Sudan — Country Risk Report

Sudan (Africa • North Africa). Risk report as of the 19 Jun 2026 FATF plenary.

Very high country risk, with governance and institutional weakness. Sudan's country risk score is 7.6/10, placing it in the very high-risk band. Some information is unavailable, so the available parts are rebalanced and the country will not be labelled Low risk while information is missing. The principal score driver is governance and institutions, contributing 7.6 of 7.6 points. Separately, the treatment overlays show that Sudan is not currently FATF grey- or black-listed, and that Sudan has a sectoral sanctions programme. Firms should apply additional scrutiny where exposure involves state-linked entities, restricted sectors, sensitive technology, dual-use goods or politically exposed counterparties.

Recommended treatment

Enhanced due diligence on every relationship, with senior approval and enhanced ongoing monitoring.

At a glance

• FATF status: Not currently listed (one indicator only; it does not set the overall country risk rating by itself)
• Sectoral country-level sanctions programme identified; this is a legal treatment overlay and does not change the numeric country-risk score.
• Governance and institutions: 7.6/10
• Corruption (CPI 2025): 14/100, rank #175 of 182
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 7.6/10 (Very high)

Higher score means higher country risk (global average 5.5). Some information unavailable. Indicative governance proxy. Limited supporting evidence. Enforcement activity and CPI are context only; FATF listing and sanctions are regulatory overlays except the labelled FATF listing status used where no mutual evaluation exists.

Some underlying pillars are unavailable. Available weights are rebalanced; missing evidence is not treated as low risk. Only World Bank governance evidence is available. This remains visible for discovery but is excluded from exact global ranking.

How this score was calculated

• AML/CFT effectiveness: information unavailable — 0% of this score
• Technical compliance: information unavailable — 0% of this score
• Governance and institutions: 7.6/10 — 100% of this score
• FATF effectiveness ratings are incomplete
• FATF technical safeguard ratings are incomplete
• Only one line of evidence is available, so the score is indicative rather than a composite

Sanctions treatment: Screen transactions and counterparties. FATF treatment: none.

Principal risk drivers

• Governance and institutions: 7.6/10 × 100% = 7.6 points

Mitigating factors

• Not currently on the FATF grey or black list.
• No comprehensive country-wide sanctions programme.
• Risk is concentrated in specific counterparties, sectors and transactions rather than applying uniformly.

Business impact

• Customer onboarding (Enhanced): Verify ultimate beneficial ownership and control from more than one source.
• Payments and transactions (Enhanced): Review transaction purpose, counterparties and the full payment routing.
• Trade and export activity (Enhanced): Screen goods, end users and potential dual-use exposure.
• Corporate clients (Enhanced): Assess state ownership, government links and political exposure.
• Ongoing monitoring (Enhanced): Alert on ownership changes, new designations and status changes.

Recommended controls

• Verify ultimate beneficial ownership using more than one reliable source.
• Identify state ownership, government influence and politically exposed persons.
• Screen entities, directors and beneficial owners against applicable sanctions lists.
• Apply enhanced review to technology, defence, telecommunications, financial services and dual-use activity.
• Document transaction purpose and source of funds where cross-border structures are complex.
• Escalate unresolved ownership opacity or adverse information to Compliance.

Enhanced due diligence triggers

• State ownership / control
• PEP involvement
• Sensitive / restricted sectors
• Opaque ownership
• Adverse media
• Dual-use goods & technology
• High-risk intermediary routing

FATF status: Not currently listed

Sudan is not on the FATF grey or black list as of the 19 Jun 2026 plenary.

Sanctions: Sectoral

• EU — targeted: Restrictive measures in view of activities undermining the stability and the political transition of Sudan (source)
• EU — sectoral: Restrictive measures in view of the situation in Sudan (source)
• OFAC — targeted: Sudan and Darfur Sanctions (source)
• UK — sectoral: Sudan sanctions (source)
• UN — sectoral: 1591 Sudan sanctions (source)

Source details

International sanctions by issuing body

• UN: Yes (Sectoral)
• EU: Yes (Sectoral)
• UK: Yes (Sectoral)
• US: Yes (Targeted)

No means the complete UN, UK, EU and US review found no direct country-level programme. People or organisations may still appear on sanctions lists.

Government effectiveness and rule of law (World Bank 2024, percentile)

• Government Effectiveness: 16/100
• Regulatory Quality: 29/100
• Rule of Law: 26/100

Regulators and legal framework

FATF network

FATF network via MENAFATF.

• Middle East and North Africa Financial Action Task Force

National regulators

Regulator profiles not yet available on RegActions.

FIU: Egmont Group member (FIUSU)

Framework signals

• FATF listing: Not currently listed
• International sanctions: sectoral country programme (legal treatment overlay)
• Corruption (CPI 2025): 14/100, rank #175 of 182
• Rule of law (WGI): 7.6/10 risk

Regulatory ecosystem and enforcement visibility

This evidence map is separate from Country Risk v3. It describes official mandates, publication access and RegActions coverage; it does not judge regulatory strength or add points to country risk.

Transparency Index: not scored · Evidence disposition: local-authority-evidence · Mapped official authorities: 2.

Evidence level: Level 1: Identity confirmed. The ladder uses the authority evidenceLevel schema directly and does not infer a level from a URL, site access or RegActions feed count.

1. 1. Identity confirmed — The authority and its mandate are evidenced by official directory provenance.
2. 2. Regulatory activity visible — A qualified authority-owned route has provisional dated activity in the first-page scan.
3. 3. Enforcement visible — A qualified authority-owned enforcement route has provisional dated activity in the first-page scan.
4. 4. Score eligible — Shown only when the authority evidence schema explicitly records score-eligible; no authority currently does.

Enforcement visibility: No authority is classified enforcement-visible or score-eligible in the authority evidence schema. Enforcement visibility remains unknown or limited to identity/activity evidence; this is not evidence of no enforcement.

Authorities and mandate evidence

• Bank of Sudan — Level 1: Identity confirmed · Official site reachable

  Mandates: Central bank, Prudential supervision · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

  No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

• Financial Information Unit (FIUSU) — Level 1: Identity confirmed · Official site reachable

  Mandates: Financial intelligence · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

  No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

Download regulatory ecosystem PDF · CSV · JSON

Sector exposure

• Banking & payments (Elevated): Governance pillar risk is 7.6/10
• Trade & export controls (High): Sectoral sanctions overlay restricts named trade sectors
• Crypto & virtual assets (Review): Effectiveness pillar unavailable; no low-exposure conclusion
• Real estate & luxury assets (High): BO subscore 9.0/10; CPI context 14/100
• State-linked & procurement (High): Governance pillar risk is 7.6/10

Derived from sanctions tier, FATF listing, World Bank WGI governance and CPI; no per-sector dataset is asserted.

Sudan: analysis

Sudan's profile is driven by severe weaknesses across all four governance domains. Corruption (weighted 35%) and rule of law (weighted 40%) are the principal contributors. Political stability (weighted 15%) and voice and accountability (weighted 10%) are also acutely elevated, reflecting a deeply fragile institutional environment. Sudan is not on the FATF grey or black list and carries no sanctions. Sudan sits in the lowest quartile of the World Bank governance indicators. The CPI reading confirms the severity of the corruption risk.

Outlook

Sudan's very high risk profile reflects deep structural fragility, including conflict dynamics and severely degraded institutional capacity. Meaningful risk reduction would require sustained and verifiable progress in governance, rule of law, and AML/CFT supervisory capacity over an extended period. Firms should apply stringent enhanced due diligence to any Sudan-linked exposures and should monitor FATF listing decisions closely, as the governance profile would support future scrutiny.

Key watchpoints

• Watch for any FATF listing decision, as the governance profile is consistent with grey-list risk.
• Monitor political stability and conflict developments that could further degrade institutional capacity.
• Apply enhanced due diligence to all transactions and counterparties with a Sudan nexus.
• Track CPI and WGI trends for any signals of governance deterioration or improvement.

Assessment currency

• FATF status: Not listed (as of 19 Jun 2026)
• Sanctions exposure: Sectoral programme in place (as of Jul 2026)
• Governance (WGI): Latest dataset incorporated (as of 2024)
• Corruption (CPI): 14/100 (as of 2025)
• RegActions assessment: Reviewed (as of 19 Jun 2026)

Public evidence layer

FATF action: none. No FATF call-for-action or increased-monitoring status was identified at the latest plenary. This does not establish low risk.

Contextual signals (not scored)

• FATF network membership: FATF regional network: MENAFATF (present, as of 2026-07)
• EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, as of 2026-02-17)
• Egmont Group FIU: FIUSU (present, as of 2026-07-17)
• Beneficial-ownership register: No live register identified in the source (unavailable, as of 2026-08-23)
• Transparency International CPI: 14/100, rank 175 (present, as of 2025)

Evidence freshness

• FATF monitored-jurisdiction status: current; data 2026-06-19
• FATF mutual evaluation and follow-up ratings: current; data 2026-08-24
• World Bank governance indicators: current; data 2024
• UN, UK, EU and US sanctions regimes: current; data 2026-08-30

Contextual signals are public evidence only and do not change the current country-risk score.

Download evidence PDF · CSV · JSON

Contextual risk evidence (not scored)

These eight evidence families provide context only. They do not change the v3.1 headline score. Unavailable means no reviewed, country-comparable evidence is currently ingested; it does not mean the risk is absent.

• Organised crime: Not available. No reviewed country-level organised-crime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Fraud and cybercrime: Not available. No reviewed country-level fraud or cybercrime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Terrorism and proliferation financing: Not available. No reviewed country-comparable terrorism/proliferation threat dataset is currently checked in; FATF listing status remains a separate overlay. Candidate sources are research leads only; they have not been ingested as evidence.
• Trafficking: Not available. No reviewed country-level trafficking dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Financial secrecy and offshore exposure: Not available. No reviewed, licence-clean financial-secrecy index is currently checked in; jurisdiction type alone is not used as a proxy. Candidate sources are research leads only; they have not been ingested as evidence.
• Tax cooperation: Not listed in EU Annex I. Annex I is a political/legal tax-cooperation list, not a general AML, corruption, or country-risk score. Source
• Political stability and conflict: 31/100 WGI percentile. WGI is an institutional perception indicator, not a conflict event feed or a prediction of future violence. Source
• Beneficial ownership: Not available. The Open Ownership map is a live-register snapshot and absence means no register was identified in that snapshot, not that no register exists. Candidate sources are research leads only; they have not been ingested as evidence.

Regional peer scores

• Eritrea: 8.7/10 (Very high)
• Central African Republic: 8.2/10 (Very high)
• Chad: 8.0/10 (Very high)
• Democratic Republic of the Congo: 7.9/10 (Very high)
• Equatorial Guinea: 7.9/10 (Very high)
• Somalia: 7.9/10 (Very high)

Source: FATF black & grey lists · World Bank WGI (CC BY 4.0 — World Bank WGI) · TI CPI (CC BY-ND 4.0 — Transparency International, display only)