issued a statement prohibiting citizens from dealing with virtual currencies, particularly bitcoins saying they don't have legal status in the country."

Controversial cryptocurrency dealer Silicone Valley Shares claims security operatives seized their assets secondary

2022-09-18

"Security operatives in Juba have seized their funds and arrested an undisclosed number of office staff... Silicone Valley Shares is a legally registered and licensed company in South Sudan."

Jurisdictions under Increased Monitoring - October 2025 primary

2025-10-24

"South Sudan should continue to work to implement its action plan... ensuring that competent authorities are suitably structured and capacitated."

Crypto Adoption Around the World: South Sudan secondary

2025-03-12

"Cryptocurrency adoption in South Sudan is still in its early stages, with no official legal framework in place. The Central Bank has issued warnings about the risks of digital currencies due to their volatility and lack of regulation."

Cryptocurrency Regulation Tracker secondary

2024-06

"South Sudan. Undecided. Cryptocurrency has no legal status; No formal cryptocurrency regulation put into place."

Cryptocurrency in South Sudan: Opportunities and Challenges secondary

2023-04-08

"South Sudan currently has no regulatory framework for cryptocurrency, which creates uncertainty for investors and hinders the industry's growth."

Pesabase : Sending Money to South Sudan secondary

2025-04-28

"Many African governments have strict regulations on crypto, but South Sudan's stance is still developing. By entering early, Pesabase can help shape regulatory frameworks in its favour, whilst establishing a licensed bank provides legitimacy and could attract partnerships with global FinTech firms."

Bank of South Sudan - Regulations Page primary

Best South Sudan Crypto Exchanges in 2025 secondary

2025-01-01

"In short, crypto buying in South Sudan is legal. There are no laws prohibiting citizens from buying, selling or trading cryptocurrency assets. However, crypto is not legal tender."