Sudan Cryptocurrency Regulation: The Central Bank’s Prohibition Extends Beyond Banks
Read Sudan’s virtual-asset prohibition, its scope beyond banks, and the 2026 banking law’s commencement, savings and penalty provisions.
On this page
Sudan’s cryptocurrency regulation includes a published central-bank prohibition. It reaches individuals and companies as well as supervised institutions.
Our Africa cryptocurrency regulation directory compares restrictions, licensing regimes and unresolved evidence across countries.
What does the central bank prohibit?
The Central Bank of Sudan issued Circular No. 9/2022 on 12 December 2022, effective that day.
It prohibits supervised banks, non-bank financial institutions and any natural or legal person from dealing in virtual assets through financial and banking transactions. It limits dealings to approved official currencies.
The circular invokes Article 21 of the central-bank law as amended in 2012. Its penalty paragraph refers to the Banking Business Act of 2004 and administrative or financial sanctions for supervised institutions.
The reference to natural and legal persons matters. An exchange should not describe this as a restriction on banks alone.
This guide does not determine how a court would classify every possession, custody, mining or software activity. The precise activity and applicable law still matter.
Did the 2026 banking law remove the prohibition?
The bank publishes the Arabic Banking Business Act 2026. The new law requires more than a check of the directory title.
Section 1 makes it effective from signature. The signed certification page gives 4 April 2026.
Section 2 repeals the 2004 Act. However, it preserves regulations, decisions, circulars and procedures issued under it until they are repealed or amended under the new law.
That savings clause prevents a simple claim that replacing the old Act automatically cancelled every earlier circular.
The crypto circular also invokes the central-bank law as its authority. Its continuing effect cannot be assessed only from its reference to the older banking statute.
No express withdrawal of Circular No. 9/2022 or replacement crypto-permission instrument was independently established in the public materials reviewed. Readers should not treat the new banking law as an automatic permission to trade crypto.
What can we accurately say about penalties?
The circular’s 2004 reference should not be presented as the complete current penalty position.
The 2026 law’s penalty chapter contains several offence provisions.
Section 116(4) provides for imprisonment of up to five years, a fine, or both where a contravention of the Act or the listed subordinate instruments constitutes a criminal offence.
Those instruments include regulations, orders, decisions, circulars, controls and directives issued under the law.
The condition matters. This provision should not be turned into a claim that every crypto-related act attracts the same sentence.
A penalty assessment needs the conduct, offence, relevant date, applicable instrument and any court interpretation. This review did not establish a crypto-specific judgment resolving those questions.
Is a mobile-payment licence a crypto licence?
The bank’s financial-technology company page lists mobile-payment and financial-switch permissions.
Those licence categories do not themselves establish permission for cryptocurrency exchange or custody. A listing also needs a current status check before anyone relies on a particular company’s authorisation.
Ask for the legal entity, licence number and exact approved activity. Check whether a later decision changes the permission.
An app being downloadable is not proof of local authorisation.
Does overseas access overcome the restriction?
A foreign platform accepting a Sudanese account does not establish local permission.
An overseas licence has territorial and service limits. Identity checks and AML controls answer different questions from legal authority to provide a service.
A business must assess the whole transaction. That includes fiat collection, conversion, custody and payout.
What should a business verify?
Map the proposed service before relying on an approval claim.
| Issue | Evidence required |
|---|---|
| Local dealing restriction | Operative instrument and later amendments |
| Claimed exemption | Written legal basis and relevant decision |
| Fiat collection or payout | Payment provider’s authorised role |
| Foreign registration | Exact entity, service and territorial scope |
| Penalty exposure | Current offence, legislation and transaction date |
These are legal-review questions. They are not a verified VASP application checklist.
Written advice should address the actual funds flow. General statements about blockchain or financial inclusion do not resolve a legal restriction.
What about licensing, capital and tax?
A current VASP licensing route, named local crypto approval and universal VASP capital minimum were not independently established.
An unverified route should not be advertised as an open application process. A missing capital figure does not imply a zero requirement. Bank capital rules cannot simply be substituted.
Tax consequences and sanctions screening require separate analysis. Paying tax does not itself authorise a restricted service.
Read Egypt’s cryptocurrency restrictions and approval rules, Ethiopia’s crypto restrictions and Eritrea’s VASP evidence gaps.
Sources and review limits
Reviewed 6 November 2026. The Arabic virtual-asset circular was checked alongside selected commencement, repeal, savings, penalty and final provisions of the 2026 banking law.
The bank’s later-circulars index and fintech licence categories were also checked. This was not a review of every provision in every chapter or every court decision.
No current provider onboarding, trade or withdrawal test was performed. This article does not certify a platform’s availability, approval or compliance.
