Sudan
Overview
Sudan’s current AML/CFT statutory layer is anchored in the Anti-Money Laundering and Combating the Financing of Terrorism Law of 2014. Central Bank Circular No. 8/2026, effective from 30 April 2026, replaces Circular No. 8/2014 and related earlier circulars for institutions under CBOS supervision and sets the current AML/CFT/CPF supervisory control baseline.
Central Bank Circular No. 8/2026 expressly covers risk-based CDD, beneficial-owner identification, enhanced due diligence, wire transfers, recordkeeping, internal controls and targeted financial sanctions for CBOS-supervised institutions.
FIU Sudan receives, analyses and disseminates STRs. Circular No. 8/2026 requires CBOS-supervised institutions to notify the FIU immediately when a transaction or attempted transaction is suspected or reasonably suspected to involve criminal proceeds, money laundering or terrorist financing, and preserves five-year recordkeeping baselines for CDD, transactions and FIU reports.
Compliance Calendar3
Requirement
Banking / Credit Institutions
Bank customer-data update exercise
Authority / Report toCentral Bank of Sudan supervisory framework; completion occurs through the customer’s bank under the required procedures
Deadline / triggerBy 31 December 2026 (CBOS extended the update period through the end of 2026).
Requirement
- Sector scope
- Banking / Credit Institutions
- Subject scope
- Banks and their customers within the CBOS customer-data update exercise announced as having begun under directions issued from February 2026.
- Trigger
- Complete outstanding customer-data updates and account classification required by CBOS supervisory and AML/CFT requirements.
- Filing channel
- Provide/validate approved customer documentation and complete the bank’s customer-data and account-classification update process.
Impact
- Consequences of non-compliance
- The CBOS notice stresses completion within the specified period; no standalone monetary penalty is asserted from the notice itself.
- Enforcement authority
- Central Bank of Sudan
- Operational impact
- Banks should track outstanding KYC/customer-data remediation to completion by year-end 2026 and preserve evidence of the updated customer profile/account classification.
Requirement
Banking / Credit Institutions
Supervised-institution suspicious transaction report
Authority / Report toSudan Financial Intelligence Unit
Deadline / triggerImmediately.
Requirement
- Sector scope
- Banking / Credit Institutions
- Subject scope
- Institutions under the supervision of the Central Bank of Sudan within Circular No. 8/2026.
- Trigger
- The institution suspects or has reasonable grounds to suspect funds constitute proceeds or that transactions/attempted transactions are linked to money laundering or terrorist financing.
- Filing channel
- Compliance officer files using the reporting template designed by the FIU.
Impact
- Consequences of non-compliance
- Failure to report may lead to supervisory and statutory enforcement.
- Enforcement authority
- Central Bank of Sudan / Sudan FIU
- Operational impact
- Configure immediate internal escalation and FIU reporting for suspicious transactions or attempted transactions under Circular No. 8/2026.
Requirement
Banking / Credit Institutions
Supervised-institution AML/CFT record retention
Authority / Report toCentral Bank of Sudan / Sudan FIU on lawful request
Deadline / triggerAt least 5 years for covered transaction records; STR-related records for at least 5 years after notifying the FIU; risk-assessment and AML/CFT training records also have five-year baselines in the circular.
Requirement
- Sector scope
- Banking / Credit Institutions
- Subject scope
- Institutions under the supervision of the Central Bank of Sudan within Circular No. 8/2026.
- Trigger
- Transactions/attempted transactions, STR submission, risk assessment or training activity, depending on record type.
- Filing channel
- Retained internally in sufficient detail for transaction reconstruction and supervisory/FIU access.
Impact
- Consequences of non-compliance
- Recordkeeping deficiencies may trigger supervisory and statutory enforcement.
- Enforcement authority
- Central Bank of Sudan / Sudan FIU
- Operational impact
- Apply the Circular No. 8/2026 five-year recordkeeping baselines to CDD records, transactions/attempts, FIU reports, unusual-transaction files, risk assessments and AML/CFT/CPF training records.
Authorities & FIU1
FATF Assessment
Measures how fully the jurisdiction has implemented FATF’s technical requirements. It does not measure practical effectiveness.
Measures whether the AML/CFT system achieves its intended results in practice. No jurisdiction-specific effectiveness ratings are asserted where the consolidated dataset has no standalone assessment row.
Regulatory Timeline37
On 16 August 2026, the Central Bank of Sudan clarified that banks had been directed since February 2026 to update customer data and classify accounts in line with supervisory and AML/CFT requirements, and extended the update period through the end of 2026.
The Central Bank of Sudan issued Circular No. 8/2026 on 30 April 2026 for all institutions under its supervision. The circular cancels Circular No. 8/2014, Circular No. 2/2026 and specified earlier circulars, and replaces them with updated AML/CFT/CPF regulatory and supervisory requirements.
FATF revised Recommendation 16 to standardise payment information and strengthen fraud/error controls in cross-border payments.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendation 1 and related interpretive material to strengthen proportionality and simplified measures under the risk-based approach.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF revised Recommendations 4, 30, 31 and 38 and related interpretive material to make asset recovery a stronger operational priority, expand tools to trace and confiscate criminal property and improve domestic and international cooperation.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗At its February 2023 Plenary FATF revised Recommendation 25 and its Interpretive Note to strengthen transparency and beneficial-ownership requirements for trusts and similar legal arrangements, complementing the 2022 strengthening of Recommendation 24 for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF strengthened Recommendation 24 on beneficial ownership transparency for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendations 1 and 2 and their Interpretive Notes so countries and covered private-sector entities must identify, assess and mitigate risks of breaches, non-implementation or evasion of proliferation-related targeted financial sanctions.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee revised its ML/TF risk-management guidelines to add principles for information exchange and cooperation between prudential and AML/CFT supervisors in authorisation, ongoing supervision and enforcement.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted detailed implementation requirements for virtual assets and VASPs in June 2019, including the application of wire-transfer information requirements commonly described as the Travel Rule. This operationalised the virtual-asset perimeter introduced through the 2018 Recommendation 15 revision.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗In October 2018 FATF revised Recommendation 15 and added the definitions of virtual asset and virtual asset service provider, formally bringing virtual-asset activity into the global AML/CFT standards architecture. Detailed implementation requirements followed in 2019.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Official CBOS institutional history records FIU Sudan’s admission to the Egmont Group in June 2017.
FATF removed Sudan from its on-going global AML/CFT compliance monitoring process.
The Basel Committee issued Sound management of risks related to money laundering and financing of terrorism, superseding its 2001 CDD and 2004 consolidated KYC papers and integrating ML/TF risk management with prudential supervisory expectations.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗The 2014 AML/CFT Act established the FIU as an independent unit with legal personality and anchors the current statutory framework.
FATF adopted a consolidated revised set of 40 Recommendations integrating AML, CFT and proliferation-financing safeguards.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF identified Sudan in its on-going global AML/CFT compliance process.
CBOS records that the Financial Information Unit was established on 10 January 2010 under Central Bank supervision to receive, analyse and disseminate STRs.
Resolution 1737 imposed binding measures concerning Iran’s proliferation-sensitive nuclear activities, including an asset freeze on designated individuals and entities. Together with the DPRK regime, it forms a foundational UN counter-proliferation targeted-financial-sanctions architecture.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗Following the DPRK nuclear test, Resolution 1718 imposed binding sanctions including an asset freeze on designated persons and entities connected to the nuclear programme. It became a central UN targeted-financial-sanctions pillar for counter-proliferation financing.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗MENAFATF admitted Sudan during its Third Plenary in March 2006.
FATF added a ninth Special Recommendation addressing cash couriers and cross-border movement of currency.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1540 requires all States to adopt and enforce laws and domestic controls to prevent non-State actors from acquiring or using weapons of mass destruction and related materials. It forms a binding global legal pillar of the proliferation-financing control environment later reflected in FATF CPF standards.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The UN General Assembly adopted the United Nations Convention against Corruption on 31 October 2003. UNCAC addresses prevention of money laundering, laundering of corruption proceeds, confiscation and a dedicated asset-recovery framework; the Convention entered into force globally on 14 December 2005.
Current UN depositary relationship to 2003 UN Convention against Corruption. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗FATF comprehensively revised its AML/CFT Recommendations, strengthening preventive measures and extending coverage.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee issued Customer due diligence for banks, setting minimum supervisory expectations for customer acceptance, identification, ongoing monitoring and risk management. It became an influential global banking KYC/CDD benchmark and was later reflected in FATF standards.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF expanded its standards to terrorist financing through eight Special Recommendations.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1373 requires all States to prevent and suppress terrorist financing, criminalise the provision or collection of funds for terrorist acts, freeze terrorist assets without delay and prohibit making funds or financial services available to terrorists and related entities.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The Palermo Convention was adopted on 15 November 2000 and broadened the international money-laundering framework beyond drug proceeds through criminalisation and preventive measures tied to transnational organised crime. It entered into force globally on 29 September 2003.
Current UN depositary relationship to 2000 Palermo Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗The UN General Assembly adopted the International Convention for the Suppression of the Financing of Terrorism on 9 December 1999, creating the treaty framework for criminalising terrorist financing and international cooperation. It entered into force globally on 10 April 2002.
Current UN depositary relationship to 1999 Terrorist Financing Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗Resolution 1267 imposed an assets freeze and other targeted sanctions in the Taliban context and created the Security Council committee that became the foundation of the UN 1267 sanctions architecture. It is a key global precursor to modern terrorist-financing targeted financial sanctions.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗FATF revised the Forty Recommendations to reflect evolving money-laundering methods and countermeasures.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Representatives of 13 financial intelligence units met in Brussels on 9 June 1995 and founded what became the Egmont Group. The milestone created the operational global network for FIU-to-FIU cooperation and exchange of financial intelligence.
Current profile relationship to the Egmont network. This does not imply membership in 1995; admission history is a separate LOCAL/STATUS fact.
Egmont Group · Member FIUs ↗FATF issued its original Forty Recommendations, establishing the first global AML standard framework.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The G7 established FATF in 1989 to examine and develop measures to combat money laundering. FATF became the central global standard-setting body whose recommendations are implemented through national and regional AML/CFT frameworks.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Vienna Convention was adopted on 20 December 1988 and created the first treaty-level international obligation to criminalise laundering conduct linked to drug-trafficking proceeds, alongside confiscation and international-cooperation measures. It entered into force globally on 11 November 1990.
Current UN depositary relationship to 1988 Vienna Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗The Basel Committee published a Statement of Principles for banks aimed at reducing the risk that banking institutions would be used by criminals or as channels for money laundering. This helped establish the preventive and supervisory side of AML alongside the emerging criminal-law framework.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗