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Sudan Country Summary

Sanctions

UN, EU and US sanctions in place

FATF AML Deficient List

No

Terrorism
Corruption
US State ML Assessment
Criminal Markets (GI Index)
EU Tax Blacklist
Offshore Finance Center

Please note that although the below Summary will give a general outline of the AML risks associated with the jurisdiction, if you are a Regulated entity then you may need to demonstrate that your Jurisdictional AML risk assessment has included a full assessment of the risk elements that have been identified as underpinning overall Country AML risk. To satisfy these requirements, we would recommend that you use our Subscription area.

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Anti Money Laundering

FATF status

Sudan is no longer on the FATF List of Countries that have been identified as having strategic AML deficiencies

Latest FATF Statement - 23 October 2015

The FATF welcomes Sudan’s significant progress in improving its AML/CFT regime and notes that Sudan has established the legal and regulatory framework to meet its commitments in its action plan regarding the strategic deficiencies that the FATF had identified in February 2010. Sudan is therefore no longer subject to the FATF’s monitoring process under its on-going global AML/CFT compliance process. Sudan will work with MENAFATF as it continues to address the full range of AML/CFT issues identified in its mutual evaluation report.

Compliance with FATF Recommendations

It should be noted that the new style FATF Mutual Evaluation has not yet been undertaken.

The last Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in Sudan was undertaken by the Financial Action Task Force (FATF) in 2013. According to that Evaluation, Sudan was deemed Compliant for 0 and Largely Compliant for 4 of the FATF 40 + 9 Recommendations. It was Partially Compliant or Non-Compliant for 5 of the 6 Core Recommendations.

Sanctions

Sudan, as a UN member, is obligated to adhere to sanctions aimed at maintaining international peace and security. The UN Security Council has established various sanctions regimes since 1966, which include arms embargoes, travel bans, and asset freezes, with a focus on protecting the rights of those targeted and ensuring fair procedures for sanctions implementation.

In addition to UN sanctions, the Arab League has imposed measures against Syria and has a systematic boycott of Israel. Sudan faces an arms embargo and restrictions on military assistance from the UN and EU, while the US has lifted some sanctions but maintains others related to the conflict in Darfur.

Bribery & Corruption

Rating 0 (bad) - 100 (good)
Transparency International Corruption Index 20
World Bank: Control of Corruption Percentile Rank 7

Corruption is pervasive in Sudan, with the Bashir regime's weak enforcement of anti-corruption laws allowing officials to often escape punishment for corrupt acts. Although a special anticorruption attorney was tasked with investigating cases, actual penalties for embezzlement were rarely enforced, and media reporting on corruption faced significant restrictions. Following the 2019 Constitutional Declaration, which aimed to establish anti-corruption measures, the situation worsened after the October 2021 military takeover, leading to the dissolution of the anti-corruption commission and a continued lack of transparency and accountability in government practices.

Economy

Sudan's economy has faced significant challenges following the military takeover in October 2021, which disrupted the reforms initiated by the Civilian-Led Transitional Government (CLTG). The country has experienced economic uncertainty, a depreciating national currency, and shortages of essential goods, exacerbated by the suspension of international financial assistance. Key sectors of interest for foreign investment include mineral extraction and agriculture, but obstacles such as poor infrastructure, corruption, and a lack of domestic investment capital hinder economic growth.

Sudan's investment climate is characterized by a strong encouragement of foreign direct investment (FDI), with the government offering various incentives such as tax exemptions and land grants through the Ministry of Investment and International Cooperation. However, challenges persist due to a lack of domestic investment capital, poor infrastructure, and bureaucratic hurdles, compounded by the political instability following the military takeover in October 2021, which has led to economic uncertainty and a depreciating currency.

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