Sudan

{
  "analysis_text": "The regulatory status of cryptocurrency in Sudan is best classified as a \u0027Gray-Zone.\u0027 While there is no single piece of legislation that explicitly criminalizes the mere possession of Bitcoin or other digital assets by individuals, the government\u0027s 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 \u0027steer clear\u0027 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\u0027s laws.\n\nThis lack of legal classification has profound implications. Because the *Electronic Transactions Act of 2007*\u2014the country\u0027s main digital commerce law\u2014predates 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.\n\nDespite 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 \u0027hawala\u0027 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 \u0027illegal\u0027 financial flows.\n\nIt is crucial to distinguish between \u0027unregulated\u0027 and \u0027gray-zone\u0027 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.",
  "confidence_level": "High",
  "executive_summary": "Retail cryptocurrency trading in Sudan is in a regulatory gray zone, characterized by active central bank hostility and a lack of legal recognition. The Central Bank of Sudan (CBOS) has issued warnings advising citizens against dealing in cryptocurrencies, stating they are not classified as money or property under current laws. While there is no specific legislation explicitly criminalizing individual possession, the lack of legal recourse and the prohibition on banks processing crypto transactions create significant legal and operational risks.",
  "grounding_urls": [
    {
      "resolved_url": "https://coinfomania.com/cryptocurrency-regulation-in-sudan/",
      "title": "coinfomania.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEM28Q-nM0Bd0gxzhsGaji9Q9j76k-EXvfaLBAJ6MBU27nmOZFd0P5xZWrewvYZmsj0GZwninX7wAOPK76BgGh8YMqV3_fYK3WKjtmxNgiLQqljvyEWlOmN-NselSmGpFEWwlZ9pGIMM0YEIhpV4fCte4R7k_4e"
    },
    {
      "resolved_url": "https://zycrypto.com/central-bank-of-sudan-urges-citizens-to-steer-clear-of-cryptocurrencies-despite-economic-downturn/",
      "title": "zycrypto.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFaQoiE61bnS9PFQU4uWd6HNFHWIo2rMqSzXm5yLgignm_dsWJcB_B9pNaIfW3knDVZDt3fTLvK4pQRbgDjgS0ERRc1Nq768PCeH91wGN76l61VDVRb0aNB-3dqx8V2VP1qE6TxtgE2lOOnB8xsmjpQ63xHOtwkvJN8kKL7eSrP34bOGI0ZLBkRWtxdmJUbZENhkMmLxFqIEuKgoP31D4mhSHmzgfXolR-4BvGJv0dnEElw"
    },
    {
      "resolved_url": "https://news.bitcoin.com/central-bank-of-sudan-warns-of-risks-associated-with-cryptocurrency/",
      "title": "bitcoin.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQG01QB6XZ_DsljDQUUsvJkVWTdpf4GZnN9G6Yljmy98XHDe-y13KT_8X4SafAJmqZsdcVc7-V2Ag9Ep_ZcSQ3ziWqsk9BKJM07uR_iKXOTQfhXmVgRpiPE5gYrnP4TgNGUFOCcGl9GZrV7cAwiWzWE9Mv-7-DckwXzsJmEwEw1IYKKZUsLFqB03w9e96HtTaOEPa69-jtC-tQ=="
    },
    {
      "resolved_url": "https://coingeek.com/sudan-central-bank-warns-against-digital-currencies-amid-economic-collapse/",
      "title": "coingeek.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFBrzfU9iJGf1EzEF2Q8fbWCzVTwP13caXjAM3blbfrWUutLHQ0FU6sCi95vk2vQUhTi47Vt8vRPk2LTodC8skaGHSf49DTZOWPAWxcY0rHM21E6o6qUXzCSEE6lciNVtOZx8iy2-u_NNbuv1wNu6FBfb11z8-tsdefOG4g04XzCp23vypp95gyJuLLq7FZqTAjEdWUoeC3MBILbA=="
    },
    {
      "resolved_url": "https://boss.gov.ss/wp-content/uploads/2022/10/Press-Release-7.10.22.pdf",
      "title": "boss.gov.ss",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQH4CiZsL7SdEJJPhtqqxgVafUiNVdfvBoKclZvlv0P6B-2xCQK3lPpSxbvCQR1aQxwAsk2jKdPXnLJaRbED32ilLeO0cZSbarZeDXeSplTM_koiVObqCY_nQqzfbTD4wX2dvoR_M1kklIKkLTZlEmkFOWpaCZW8y56GRzJWC3ezdfyDaA=="
    }
  ],
  "status": "Gray-Zone",
  "structured_data": {
    "confidence_level": "High",
    "detailed_analysis": "The regulatory status of cryptocurrency in Sudan is best classified as a \u0027Gray-Zone.\u0027 While there is no single piece of legislation that explicitly criminalizes the mere possession of Bitcoin or other digital assets by individuals, the government\u0027s 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 \u0027steer clear\u0027 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\u0027s laws.\n\nThis lack of legal classification has profound implications. Because the *Electronic Transactions Act of 2007*\u2014the country\u0027s main digital commerce law\u2014predates 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.\n\nDespite 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 \u0027hawala\u0027 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 \u0027illegal\u0027 financial flows.\n\nIt is crucial to distinguish between \u0027unregulated\u0027 and \u0027gray-zone\u0027 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.",
    "executive_summary": "Retail cryptocurrency trading in Sudan is in a regulatory gray zone, characterized by active central bank hostility and a lack of legal recognition. The Central Bank of Sudan (CBOS) has issued warnings advising citizens against dealing in cryptocurrencies, stating they are not classified as money or property under current laws. While there is no specific legislation explicitly criminalizing individual possession, the lack of legal recourse and the prohibition on banks processing crypto transactions create significant legal and operational risks.",
    "important_considerations": [
      "Legal Recourse Risk: Since crypto is not recognized as property, victims of theft or fraud have no legal standing to recover assets in Sudanese courts.",
      "Sanctions Environment: Sudan\u0027s history of international sanctions makes the government highly sensitive to unregulated financial flows, increasing the risk of asset seizure.",
      "Inflation Hedge: Despite warnings, adoption is driven by hyperinflation and the devaluation of the Sudanese Pound (SDG).",
      "Banking Blockade: Users cannot legally use local bank accounts to fund crypto exchanges; activity is pushed to P2P markets and the informal economy."
    ],
    "key_regulatory_pillars": [
      "Central Bank of Sudan (CBOS) - Primary financial regulator issuing warnings and banking circulars.",
      "Banking Prohibition - Banks are effectively prohibited from facilitating crypto transactions due to \u0027legal risks\u0027 and lack of recognition.",
      "Legal Non-Recognition - Cryptocurrencies are not recognized as \u0027money\u0027 or \u0027property\u0027 under the Electronic Transactions Act 2007.",
      "Anti-Money Laundering (AML) - Strict AML controls are likely applied to any crypto-related flows detected in the banking system due to sanctions and FATF compliance."
    ],
    "landmark_legislation": [
      {
        "date_enacted": "2022-03-27",
        "identifier": "CBOS Warning (via SUNA)",
        "name": "Central Bank of Sudan Warning on Cryptocurrencies",
        "summary": "A public warning advising citizens to avoid cryptocurrencies due to high risks of financial crime and volatility. It clarified that crypto is not classified as money or private property under Sudanese law.",
        "url": "https://cbos.gov.sd"
      },
      {
        "date_enacted": "2007-01-01",
        "identifier": "Act of 2007",
        "name": "Electronic Transactions Act",
        "summary": "The primary law governing digital commerce. The Central Bank has clarified that this act predates crypto and does not provide legal cover or recognition for virtual assets.",
        "url": "https://cbos.gov.sd/en/node/363"
      }
    ],
    "notes_and_comments": "Some online sources (e.g., MEXC Wiki, Coinfomania) may contain AI-generated or outdated content claiming mining is legal or regulated in 2024/2025. These claims contradict the official CBOS stance and lack verifiable citations. The analysis relies on the confirmed 2022 CBOS warning as the most authoritative current stance.",
    "primary_sources": [
      {
        "date": "2022-03-29",
        "key_quote": "The Central Bank of Sudan has decided to remain up to date... [lists Electronic Transactions Act 2007]",
        "source_type": "official_government",
        "title": "Central Bank of Sudan Website - Laws and Regulations",
        "url": "https://cbos.gov.sd/en/regulations"
      },
      {
        "date": "2022-03-29",
        "key_quote": "The CBOS also believes that digital currencies come with legal risks as they are not classified as money or even private money and property in accordance with the legislation.",
        "source_type": "news",
        "title": "Sudan\u0027s Apex Bank Warns Citizens against Dealing in Cryptocurrencies",
        "url": "https://suna-sd.net"
      }
    ],
    "remaining_uncertainties": [
      "Whether the \u0027legal risks\u0027 mentioned by CBOS have translated into specific arrests of individual traders (distinct from cybercriminals/hackers).",
      "The exact text of the 2022 circular (only reported via news agencies like SUNA, not directly downloadable from the current CBOS site).",
      "Status of any upcoming \u0027FinTech Bill\u0027 rumored in some less reliable sources."
    ],
    "secondary_sources": [
      {
        "date": "2022-04-04",
        "key_quote": "The Central Bank of Sudan (CBOS) recently issued the warning, stating that digital currencies entail high risks... financial crimes, electronic piracy and the risk of losing their value.",
        "source_type": "news",
        "title": "Sudan\u0027s central bank warns against digital currencies amid economic collapse",
        "url": "https://coingeek.com/sudan-central-bank-warns-against-digital-currencies-amid-economic-collapse/"
      },
      {
        "date": "2023-01-01",
        "key_quote": "Sudan has not currently enacted regulations or legislation specifically regulating digital currency yet... it does not cover cryptocurrencies because the Electronic Transactions Act, 2007 was enacted before the rise of these virtual currencies.",
        "source_type": "analysis",
        "title": "Sudan and Cryptocurrency - Freeman Law",
        "url": "https://freemanlaw.com/cryptocurrency/sudan/"
      }
    ],
    "status": "Gray-Zone"
  }
}