Financial Crime World

Sudan’s Progress in Anti-Money Laundering and Countering Financing of Terrorism: A MENAFATF Update

In April 2016, the Middle East and North Africa Financial Action Task Force (MENAFATF) published its 3rd Follow-Up Report on Sudan’s progress against previously identified major deficiencies in Anti-Money Laundering (AML) and Countering Financing of Terrorism (CFT) efforts.

Improvements Made by Sudan

  1. Customer Due Diligence (R5) Sudan has mandatory obligations for financial institutions (FIs) to comply with Customer Due Diligence measures. These measures include verifying customer identity, understanding ownership and control structures, risk assessments, and evaluating transactions.

  2. Suspicious Transaction Reporting (R13, SR V) Sudanese FIs now have an obligation to report suspicious transactions related to money laundering or terrorist financing, regardless of their value, with no delay.

  3. Criminalizing Terrorist Financing (R10, SR II) With the criminalization of terrorist financing under its new law, Sudan has addressed deficiencies in this recommendation, covering acts, intentions, and associations.

  4. Supervision, Regulation, and Monitoring (R23) Sudan has made progress in establishing a regulatory and legal basis for monitoring the financial sector, ensuring compliance with AML/CFT requirements, and granting monitoring entities authority to apply “fit and proper” criteria on managers and senior management within FIs.

  5. Financial Intelligence Unit (R26) The establishment of a Financial Intelligence Unit (FIU) has been a significant advancement for Sudan’s AML/CFT system. The FIU now operates independently with modern technology systems and an appropriate budget.

Key Advancements

These improvements made by Sudan contribute to its efforts towards addressing major deficiencies related to previously identified NC (Non-Compliant) and PC (Partially Compliant) recommendations. The Plenary Meeting is currently considering whether Sudan’s AML/CFT system has reached the level of essential equivalency to a ‘Compliant’ or ‘Largely Compliant’ country, meriting a transition from regular follow-up to biennial updates.

Important Considerations

However, it is essential to note that this analysis does not prejudge the results of future assessments. This report focuses only on the recommendations that were rated NC or PC and provides a desk-based analysis. The technical compliance of Sudan’s AML/CFT system with FATF standards was verified through a less detailed and comprehensive review. The conclusions drawn should not be considered as a definitive statement of their current state.