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Gold

Sudan

Checked 2026-09-29 · Version r2 · Replaces version r1 · Reviewed

Public law and official guidance, published as research. Not legal, tax or financial advice.

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Small-scale mining origin

Wartime artisanal gold origin (83% of 64 t declared in 2024). The rules are in the Mineral Wealth and Mining Development Act 2015, the Traditional Gold Mining Regulation 2016 (royalty 10% of product) and CBOS circulars issued under the Currency Dealing Regulation Act 1981. Free (artisanal) gold may be exported by any Sudanese legal person (Circular 17/2025 of 5 Nov 2025): international prices, advance payment or confirmed sight L/C, proceeds within 30 days of shipment held up to 21 working days, minimum contract 1 kg (Circular 11/2026), price not below the CBOS daily price of international 24k less USD 10/oz (Circular 13/2026). Concession and small-mining companies export 70% of output after in-kind government shares and sell 30% to CBOS (Circular 2/2025). CBOS was sole buyer and exporter of free and tailings gold from 14 Sep to 5 Nov 2025 (Circular 14/2025) and bought 100% of tailings gold from 13 May to 21 Sep 2026 (Circular 11/2026, cancelled by 18/2026). Since 15 Jul 2026 the EU bans buying Sudan-origin gold anywhere; the UK sanctioned three state-owned miners on 16 Jul 2026. Roughly half or more of production is smuggled.

How sure this page is

  • Primary law 37
  • Official guidance 59
  • Secondary 23
  • Unverified 1
  • No confidence level recorded 10
  • Researcher's note 62
  • Read in full 39
  • Blocked 1
  • Not recorded 20
  • Text 17
  • OCR 22
  • Not stated 21

Regulators

  • Central Bank of Sudan (Bank of Sudan, CBOS)

    Foreign-exchange regulator under the Currency Dealing Regulation Act 1981 and art.20 of the Regulation 2013; sets gold purchase and export rules by Policies Department circulars (2/2025, 17/2025, 11/2026, 12/2026, 13/2026, 18/2026); publishes the daily gold export price (XAR system); buys the 30% share of concession and small-mining gold and gold for reserves (17/2025 خامساً-5); was sole buyer and exporter of free and tailings gold 14 Sep - 5 Nov 2025 and bought all tailings gold 13 May - 21 Sep 2026.

    No confidence level recordedOCR
  • Sudan Customs Authority

    Export clearance at Port Sudan airport and seaport and land borders; releases gold returned after manufacture only against the IM form and monitors the limit on worked gold carried by travellers under the Customs Disclosure Regulation (Circulars 14/2025, 17/2025); receives border declarations of currency (AML/CFT Act 2014 s.31).

    No confidence level recordedOCR
  • Financial Information Unit

    Receives suspicious transaction reports from financial and non-financial institutions, including dealers in metals and precious stones above the Minister's cash threshold (AML/CFT Act 2014 ss.3, 6), and copies of customs declarations (s.31(3)).

    No confidence level recorded
  • Ministry of Finance and Economic Planning

    Approves changes to fees and rents (MMDA s.20(2)-(3)); receives the cash value of government shares collected by the competent authority (s.27أ); sets the distribution of mining revenues between federal, state and locality (Decision 90/2021); approves the state/national royalty split (Traditional Gold Mining Regulation art.8).

    No confidence level recordedOCR
  • Ministry of Industry and Trade

    Exporters' register and export e-contract (Baladna platform, Circular 1/2026 for goods other than gold); may set the minimum gold export contract (17/2025 خامساً-2) and the limit for gold sent for manufacture; approves gold sent abroad for manufacture and return (17/2025 رابعاً-1); receives the CBOS daily gold price; import and export approvals for worked and refined gold (Currency Dealing Regulation 2013 arts.7-8, "Ministry of Trade").

    No confidence level recordedOCR
  • Ministry of Minerals

    Minister issues search and exploration licences on the Technical Committee's recommendation (MMDA s.13(1)); licences and mining contracts are signed by the Director of the Geological Research Authority with the Minister's approval (s.14(2)); traditional gold mining contracts issued by the Ministry on SMRC recommendation (Traditional Gold Mining Regulation art.4); sets royalty rates by mineral and location (Exploitation Regulation art.15); Ministry export-approval certificate for concession and small-mining gold (Circular 2/2025) and ore export certificates (Exploitation Regulation art.34).

    No confidence level recordedOCR
  • Supreme Committee for Economic Emergencies (chaired by the Prime Minister)

    Wartime committee; its recommendations were approved by Transitional Council of Ministers Decision No. 132 of 2025 (2 Sep 2025, not held), which Circular 14/2025 implemented (single buyer and exporter).

    No confidence level recordedNot recordedOCR
  • Sudan Gold Refinery Company

    State-owned refinery (Khartoum, completed 2012); executes CBOS gold purchases (Circular 2/2025 رابعاً; 14/2025 ثانياً-4); exporters must comply with its controls (17/2025 خامساً-1). Looted by the RSF in May 2023.

    No confidence level recordedNot recordedOCR
  • Sudanese Mineral Resources Company (SMRC)

    State-owned company holding all delegable powers of the "competent authority" under MMDA 2015 (MoM Decision 45/2024): supervision and inspection, in-kind and cash collection of royalties, rents and profit shares, sale of the state's in-kind gold; determines, collects and distributes mining revenues and manages government gold including zakat gold (MoF Decision 90/2021); recommends traditional mining contracts and keeps the miners' register (Traditional Gold Mining Regulation arts.4, 6); weighs concession gold bought by CBOS and certifies in-kind deductions (Circular 2/2025); runs Minerals Gate. Head office moved to Port Sudan during the war.

    No confidence level recordedNot recordedOCR
  • Sudanese Standards and Metrology Organisation (SSMO)

    Its Hallmarking and Precious Metals Control Department hallmarks precious metals before export and approves imports (Precious Metals and Gemstones Act 2008 ss.3, 20), keeps the register of assayers and goldsmiths (s.23); issues the certificate required for concession gold exports (Circular 2/2025) and weight and assay documents for free gold (17/2025 ثالثاً-6); sets fineness for CBOS purchases (2/2025 رابعاً-1).

    No confidence level recordedOCR

Laws

  • Regulation on Gold and Associated Minerals Assaying Work 2016

    Licensing of gold assay laboratories on the recommendation of a joint committee (SSMO involved); applicant must be Sudanese with capital of at least SDG 500,000; provisional approval 6 months, final licence 1 year; assay certificate within +/-1% with prescribed contents (art.6(4)).

    Citation
    Approved by the National Assembly in sitting No. 29 of its third session, 22 Ramadan 1437 / 27 June 2016, with amendments in its Decision No. 15
    Kind
    Regulation
    In force from
    2016-06-27
    Primary lawOCR

    Researcher's note: [transcription]

  • CBOS gold marketing policy of 1 January 2020 (70/30 rule for concession companies; 85/15 for artisanal)

    Concession companies may export up to 70% of output and must sell 30% to CBOS; artisanal output 85% to CBOS / 15% export (Sudan Events).

    Kind
    Circular
    In force from
    2020-01-01
    SecondaryNot recorded

    Researcher's note: Instrument not seen. The 70/30 rule is now set by Circular 2/2025 (sd.law-cbos-circ-02-2025), which repeals Circular 2022/24 and the 2023-2024 gold circulars; whether the 2020 policy was itself replaced by 2022/24 is [inferred].

  • CBOS Circular 14/2025: CBOS sole buyer and sole exporter of free and tailings gold

    Purchase of free (artisanal) and tailings gold inside Sudan reserved to CBOS or its delegate; export reserved to CBOS alone, banned for any natural or legal person; purchases at international prices and the prevailing market price, executed by Sudan Gold Refinery per 2/2025. Manufacture-and-return exports kept, against MoIT approval, SSMO certificate, a bank cheque or guarantee for the gold's value and return within one month. Exception for advance-payment exports whose proceeds arrived on or before the Cabinet decision.

    Citation
    Policies Department Circular (2025/14) of 14 Sep 2025, implementing Transitional Council of Ministers Decision No. 132 of 2025 (2 Sep 2025, not held); repeals 2025/3; repealed by 2025/17
    Kind
    Circular
    In force from
    2025-09-14
    Repealed on
    2025-11-05
    Official guidanceNot recordedOCR

    Researcher's note: [conflict] Press dated it 16 Sep 2025 and reported 100% advance payment and a 21-day deposit for concession exports; the circular is dated 14 Sep 2025 and leaves concession and small-mining gold to Circular 2/2025 (رابعاً-4).

  • CBOS Circular 1/2026: commodity export procedures and controls

    General export rules (electronic export contract from MoIT on the Baladna platform, EX form on IMEX, repatriation periods by payment method). Gold is carved out: "gold is dealt with under its own controls" (ثالثاً-14). Circular 14/2026 (10 Jun 2026) makes bank executive management personally liable for following up export proceeds under its item ثانياً-5.

    Citation
    Policies Department Circular (2026/01) of 6 Jan 2026; repeals 2025/01
    Kind
    Circular
    In force from
    2026-01-06
    Official guidanceOCR
  • CBOS Circular 2/2025: purchase and export of gold of concession and small-mining companies

    Banks may not complete gold export procedures for concession or small-mining companies without CBOS written approval, an SSMO certificate and a Ministry of Minerals export-approval certificate (ثانياً). Concession companies export 70% of output remaining after in-kind deduction of zakat, royalties and profit shares, keeping proceeds inside or outside Sudan as their agreements allow; the other 30% is sold to CBOS or its delegate (ثالثاً-1). Small-mining companies: same 70/30 split, international prices, advance payment transferred from abroad or confirmed sight L/C without overseas-assay conditions, proceeds within 30 days of shipment, gold export account up to 21 working days (ثالثاً-2). CBOS purchases are executed by Sudan Gold Refinery: fineness by SSMO, weights by an SMRC committee, SMRC document that government shares were deducted in kind (رابعاً).

    Citation
    Policies Department Circular (2025/2) of 21 Jan 2025, under ss.7-8 of the Currency Dealing Regulation Act 1981 and art.20 of the Regulation 2013; repeals Circulars 2022/24, the circular of 11 Jun 2023, 2024/4 and 2024/5
    Kind
    Circular
    In force from
    2025-01-21
    Official guidanceOCR

    Researcher's note: In force: no later circular repealing it appears on the CBOS index of circulars issued after 15 April 2023 (checked 2026-09-29).

  • CBOS Circular 3/2025: purchase and export of free gold and tailings-company gold

    Any legal person could export free and tailings gold against advance payment transferred from abroad or a confirmed sight L/C (proceeds within 30 days); gold export account 21 working days; minimum 10 kg; no exports by government bodies or foreigners except concession companies.

    Citation
    Policies Department Circular (2025/3) of 21 Jan 2025; repealed by Circular 2025/14
    Kind
    Circular
    In force from
    2025-01-21
    Repealed on
    2025-09-14
    Official guidanceOCR
  • CBOS Circular 11/2014: Gold export by companies

    Banks may not complete export banking procedures for gold by mining or tailings companies without CBOS prior written approval. Issued under art.20 of the Foreign Currency Dealing Regulations 2013.

    Kind
    Circular
    In force from
    2014-09-09
    Official guidance

    Researcher's note: [inferred] No repeal text held, but the approval rules are now set by Circulars 2/2025 (concession and small-mining gold) and 18/2026 (tailings gold); free gold needs no CBOS approval under 17/2025.

  • CBOS Circular 11/2026: amendments to the free-gold and tailings-gold policy

    (1) Free-gold proceeds may be used for the holder's imports or sold to the exporter's bank, any other bank or CBOS. (2) CBOS buys 100% of tailings companies' gold at its announced price after in-kind deduction of profits and royalties from total production - cancelled 21 Sep 2026. (3) Minimum free-gold export contract 1 kg.

    Citation
    Policies Department Circular (2026/11) of 13 May 2026, amending 2025/17; item 2 cancelled and replaced by 2026/18 of 21 Sep 2026
    Kind
    Circular
    In force from
    2026-05-13
    Official guidanceNot recordedOCR
  • CBOS Circular 12/2026: amendments to import procedures (use of export proceeds)

    Free-gold proceeds, other export proceeds and banks' other resources may pay for any goods MoIT allows to be imported; all imports run through an intermediate import account; amounts may stay there at most 21 working days, then are bought for CBOS at the bank's buying rate; the item allowing 100% of free and tailings gold proceeds for strategic imports is deleted.

    Citation
    Policies Department Circular (2026/12) of 13 May 2026, amending the import circular 2026/02 of 6 Jan 2026 (not held)
    Kind
    Circular
    In force from
    2026-05-13
    Official guidanceNot recordedOCR
  • CBOS Circular 13/2026: incentive price for free-gold exports

    CBOS prices gold for export daily at the international 24-carat price per ounce less USD 10, converted to USD per gram, announced on the XAR system to MoIT and the unified gold export window; the exporter is settled at this price and no shipment passes if proceeds fall below the value at the announced price; banks send monthly electronic returns.

    Citation
    Policies Department Circular (2026/13) of 13 May 2026
    Kind
    Circular
    In force from
    2026-05-13
    Official guidanceNot recordedOCR
  • CBOS Circular 17/2025 (reopening of gold exports to companies)

    Free gold = gold from traditional (artisanal) mining (ثانياً). Any legal person may export free and tailings gold after all export procedures (ثالثاً-1), at international prices, by advance payment or confirmed sight L/C without overseas-assay conditions, proceeds on acceptance of documents and at most 30 days from shipment (ثالثاً-2); gold export account up to 21 working days, then bought for CBOS (ثالثاً-3); tailings gold needs CBOS written approval (ثالثاً-5); free gold needs SSMO weight and assay documents (ثالثاً-6). Manufacture and return within one month with MoIT approval, SSMO certificate and IM form on return (رابعاً). Exporters follow MoIT, Ministry of Minerals, SSMO, Customs and Sudan Gold Refinery controls (خامساً-1); minimum contract 10 kg or as MoIT decides (خامساً-2, replaced by 1 kg in 2026/11); no exports by government bodies or foreigners except concession companies (خامساً-4); CBOS buys gold only to build reserves (خامساً-5).

    Citation
    Policies Department Circular (2025/17) of 5 Nov 2025; repeals 2025/14; amended by 2026/11 (13 May 2026) and, for tailings gold, by 2026/18 (21 Sep 2026)
    Kind
    Circular
    In force from
    2025-11-05
    Official guidanceNot recordedOCR
  • CBOS Circular 18/2026: purchase and export of tailings-company gold

    Tailings companies may sell all their gold to CBOS, its delegate or exporters (1); banks may complete tailings-gold exports by advance payment, with daily CBOS pricing (2), or confirmed sight L/C without goods conditions, proceeds within 30 days of shipment (3); gold export account up to 21 working days (4); proceeds used for imports of activity needs after SMRC approval, or sold to banks or CBOS (5); CBOS written approval required (6).

    Citation
    Policies Department Circular (2026/18) of 21 Sep 2026; cancels paragraph (2) of 2026/11
    Kind
    Circular
    In force from
    2026-09-21
    Official guidanceOCR
  • CBOS Foreign Exchange Operations Controls and Directions (ضوابط وتوجيهات عمليات النقد الأجنبي), booklet

    Export contract endorsed by a commercial bank, valid «شهرين» (dual of «شهر», month) from endorsement, advance-payment contracts excepted; exporters must repatriate export proceeds in foreign currency within the periods set per payment method. Gold rules of the booklet: artisanal gold is exported only by the Central Bank of Sudan; licensed gold companies with agreements with the Government export their production after refining at the Khartoum refinery; export of raw gold is prohibited; free-gold exports are paid by advance payment transferred from abroad; gold exported for repair and return needs an export licence and a guarantee cheque for its value (pages in refs).

    Kind
    Guideline
    Official guidanceOCR

    Researcher's note: [ocr] Read in the booklet's unchecked OCR text. Its gold rules are superseded by later CBOS gold circulars; the export-contract rules are still the only text held on contract validity.

  • CBOS monetary and financial policies for 2026

    Lists activities banks may not finance, including "purchase of gold and its tailings" (شراء الذهب ومخلفاته).

    Kind
    Guideline
    In force from
    2026-01-01
    Official guidanceOCR

    Researcher's note: [ocr]

  • Currency Dealing Regulation Act 1981 (amended 2011)

    Import and export of gold in all forms is subject to what the regulations provide (s.7); exporters must recover the value of exported goods in foreign currency; offences up to three years' imprisonment or fine, with confiscation (s.9). Legal basis cited by every 2025-2026 CBOS gold circular, with art.20 of the Currency Dealing Regulation 2013.

    Citation
    Act of 1981, amended 2011 (s.5 replaced); printed in the CBOS 2014 booklet
    Kind
    Act
    Primary lawOCR

    Researcher's note: [ocr] Read in the OCR of the booklet; ss.7 and 9 checked against the page images.

  • Currency Dealing Regulation 2013

    Import of worked or refined (bar) gold only with a Ministry of Trade import approval and CBOS consent; anyone may bring in up to ten ounces of worked gold for adornment (art.7). Export of worked or refined gold only with a Ministry of Trade approval and CBOS consent; a resident may take out up to ten ounces of worked gold for adornment registered in the passport; worked gold declared on arrival may be taken out again (art.8). Art.20 is the Governor's power under which the CBOS circulars are issued.

    Citation
    Signed 2 Jan 2013; repeals the Foreign Exchange Dealing Regulation 1999; printed in the CBOS 2014 booklet
    Kind
    Regulation
    In force from
    2013-01-02
    Primary lawOCR

    Researcher's note: [ocr] Read in the OCR of the booklet; arts.7-8 checked against the page images.

  • Council Regulation (EU) 2026/1724 of 13 July 2026 (gold, mercury and cyanide measures)

    Art.1a: ban on purchase, import or transfer of Sudan-origin gold (CN 7108, 7112 91, ex 7118 90) exported from Sudan after 15 Jul 2026; Art.1b: ban on mercury and sodium cyanide exports to Sudan. Entry into force the day after publication (OJ 14 Jul 2026).

    Kind
    Regulation
    In force from
    2026-07-15
    Primary law
  • Minister of Minerals Decision No. 45 of 2024 (delegation of competent-authority powers to SMRC)

    SMRC holds all delegable powers of the "competent authority" under MMDA 2015: supervision and inspection; in-kind and cash collection of royalties, rents and profit shares; sale of the state's in-kind gold with proceeds paid as MoF Decision 90/2021 provides.

    Citation
    Ministerial Decision No. 45 of 2024, 29 Aug 2024; read with Council of Ministers Decision No. 98 of 2024 (not held); repeals Decision No. 44 of 2021
    Kind
    Decree
    In force from
    2024-08-29
    Primary lawOCR

    Researcher's note: [transcription]

  • Minister of Minerals Decisions Nos. 40, 41 and 42 of 2024 (royalties on gypsum, salt and cement)

    Posted on Minerals Gate as the royalty decision; it covers only gypsum, salt and cement raw materials. No Minister's decision setting a gold royalty rate under art.15 of the 2016 Exploitation Regulation was found.

    Kind
    Decree
    In force from
    2024-08-20
    Primary lawOCR

    Researcher's note: [transcription]

  • Precious Metals and Gemstones Act 2008 (Act No. 10 of 2008)

    Administered by the Hallmarking and Precious Metals Control Department of the Sudanese Standards and Metrology Organisation (s.3). No trading in or possession for sale of unhallmarked gold or silver articles (s.4). Legal gold standards: 23.5 kt (979.16), 21 kt (875), 18 kt (750), 14 kt (583.33), 12 kt (500), 9 kt (375) parts per thousand (s.7). No export, including for manufacture and return, of precious metals or gemstones as bars or jewellery without hallmarking by the Department as regulations provide (s.20(1)); imports need the Department's approval, assay and hallmark unless there is a mutual-recognition agreement (s.20(2)). Register of assayers and goldsmiths (s.23); goldsmiths need a registration certificate (s.24). Offences s.25.

    Citation
    Act No. 10 of 2008; s.2 repeals the Gold and Silver Hallmarking Act 1972
    Kind
    Act
    Primary lawOCR

    Researcher's note: [transcription]

  • Minister of Finance Decision No. 90 of 2021 on the distribution of mining-sector revenues

    Shares of the producing state and locality: royalties 7.5% each; government profit share 12.5% each; traditional mining revenues 20% each; community-responsibility money 80% to the locality; mineral zakat 30% state / 70% locality. Social responsibility: 4% in kind of tailings companies' gold output and 1% in cash of concession companies' gold production value. SMRC determines, collects and distributes the shares and manages the government's gold, including zakat gold.

    Citation
    Ministerial Decision No. 90 of 2021, signed 4 Rabi' al-Thani 1443 / 9 Nov 2021, under s.22 of the Financial and Accounting Procedures Act 2007
    Kind
    Decree
    In force from
    2021-11-09
    Primary lawOCR

    Researcher's note: [transcription] The federal-share column of the distribution table is illegible on the scan.

  • Traditional Gold Mining Regulation 2016

    No traditional gold mining without a contract from the Ministry on SMRC recommendation (art.4); annual renewal (art.5); conditions: Sudanese, entered in the SMRC register, aged 18+, contract, miner card, sale of gold as Ministry and SMRC policy provides, payment of fees and royalties (art.6); royalty per the Schedule, 50% national / 50% state, payable in kind or cash as the Ministry decides (art.8); coordination councils down to market councils that collect royalties and fees (arts.9-16); tailings not to be moved between states or stored within 25 km of housing (art.18); contract suspension or cancellation for breaches (art.19); Schedule: royalty 10% of product (gold or cash) or 20% of ore; fees.

    Citation
    Made by the Minister of Minerals with National Assembly approval under MMDA 2015 s.34(ج); in force from signature (art.1); signature page undated
    Kind
    Regulation
    Primary lawOCR

    Researcher's note: [transcription] The signature date is blank in the posted copy.

  • US Executive Order 14098 (Sudan)

    Authority for designation of Al Junaid (2023) and AZ Gold, Capital Tap and Hemedti (2025).

    Kind
    Other
    Official guidance

    Researcher's note: [not-read] Executive Order text not held; its date (4 May 2023) is not stated in the held documents. The held "programme page" file is 31 CFR part 546 (Darfur, EO 13400).

  • Money Laundering and Terrorism Financing Act 2009

    NOT IN FORCE. Historical: covered "trade of minerals and valuable gems" (CDD s.6(1), STR s.6(3)) and required declaration of money, bearer instruments, metals and valuable gems at the border (s.36). Superseded by sd.law-aml-2014.

    Kind
    Act
    Primary law

    Researcher's note: [inferred] Replaced by the Money Laundering and Terrorist Financing Act 2010 (not held), which the 2014 Act s.2 repeals; the repeal date of the 2009 text is not known.

  • Anti-Money Laundering and Counter-Terrorist Financing Act 2014

    Dealers in metals or precious stones are "non-financial institutions" when they conclude cash transactions above a threshold the Minister sets by decision (s.3); CDD (s.5); record keeping and suspicious-transaction reporting (s.6); border declaration of currency and bearer negotiable instruments at amounts set by regulations (s.31) - metals and gems are not included; seizure by customs (s.32); breach of s.31: fine equal to twice the amount (s.38(4)).

    Citation
    Act of 2014; s.2 repeals the Money Laundering and Terrorist Financing Act 2010
    Kind
    Act
    Primary law

    Researcher's note: Read in the HTML text on the CBOS site; no gazetted copy held. The Minister's decision fixing the cash threshold for dealers is not held.

  • Council Regulation (EU) 2023/2147 concerning restrictive measures in view of the situation in Sudan

    EU Sudan regime; amended by 2026/1724.

    Kind
    Regulation
    Primary lawBlocked

    Researcher's note: [not-read] Base regulation not held; the Publications Office consolidated text downloaded was the Estonian language version. Known from the amending act.

  • Regulation on the Exploitation of Minerals 2016

    Mining contract area up to 2 km2 (art.13(2)); rent EUR 10,000 per km2 (art.13(5)); royalty on gross production at the percentage the Minister sets by mineral and mine location (arts.13(6), 14(6), 15); community development contributions (art.33); no export of mineral ores, salt, gypsum or gemstones without a Ministry export certificate (art.34(1)), certificates issued after payment of fees (art.34(2)); fee schedule (ore export certificate EUR 500; sample export EUR 100 per 20 kg; tailings-processing contract signing bonus and renewal SDG 5,000,000 each); settlement schedule (dealing in mercury without a Ministry permit EUR 100,000).

    Citation
    Made by the Minister of Minerals under MMDA 2015; art.2 repeals the 2012 Regulation; signed 13 Rabi' al-Awwal 1438 (handwritten; probably 12 Dec 2016)
    Kind
    Regulation
    Primary lawOCR

    Researcher's note: [transcription]

  • Mineral Resources and Mining Development Act 2007

    Repealed by the 2015 Act (commencement date not read); permits and contracts issued under it stay valid.

    Kind
    Act
    Primary lawOCR

    Researcher's note: Known only from the repeal clause of the 2015 Act.

  • Mineral Wealth and Mining Development Act 2015 (amended 2019 and 2023)

    Licence and contract types s.14(1)(أ)-(ز): general search licence, exclusive exploration licence, mining contract, small mining contract, traditional mining contract (هـ), industrial minerals contract, tailings licence (ز, added 2019); signed by the Director of the Geological Research Authority with the Minister's approval (s.14(2)). Licence conditions s.12(1); traditional mining contract only for Sudanese aged 18+ registered with the Authority who have paid the fees (s.12(2)). Minister issues search/exploration licences on the Technical Committee's recommendation (s.13(1)). Fees per the Schedule (s.20(1)); rents set by regulations (s.20(2)); the Act sets no royalty rate. Competent authority collects fees and government shares, may sell in-kind shares and remit to the Ministry of Finance (s.27أ, 2023). Offences s.32(1)(أ)-(ز), mandatory confiscation s.32(2), General Criminal Court s.33, regulations with National Assembly approval s.34.

    Citation
    Act No. 8 of 2015 (footnote to the title); s.2 repeals the Mineral Resources and Mining Development Act 2007; amended by the Miscellaneous Amendments (Anti-Smuggling) Act 2019 and the Miscellaneous Amendments (Public Funds) Act 2023
    Kind
    Act
    Primary lawOCR

    Researcher's note: [transcription] Consolidated text as posted on Minerals Gate; the 2019 and 2023 amending Acts themselves are not held.

  • The Sudan (Sanctions) (EU Exit) Regulations 2020

    UK asset freezes under the Sudan regime, including the 16 Jul 2026 designations of Omdurman Mining, Ariab Mining Company and Sudamin (FCDO press release) and the four designations in the OFSI notice of 12 Dec 2025. The GOV.UK notice page was withdrawn on 30 Jan 2026 (notices moved to a new page); the Regulations continue.

    Citation
    S.I. 2020/753
    Kind
    Regulation
    Official guidance

    Researcher's note: [not-read] The Regulations themselves are not held.

Laws concerning gold in Sudan

From the law library: the laws tagged with this commodity, with their sources. They are not research findings; the sections above are.

منشور إدارة السياسات رقم (2025/2) - سياسات شراء وتصدير ذهب شركات الإمتياز وشركات التعدين الصغير (CBOS Policies Department Circular No. 2025/2: purchase and export of gold of concession and small-mining companies)

Circular · Policies Department Circular No. (2025/2); addressed to all banks and concerned bodies · Central Bank of Sudan (بنك السودان المركزي), General Directorate of Policies, Research and Statistics - Policies Department

منشور إدارة السياسات رقم (2025/3) - سياسات شراء وتصدير الذهب الحر وذهب شركات مخلفات التعدين (CBOS Policies Department Circular No. 2025/3: purchase and export of free gold and gold of mining-tailings companies)

Circular · Policies Department Circular No. (2025/3); addressed to all banks and concerned bodies · Central Bank of Sudan (بنك السودان المركزي), General Directorate of Policies, Research and Statistics - Policies Department

منشور إدارة السياسات رقم (2026/11) - تعديلات في سياسات شراء وتصدير الذهب الحر وذهب شركات مخلفات التعدين (CBOS Policies Department Circular No. 2026/11: amendments to the free-gold and tailings-gold policy (2025/17))

Circular · Policies Department Circular No. (2026/11); addressed to all banks and concerned bodies · Central Bank of Sudan (بنك السودان المركزي), General Directorate of Policies, Research and Statistics - Policies Department

منشور إدارة السياسات رقم (2026/13) - تحفيز حصائل صادرات الذهب الحر (CBOS Policies Department Circular No. 2026/13: incentive for free-gold export proceeds (daily CBOS export price))

Circular · Policies Department Circular No. (2026/13); addressed to all banks and concerned bodies · Central Bank of Sudan (بنك السودان المركزي), General Directorate of Policies, Research and Statistics - Policies Department

منشور إدارة السياسات رقم (2025/14) - سياسات شراء وتصدير الذهب الحر وذهب شركات مخلفات التعدين (CBOS Policies Department Circular No. 2025/14: purchase and export of free gold and tailings-company gold (CBOS sole buyer and exporter))

Circular · Policies Department Circular No. (2025/14); addressed to all banks and concerned bodies · Central Bank of Sudan (بنك السودان المركزي), General Directorate of Policies, Research and Statistics - Policies Department

منشور إدارة السياسات رقم (2025/17) - سياسات شراء وتصدير الذهب الحر وذهب شركات مخلفات التعدين (CBOS Policies Department Circular No. 2025/17: purchase and export of free gold and tailings-company gold)

Circular · Policies Department Circular No. (2025/17); addressed to all banks and concerned bodies · Central Bank of Sudan (بنك السودان المركزي), General Directorate of Policies, Research and Statistics - Policies Department

منشور إدارة السياسات رقم (2026/18) - سياسات شراء وتصدير ذهب شركات مخلفات التعدين (CBOS Policies Department Circular No. 2026/18: purchase and export of tailings-company gold)

Circular · Policies Department Circular No. (2026/18); addressed to all banks and concerned bodies · Central Bank of Sudan (بنك السودان المركزي), General Directorate of Policies, Research and Statistics - Policies Department

CBOS circular No. 11 of 2014 on gold export by companies (web page, 9 September 2014)

Circular · Circular No. 11/2014 (as titled on the page) · Central Bank of Sudan (بنك السودان المركزي), General Directorate of Policies, Research and Statistics - Policies Department

cbos notice 2026 amendment free gold and tailings gold policy (from the file; to confirm against the document)

Notice · to confirm · to confirm

UK sanctions illicit gold networks fuelling Sudan's war amid crisis around El Obeid

Other · Press release (no number) · Foreign, Commonwealth & Development Office (FCDO)

لائحة تنظيم اعمال معايرة الذهب والمعادن المصاحبة لسنة 2016م (Regulation on Gold and Associated Minerals Assaying Work 2016), with transmittal letters of 2016 and 2022, the tabled draft and National Assembly Decision No. 15

Regulation · No regulation number printed; approved by the National Assembly in sitting No. 29, third session, with amendments in its Decision No. 15 · Minister (under the Precious Metals and Gemstones Act 2008) with National Assembly approval

قانون المعادن النفيسة والأحجار الكريمة لسنة 2008 (Precious Metals and Gemstones Act 2008)

Act · Act No. 10 of 2008 (footnote on first page) · National Legislature; administered by the Sudanese Standards and Metrology Organisation (الهيئة = SSMO, s.3)

لائحة تنظيم التعدين التقليدي للذهب لسنة 2016م (Traditional Gold Mining Regulation 2016)

Regulation · Made under MMDA 2015 s.34(ج); no gazette number printed · Minister of Minerals with the approval of the National Assembly (preamble)

Procedures

Move gold from mining markets to city markets

Applies when: country is the origin; between first sale and export

  1. Due diligence

    Obtain gold documentation for the lot (holding or storing undocumented gold illegal from Aug 2025); transfer fee for moving artisanal gold to city markets waived since 2024

    Who
    Gold trader in a traditional mining market
    Issues
    Gold ownership / origin documentation (required to hold or store gold, from Aug 2025)
    SecondaryNot recorded

    Researcher's note: Form and issuer of the documentation not found.

  2. Transport

    Carry gold to a city market (Atbara, Abu Hamad, Port Sudan) and sell to an exporter or to CBOS

    Who
    Gold trader in a traditional mining market
    With
    Gold exporter (Sudanese legal person)
    Needs
    Gold ownership / origin documentation (required to hold or store gold, from Aug 2025)
    SecondaryNot recorded
  3. Due diligence

    Screen the supplier and lot: dealers in metals or precious stones concluding cash transactions above the Minister's threshold must do CDD, keep records and report suspicious transactions to the FIU

    Who
    Gold exporter (Sudanese legal person)
    Primary law

    Legal basis: Anti-Money Laundering and Counter-Terrorist Financing Act 2014, s.3, s.5, s.6

    Researcher's note: Threshold decision not held.

Private export by a registered exporter

Applies when: country is the origin

Channel: private exporter (legal person), since 5 Nov 2025

  1. Licensing

    Be a Sudanese legal person that has completed export procedures (company registration, exporters' register); government bodies and foreigners are excluded except concession companies

    Who
    Gold exporter (Sudanese legal person)
    Needs
    Exporter's company registration; Exporters' register certificate (Ministry of Industry and Trade)
    Official guidanceOCR

    Legal basis: CBOS Circular 17/2025, ثالثاً-1; خامساً-4

  2. Pricing

    Agree a sale with a foreign buyer at international prices, with proceeds not below the CBOS daily price; minimum contract 1 kg of free gold (10 kg from 5 Nov 2025 to 12 May 2026)

    Who
    Gold exporter (Sudanese legal person)
    With
    Foreign buyer / refiner
    Issues
    Sale contract with foreign buyer at international benchmark price
    Official guidanceOCR

    Legal basis: CBOS Circulars 17/2025, 11/2026, 13/2026, 17/2025 ثالثاً-2; 11/2026 item 3; 13/2026 item 3

  3. Payment

    Pay in advance, or open a confirmed sight L/C with no condition on the goods such as overseas assay; L/C proceeds on acceptance of documents, at most 30 days from shipment

    Who
    Foreign buyer / refiner
    With
    Commercial bank (authorised FX dealer)
    Needs
    Export contract endorsed by the commercial bank
    Issues
    Advance payment received from the foreign buyer; Confirmed documentary L/C (no overseas-assay condition)
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 17/2025, ثالثاً-2

  4. Assay

    Comply with Sudan Gold Refinery's controls for the export lot (processing/assay as the refinery requires)

    Who
    Sudan Gold Refinery (state refinery)
    Needs
    Gold ownership / origin documentation (required to hold or store gold, from Aug 2025)
    Issues
    Sudan Gold Refinery processing / assay certificate
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 17/2025, خامساً-1

    Researcher's note: [conflict] Circular 17/2025 only requires compliance with the refinery's controls; press said local refining was required in Sept 2025. The refinery's controls are not held.

  5. Inspection

    Obtain SSMO documents on the weight and assay of the lot (free gold) or the SSMO certificate (concession and small-mining gold); precious metals must carry the SSMO hallmark before export

    Who
    Sudanese Standards and Metrology Organisation
    Needs
    Sudan Gold Refinery processing / assay certificate
    Official guidanceOCR

    Legal basis: CBOS Circular 17/2025, ثالثاً-6

  6. Licensing

    For tailings gold (and concession / small-mining gold) obtain CBOS written approval, without which banks may not complete the export; not required for free gold under Circular 17/2025

    Who
    Central Bank of Sudan (state buyer and exporter)
    Needs
    Export contract endorsed by the commercial bank
    Official guidanceOCR

    Legal basis: CBOS Circular 18/2026 (tailings); 2/2025 (concession and small mining), 18/2026 item 6; 2/2025 ثانياً-1

  7. Licensing

    Issue the export licence where required

    Who
    Ministry of Industry and Trade
    Needs
    Exporters' register certificate (Ministry of Industry and Trade)
    Issues
    Ministry of Industry and Trade export licence
    UnverifiedOCR

    Researcher's note: Circular 17/2025 requires compliance with MoIT controls and MoIT approval for manufacture-and-return exports; the Currency Dealing Regulation 2013 art.8 requires a Ministry of Trade approval to export worked or refined gold. A per-shipment MoIT licence for ordinary exports is not confirmed.

  8. Reporting

    Record the shipment on the SMRC Minerals Gate / unified gold export platform

    Who
    Gold exporter (Sudanese legal person)
    Issues
    Production and export return via Minerals Gate
    Official guidanceNot recordedOCR
  9. Customs

    Clear the export declaration at Port Sudan; shipments valued below the CBOS indicative price are not cleared

    Who
    Sudan Customs Authority
    Issues
    Customs export declaration; Certificate of origin
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 13/2026, item 3

  10. Transport

    Ship by air from Port Sudan to the buyer

    Who
    Gold exporter (Sudanese legal person)
    With
    Foreign buyer / refiner
    Needs
    Customs export declaration
    Issues
    Air waybill (Port Sudan airport)
    SecondaryNot recorded
  11. Customs

    Send gold abroad for manufacture and return against MoIT approval, an SSMO certificate and the credit-scoring condition, with the EX form; return within one month and clear it with the IM form; failure blocks the client from further exports

    Who
    Gold exporter (Sudanese legal person)
    Issues
    Ministry of Industry and Trade export licence
    Official guidanceOCR

    Legal basis: CBOS Circular 17/2025, رابعاً

    Researcher's note: A bank cheque or guarantee for the gold's value was required under Circular 14/2025 (14 Sep - 5 Nov 2025) and is not listed in 17/2025.

Concession company export with compulsory sale to CBOS

Applies when: country is the origin; industrial / concession output

Channel: concession company (70/30)

  1. Extraction

    Mine and process under the mining contract; report stockpiles, CIL processing, smelting and ingots on Minerals Gate

    Who
    Concession (mining contract) company
    Needs
    Mining contract / small-scale mining contract
    Issues
    Production and export return via Minerals Gate
    Official guidanceOCR
  2. Payment

    Sell the remaining 30% of net output (after in-kind government shares) to CBOS or its delegate, whether or not the 70% is exported

    Who
    Concession (mining contract) company
    With
    Central Bank of Sudan (state buyer and exporter)
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 2/2025, ثالثاً-1(ب)

  3. Customs

    Export up to 70% of net output with CBOS written approval, an SSMO certificate and a Ministry of Minerals export-approval certificate; concession companies keep proceeds inside or outside Sudan as their agreements allow; small-mining companies use advance payment from abroad or confirmed sight L/C and a gold export account (21 working days)

    Who
    Concession (mining contract) company
    With
    Foreign buyer / refiner
    Issues
    Ministry of Minerals export-approval certificate; Customs export declaration
    Official guidanceOCR

    Legal basis: CBOS Circular 2/2025, ثانياً; ثالثاً-1(أ), ثالثاً-2

    Researcher's note: [conflict] Press reported 100% advance payment and local refining for concession exports in Sept 2025; Circular 2/2025 (still in force) says otherwise.

Artisanal mining, processing at the market and first sale

Applies when: country is the origin; gold from traditional (artisanal) mining in government-held states (Northern, River Nile, Red Sea, parts of Kordofan)

Channel: artisanal

  1. Licensing

    Hold a traditional mining contract from the Ministry (on SMRC recommendation, renewed yearly) and be entered in the SMRC miners' register with a miner card; only Sudanese aged 18+

    Who
    Traditional (artisanal) miner
    Needs
    Traditional mining contract
    Primary lawOCR

    Legal basis: Traditional Gold Mining Regulation 2016, arts.4-6; MMDA s.12(2), s.14(1)(هـ)

    Researcher's note: [transcription] Practice (who actually holds contracts) not documented.

  2. Extraction

    Dig and haul ore by hand or light machinery

    Who
    Traditional (artisanal) miner
    SecondaryNot recorded
  3. Processing

    Crush and mill ore at the market's mills, wash to a concentrate, amalgamate with mercury and burn off the mercury to sponge gold; leave tailings ('karta') for processing companies

    Who
    Traditional (artisanal) miner
    SecondaryNot recorded
  4. Processing

    Smelt sponge into a small button or bar in the market

    Who
    Traditional (artisanal) miner
    SecondaryNot recorded

    Researcher's note: Practice inferred from reports of 21-karat gold priced per gram in mining towns; exact form at first sale not documented.

  5. Tax

    Pay the royalty on artisanal gold - 10% of the product in gold or cash (or 20% of ore) - to SMRC / the market council, which issues a receipt

    Who
    Sudanese Mineral Resources Company
    Primary lawNot recordedOCR

    Legal basis: Traditional Gold Mining Regulation 2016, art.8; art.16(أ); Schedule

    Researcher's note: [transcription] Receipt form not found.

  6. Payment

    Sell the button to a gold trader in the market for Sudanese pounds (cash or the Bankak mobile app); price follows the market, not the CBOS price

    Who
    Traditional (artisanal) miner
    With
    Gold trader in a traditional mining market
    Issues
    Trader's purchase note to the miner (informal; weight, karat, price); Weight and karat reading at the market
    SecondaryNot recorded

    Researcher's note: No source describes the paperwork at first sale.

  7. Payment

    Alternatively sell to a CBOS appointed agent at the CBOS announced price, net of royalty and statutory fees

    Who
    Traditional (artisanal) miner
    With
    CBOS appointed purchase agent
    Issues
    CBOS / agent purchase note (weight, fineness, announced price, royalty and fee deductions)
    Official guidanceNot recordedOCR

    Researcher's note: The price net of royalty and fees is from press reports.

  8. Processing

    Process tailings under the tailings licence/SMRC contract (cyanide / CIL), smelt to dore, pay 4% of gold output in kind as community contribution (MoF 90/2021), and sell the gold to CBOS, its delegate or an exporter (since 21 Sep 2026) - between 13 May and 21 Sep 2026 all of it had to be sold to CBOS

    Who
    Mining-waste (tailings, 'karta') processing company
    With
    Central Bank of Sudan (state buyer and exporter)
    Issues
    CBOS / agent purchase note (weight, fineness, announced price, royalty and fee deductions)
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 18/2026, item 1

Production and revenue reporting

Applies when: country is the origin

  1. Reporting

    File production data and allow SMRC review of financial records under the concession agreement

    Who
    Concession (mining contract) company
    Issues
    Production and export return via Minerals Gate
    Official guidance
  2. Reporting

    Compile production statistics by sector; determine, collect and distribute government revenue shares (royalties, profit shares, zakat, community contributions) to the federal, state and locality accounts and manage government gold

    Who
    Sudanese Mineral Resources Company
    Primary lawOCR

    Legal basis: MMDA 2015 s.27أ; MoM Decision 45/2024; MoF Decision 90/2021

Repatriate and use export proceeds

Applies when: country is the origin

  1. Payment

    Receive proceeds into the exporter's gold export account (L/C: on acceptance of documents, at most 30 days from shipment); balances older than 21 working days are bought for CBOS

    Who
    Commercial bank (authorised FX dealer)
    Issues
    Export proceeds repatriation record (bank)
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 17/2025, ثالثاً-2, ثالثاً-3

  2. Payment

    Use the proceeds for the holder's imports (any goods MoIT allows, via an import account, 21 working days) or sell them to the exporter's bank, another bank or CBOS

    Who
    Gold exporter (Sudanese legal person)
    Needs
    Export proceeds repatriation record (bank)
    Official guidanceOCR

    Legal basis: CBOS Circulars 11/2026 and 12/2026, 11/2026 item 1; 12/2026 items 1, 3

CBOS purchase, refining and state export

Applies when: country is the origin; gold sold to CBOS or its delegate (30% share of concession and small-mining gold; tailings gold sold to CBOS; artisanal gold sold to CBOS or its delegate)

Channel: state buyer (CBOS)

  1. Pricing

    Publish the daily gold price (international 24-carat price less USD 10/oz) on the XAR system

    Who
    Central Bank of Sudan (state buyer and exporter)
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 13/2026, items 1-2

  2. Payment

    CBOS purchases are executed by Sudan Gold Refinery: SSMO sets fineness, the SMRC receiving committee sets weights, and SMRC certifies that government shares were deducted in kind; CBOS or its delegate pays

    Who
    CBOS appointed purchase agent
    With
    Central Bank of Sudan (state buyer and exporter)
    Issues
    CBOS / agent purchase note (weight, fineness, announced price, royalty and fee deductions)
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 2/2025, رابعاً

  3. Refining

    Process CBOS gold through the Sudan Gold Refinery and certify weight and fineness

    Who
    Sudan Gold Refinery (state refinery)
    Needs
    CBOS / agent purchase note (weight, fineness, announced price, royalty and fee deductions)
    Issues
    Sudan Gold Refinery processing / assay certificate
    Official guidanceNot recordedOCR

    Researcher's note: Refinery (Khartoum) was looted in May 2023; which facility now does this work was not confirmed.

  4. Customs

    Export CBOS gold (or hold it); customs clearance at Port Sudan

    Who
    Central Bank of Sudan (state buyer and exporter)
    With
    Foreign buyer / refiner
    Needs
    Sudan Gold Refinery processing / assay certificate
    Issues
    Customs export declaration; Air waybill (Port Sudan airport)
    SecondaryNot recorded

    Researcher's note: No source describes CBOS's own export paperwork.

Licences and registrations

  • Appointment as CBOS delegate (من يفوضه) for gold purchases

    Held by
    CBOS appointed purchase agent
    Issued by
    Central Bank of Sudan
    Official guidanceNot recordedOCR

    Researcher's note: The circulars refer to "CBOS or its delegate"; the appointment instrument is not held.

  • Eligibility as gold exporter under CBOS rules (legal person; not a government body; not a foreigner unless a concession company)

    Held by
    Gold exporter (Sudanese legal person)
    Issued by
    Central Bank of Sudan
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 17/2025, ثالثاً-1; خامساً-4

  • Registration certificate for goldsmiths and assayers (no separate licence for buyers of raw gold found)

    Held by
    Gold trader in a traditional mining market
    Issued by
    SSMO (registrar appointed by the Director-General)
    Primary lawOCR

    Legal basis: Precious Metals and Gemstones Act 2008, ss.23-24

    Researcher's note: [transcription] The Act registers goldsmiths and assayers (ss.19, 23-24) and makes each person "authorised to trade or manufacture" in precious metals liable (s.21), but no licence for buyers of raw gold in mining markets was found; market councils regulate markets (Traditional Gold Mining Regulation arts.14-16).

  • Traditional mining contract

    Traditional mining contract

    Held by
    Traditional (artisanal) miner
    Issued by
    Ministry of Minerals on SMRC recommendation (Traditional Gold Mining Regulation art.4); signed by the Director of the Geological Research Authority with the Minister's approval (MMDA s.14(2))
    Valid for
    One year, renewable on SMRC recommendation after paying fees (Regulation art.5)
    Fee
    MMDA Schedule: application SDG 3,000; issue SDG 7,000; regularisation SDG 40,000; new contract SDG 15,000. Regulation Schedule: licence SDG 3,000; contract SDG 7,000 (well) to 250,000 (large pit). [conflict] the two schedules differ; see sd.tax-licence-fees.
    Primary lawOCR

    Legal basis: Mineral Wealth and Mining Development Act 2015, s.14(1)(هـ); s.12(2); Schedule row 5

    Researcher's note: [transcription] How far individual diggers hold contracts (versus working in areas contracted to groups or market operators) is not known.

  • Entry in the SMRC miners' register and miner card

    Held by
    Traditional (artisanal) miner
    Issued by
    SMRC
    Fee
    Miner card SDG 100
    Primary lawOCR

    Legal basis: Traditional Gold Mining Regulation 2016, art.6(ب), 6(ك); Schedule (miner card SDG 100)

    Researcher's note: [transcription]

  • Banking licence and authorisation to deal in foreign exchange

    Held by
    Commercial bank (authorised FX dealer)
    Issued by
    Central Bank of Sudan
    Official guidanceOCR
  • Company registration

    Certificate of incorporation

    Held by
    Gold exporter (Sudanese legal person)
    Issued by
    Commercial Registrar
    Official guidanceNot recordedOCR

    Researcher's note: Circular 17/2025 limits free-gold exports to legal persons; the registrar is not named in any text held.

  • Registration in the exporters' register

    Held by
    Gold exporter (Sudanese legal person)
    Issued by
    Ministry of Industry and Trade (the booklet names the Ministry of Commerce, وزارة التجارة)
    Official guidanceOCR

    Legal basis: CBOS FX Operations Controls and Directions (export procedures; pages in refs)

    Researcher's note: [ocr] From the CBOS FX directions booklet, read in its unchecked OCR text: the exporter submitting export contracts to the banks is registered with the Ministry of Commerce and holds a valid commercial register (the exporters' register); current procedure not read.

  • Company registration on the Minerals Gate portal

    Portal account; tracking of stockpiles, CIL plants, smelting and ingot export preparation

    Held by
    Concession (mining contract) company
    Issued by
    SMRC
    Official guidance
  • Mining contract (or small-scale mining contract)

    Held by
    Concession (mining contract) company
    Issued by
    Minister of Minerals
    Fee
    Mining contract: application SDG 3,000; issue 15,000; transfer or assignment 50,000. Small mining contract: 3,000; 10,000; 50,000. Rent EUR 10,000 per km2 a year (Exploitation Regulation art.13(5)).
    Primary lawOCR

    Legal basis: Mineral Wealth and Mining Development Act 2015, s.14(1)(ج)-(د); s.12(1); Schedule rows 3-4

    Researcher's note: [transcription]

  • Tailings licence and SMRC tailings-processing contract

    Held by
    Mining-waste (tailings, 'karta') processing company
    Issued by
    Ministry of Minerals / SMRC
    Fee
    Signing bonus SDG 5,000,000; renewal SDG 5,000,000; transfer EUR 1,000,000 (Exploitation Regulation schedule)
    Primary lawNot recordedOCR

    Legal basis: MMDA 2015 s.14(1)(ز) (2019); Exploitation Regulation 2016 fee schedule

    Researcher's note: [transcription] Contract form not held.

Taxes and fees

  • Royalty (al-'awa'id al-jalila) on traditional (artisanal) gold mining

    Traditional (artisanal) gold mining under a traditional mining contract

    Rate
    10% of the product (in gold or cash); alternatively 20% of the ore produced
    Base
    Gold produced (or ore, for the 20% rate)
    Paid by
    Traditional miner
    Collected by
    SMRC and the market councils (arts.14, 16); paid in kind or cash as the Ministry decides (art.8(ب))
    Primary lawOCR

    Legal basis: Traditional Gold Mining Regulation 2016, art.8; Schedule (art.20)

    Researcher's note: [transcription] [conflict] Art.8 splits the royalty 50% national / 50% state; MoF Decision 90/2021 gives the producing state and locality 20% each of "traditional mining revenues" (federal column illegible). See sd.div-conflict-asm-split. Chatham House's "20%" matches the 20%-of-ore alternative.

  • Corporation tax on gold companies

    Rate
    18% (reduced from 28%, 2024); USGS 2019 reported 15%
    Base
    Profits
    Paid by
    Gold mining companies
    Collected by
    Taxation Chamber
    SecondaryNot recorded
  • Royalty on gold (concession companies)

    Rate
    5-7% of mineral value (2019 policy)
    Base
    Gross production, regardless of costs, profit or loss (art.15(2))
    Paid by
    Concession company
    Collected by
    SMRC as delegated competent authority (MoM Decision 45/2024), in kind or cash
    SecondaryNot recordedOCR

    Legal basis: Regulation on the Exploitation of Minerals 2016, arts.13(6), 15

    Researcher's note: [conflict] The rate is from USGS 2019. Neither the Act nor the 2016 Exploitation Regulation fixes a rate: art.15 makes royalties on concession, small-mining and tailings companies a percentage of gross production that the Minister sets by mineral and mine location. The Minister's decision for gold was not found (Decisions 40-42/2024 cover gypsum, salt and cement only). Sudan Transparency (2024) cites 28.5% "as royalties", which likely bundles royalty and state share. See sd.div-conflict-royalty-rate.

  • Community (social) responsibility contribution on gold producers

    Rate
    4% in kind of tailings companies' gold output; 1% in cash of concession companies' gold production value (based on the previous year's output)
    Paid by
    Tailings-processing and concession companies
    Collected by
    SMRC, paid into the locality's community-responsibility account
    Primary lawOCR

    Legal basis: MoF Decision No. 90 of 2021, ثالثاً

    Researcher's note: [transcription]

  • Fee for transferring artisanal gold from mining areas to city markets

    Rate
    Waived (2024)
    Paid by
    Trader
    Collected by
    SMRC / state authorities
    SecondaryNot recorded
  • Licence and contract fees

    Rate
    MMDA Schedule (SDG): mining contract application 3,000, issue 15,000, transfer/assignment 50,000; small mining contract 3,000 / 10,000 / 50,000; traditional mining contract application 3,000, issue 7,000, regularisation 40,000, new contract 15,000; certificates 100 (samples up to 20 kg), 500 (ore export), 200 (other). Traditional Gold Mining Regulation Schedule (SDG): traditional mining licence 3,000; contract fee 7,000 (well), 50,000 / 150,000 / 250,000 (small / medium / large pit); sieve licences 10,000 / 50,000 / 100,000; miner card 100. Exploitation Regulation 2016 (EUR): ore export certificate 500; sample export 100 per 20 kg; tailings-processing contract signing bonus and renewal SDG 5,000,000 each.
    Paid by
    Applicant
    Collected by
    Ministry of Minerals / SMRC
    Primary lawOCR

    Legal basis: MMDA 2015, s.20(1); Schedule

    Researcher's note: [transcription] Schedule row 7 (certificates) is ambiguously aligned in print; the Minister may change fees with the Finance Minister's approval (s.20(3)).

  • Implicit levy: CBOS indicative price set USD 10/oz below the international price

    Rate
    USD 10 per troy ounce
    Base
    International 24-carat price
    Paid by
    Sellers to CBOS / exporters at the floor
    Collected by
    CBOS
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 13/2026, items 1-3

  • State share in concessions

    Rate
    30% of concessions (reported); plus a reported '40% tax on any gold sold' (unexplained)
    Paid by
    Concession company
    Collected by
    Ministry of Minerals / Ministry of Finance
    SecondaryNot recordedOCR

    Legal basis: MMDA 2015 s.27أ (2023); Circular 2/2025 ثالثاً

    Researcher's note: The percentage is from a secondary report. Primary texts: MMDA s.27أ (collection and sale of government shares), Exploitation Regulation art.13(7) (government share of net profits in small-mining contracts as the agreement provides), Circular 2/2025 (zakat, royalties and profit shares deducted in kind before the 70/30 split).

Controls

  • Banks may not finance the purchase of gold and its tailings (CBOS 2026 policies, list of prohibited financing, item vii "شراء الذهب ومخلفاته"). Gold buyers and exporters must use own funds or foreign advance payments.

    Kind
    Other
    Valid from
    2026-01-01
    Official guidanceOCR

    Legal basis: CBOS monetary and financial policies for 2026

    Researcher's note: [ocr] The 2025 policies were not checked for the same item.

  • Sudan is an active conflict zone with both SAF and RSF financing themselves from gold; downstream refiners following OECD/LBMA due diligence must treat all Sudanese gold as high-risk, including gold from state-owned producers now under UK sanctions. Sudan itself has no conflict-minerals law found.

    Kind
    Conflict-area due diligence
    SecondaryNot recorded
  • 2014 version: banks may not complete gold export banking procedures for any company exporting gold, including mining and tailings companies, without CBOS prior written approval (Circular 11/2014). Superseded in substance by the 2025-2026 approval rules (sd.ctl-export-approvals-2025).

    Kind
    Other
    Valid from
    2014-09-09
    Official guidance

    Legal basis: CBOS Circular 11/2014

    Researcher's note: [inferred] No repeal text held; see sd.ctl-export-approvals-2025.

  • 14 Sep - 5 Nov 2025 (Circular 14/2025): purchase of free (artisanal) and tailings gold inside Sudan reserved to CBOS or its delegate; export reserved to CBOS alone and banned for any natural or legal person; purchases executed by Sudan Gold Refinery. Concession and small-mining companies stayed under Circular 2/2025. Repealed by Circular 17/2025 on 5 Nov 2025.

    Kind
    State monopoly
    Valid from
    2025-09-14
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 14/2025, ثانياً 1-4

    Researcher's note: [time-limited] No longer in force since 5 Nov 2025.

  • Concession companies may export 70% of the output remaining after in-kind deduction of the government's zakat, royalty and profit shares, and must sell the other 30% to CBOS or its delegate whether or not they export; small-mining companies likewise (Circular 2/2025 ثالثاً). Earlier versions: CBOS gold policy of 1 Jan 2020 (secondary) and Circular 2022/24 (repealed by 2/2025, not held).

    Kind
    State monopoly
    Threshold
    30% of net output (after in-kind government shares)
    Valid from
    2025-01-21
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 2/2025, ثالثاً-1(ب), ثالثاً-2(د)

  • Every person entering or leaving Sudan must declare to customs the currency and bearer negotiable instruments carried, at amounts set by regulations (AML/CFT Act 2014 s.31(1)); customs may seize them on suspicion or false declaration (s.32); breach of s.31 is punished by a fine equal to twice the amount (s.38(4)). Metals and gems are not in the 2014 declaration rule (they were in s.36 of the superseded 2009 text). Gold carried by travellers is governed by Currency Dealing Regulation 2013 arts.7-8 (ten ounces of worked gold) and the Customs Disclosure Regulation (see sd.ctl-undocumented-gold).

    Kind
    Cross-border declaration
    Primary lawOCR

    Legal basis: Anti-Money Laundering and Counter-Terrorist Financing Act 2014, s.31, s.32, s.38(4)

    Researcher's note: [conflict] The r1 model applied the 2009 metals-and-gems declaration; see sd.div-conflict-cross-border. Declaration thresholds (regulations) not held.

  • EU ban on purchasing, importing or transferring, directly or indirectly, gold (CN 7108, 7112 91, ex 7118 90) that originates in Sudan and was exported from Sudan into the EU or any third country after 15 July 2026, and on related technical assistance, brokering, financing and financial assistance. Exception for official purposes of diplomatic missions and international organisations in Sudan. Applies to Sudanese gold routed via Dubai or elsewhere, so origin evidence travels with the metal.

    Kind
    Sanctions
    Valid from
    2026-07-15
    Primary lawBlocked

    Legal basis: Council Regulation (EU) 2026/1724, art.1a

  • Approvals banks must see before completing a gold export: concession and small-mining gold - CBOS written approval, an SSMO certificate and a Ministry of Minerals export-approval certificate (Circular 2/2025 ثانياً); tailings gold - CBOS written approval (17/2025 ثالثاً-5; restated by 18/2026 item 6); free gold - SSMO documents on weights and assay (17/2025 ثالثاً-6), no CBOS approval. Mineral ores need a Ministry of Minerals export certificate (Exploitation Regulation 2016 art.34(1)); precious metals must be hallmarked by SSMO before export (Precious Metals and Gemstones Act 2008 s.20(1)).

    Kind
    Other
    Valid from
    2025-01-21
    Official guidanceOCR

    Legal basis: CBOS Circulars 2/2025 and 17/2025

  • Free and tailings gold may be exported by any legal person (شخص اعتباري) after all export procedures (Circular 17/2025 ثالثاً-1); exports by government bodies and by foreigners, individuals or companies, are banned except concession companies in gold mining (خامساً-4). Individuals are not eligible [inferred from "legal person"].

    Kind
    Other
    Valid from
    2025-11-05
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 17/2025, ثالثاً-1; خامساً-4

  • No export, including export for manufacture and return, of precious metals or gemstones as bars or jewellery without hallmarking by SSMO's Hallmarking and Precious Metals Control Department as regulations provide; imports need the Department's approval, assay and hallmark unless a mutual-recognition agreement applies (s.20). Legal gold standards 23.5, 21, 18, 14, 12 and 9 carats (s.7).

    Kind
    Bar standard
    Primary lawOCR

    Legal basis: Precious Metals and Gemstones Act 2008, s.20; s.7

    Researcher's note: [transcription] How s.20 is applied to doré and unrefined gold exports is not stated in any text held.

  • 2014 directions: raw gold exports prohibited and company exports refined at the Khartoum refinery (historical). Current texts: CBOS purchases are executed by Sudan Gold Refinery with fineness set by SSMO (Circular 2/2025 رابعاً; 14/2025 ثانياً-4); exporters must comply with Sudan Gold Refinery's controls among others (17/2025 خامساً-1). No 2025-2026 circular held requires refining before a private export.

    Kind
    Local refining requirement
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 17/2025, خامساً-1

    Researcher's note: [conflict] Press reported that the Sept 2025 measures required local refinery processing before export; Circular 14/2025 does not say so. Sudan Gold Refinery's "controls" are not held.

  • Minimum gold export contract 10 kg "or as MoIT decides" (Circular 17/2025 خامساً-2, from 5 Nov 2025); replaced on 13 May 2026 by a 1 kg minimum for free-gold export contracts (Circular 11/2026 item 3).

    Kind
    Export quota
    Threshold
    1 kg per free-gold contract since 13 May 2026 (10 kg, 5 Nov 2025 - 12 May 2026)
    Valid from
    2026-05-13
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 11/2026, item 3

  • Payment by advance payment or by confirmed sight documentary credit whose terms contain no condition on the goods such as overseas assay ("calibration"); L/C proceeds on acceptance of documents and at most 30 days from shipment (Circular 17/2025 ثالثاً-2; same for small-mining companies under 2/2025 ثالثاً-2, where advance payment must be transferred from abroad; tailings gold under 18/2026 items 2-3).

    Kind
    Currency control
    Valid from
    2025-11-05
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 17/2025, ثالثاً-2

  • CBOS prices gold for export daily at the international 24-carat price less USD 10 per ounce, in USD per gram, announced on the XAR system to MoIT and the unified gold export window; exporters are settled at this price and no shipment passes if the proceeds fall below the value at the announced price (Circular 13/2026). Exports must also be at international exchange prices (17/2025 ثالثاً-2).

    Kind
    Price control
    Valid from
    2026-05-13
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 13/2026, items 1-3

  • L/C proceeds within 30 days of shipment (17/2025 ثالثاً-2). Proceeds are credited to a "gold export account" in the exporter's name and may stay there at most 21 working days, after which the bank buys them for CBOS at its announced rate (ثالثاً-3). Free-gold proceeds may be used for the holder's imports or sold to any bank or CBOS (11/2026 item 1); since 13 May 2026 they may pay for any goods MoIT allows, through an import account where funds may stay at most 21 working days (12/2026). Banks may buy gold export proceeds if the exporter wishes (8/2026). Bank executives are personally liable for following up export proceeds (14/2026).

    Kind
    Currency control
    Threshold
    30 days from shipment; 21 working days in the gold export account; 21 working days in the import account
    Valid from
    2025-11-05
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circulars 17/2025, 11/2026 and 12/2026, 17/2025 ثالثاً-2, ثالثاً-3

    Researcher's note: [conflict] Press reported a Sept 2025 rule reserving 70% of proceeds for strategic imports; no such rule is in any circular held (12/2026 deletes an item allowing 100% of free and tailings gold proceeds to be used for strategic imports, in import circular 2026/02, not held).

  • Offences (MMDA s.32(1)): exploring without a licence - up to 2 years (أ); extracting without a mining contract - up to 3 years (ب); withholding production data - up to 5 years (ج); false information - fine of at least SDG 100,000 (د); transporting, exporting, storing, possessing or dealing in minerals or tailings without licence or Ministry permission - up to 5 years (هـ, 2019); refusing to pay fees, charges and royalties (ز, 2023); extracting or burning minerals or tailings without the prescribed controls - up to 5 years (و, 2019). Prison terms are with or instead of a fine; (ز) states no penalty. On conviction the court must confiscate the minerals, any profit and the equipment used (s.32(2)); General Criminal Court (s.33).

    Kind
    Export ban
    Primary lawOCR

    Legal basis: MMDA 2015, s.32(1), s.32(2), s.33

    Researcher's note: [transcription]

  • 13 May - 21 Sep 2026: CBOS bought 100% of tailings (mining-waste) companies' gold at its announced price after in-kind deduction of profits and royalties from total production (Circular 11/2026 item 2). Cancelled and replaced on 21 Sep 2026 by Circular 18/2026 (see sd.ctl-tailings-sale-2026-09).

    Kind
    State monopoly
    Valid from
    2026-05-13
    Official guidanceNot recordedOCR

    Legal basis: CBOS Circular 11/2026, item 2

    Researcher's note: [time-limited] Not in force since 21 Sep 2026. [conflict] The press (Actum) dated the rule June 2026; the circular is dated 13 May 2026.

  • Since 21 Sep 2026 (replacing sd.ctl-tailings-100pct): tailings companies may sell all their gold to CBOS, its delegate or exporters; tailings gold may be exported by advance payment (priced daily by CBOS) or confirmed sight L/C with proceeds within 30 days of shipment; proceeds held in a gold export account up to 21 working days and used for imports of activity needs after SMRC approval or sold to banks or CBOS; banks need CBOS written approval for each export.

    Kind
    Currency control
    Valid from
    2026-09-21
    Official guidanceOCR

    Legal basis: CBOS Circular 18/2026, items 1-6

  • The UAE, which took about 88-95% of Sudan's official gold exports, suspended trade with Sudan in August 2025, forcing a search for other buyers (Qatar refinery agreement, Egypt, Turkey, India, Hong Kong).

    Kind
    Import restriction
    Valid from
    2025-08-01
    SecondaryNot recorded

    Researcher's note: UAE instrument not read; Bloomberg report blocked.

  • UK asset freezes (16 Jul 2026) on three Sudanese state-owned mining companies - Omdurman Mining and Ariab Mining Company (suspected of generating gold revenue for the SAF) and Sudamin Company Ltd (suspected of channelling conflict-gold revenue to both SAF and RSF, incl. past links to Al Junaid) - plus RSF financier Abu Dharr Abdul Nabi Habiballa Ahmmed and UAE/HK-based procurement companies. Dealing with gold from these producers is now a UK sanctions risk even inside the lawful state channel.

    Kind
    Sanctions
    Valid from
    2026-07-16
    Official guidanceNot recorded

    Legal basis: The Sudan (Sanctions) (EU Exit) Regulations 2020

    Researcher's note: The designation notice for 16 Jul 2026 is [not-read]; list as given in the FCDO press release.

  • Transporting, exporting, storing, possessing or dealing in minerals or tailings whose source of production one does not own, without a licence or Ministry permission, is an offence (MMDA s.32(1)(هـ), added 2019; up to five years). Press reported that the Aug 2025 measures made holding undocumented gold illegal. Customs monitor the limit on worked gold carried by departing travellers under the Customs Disclosure Regulation 2015 (amended 2022, not held) (Circular 14/2025 ثالثاً-2(ب); 17/2025 رابعاً-2(ب)); a resident may take out up to ten ounces of worked gold registered in the passport (Currency Dealing Regulation 2013 art.8).

    Kind
    Other
    Valid from
    2025-08-21
    Primary lawNot recordedOCR

    Legal basis: MMDA 2015, s.32(1)(هـ)

    Researcher's note: The Aug 2025 measure itself is [not-read] (press only). The Customs Disclosure Regulation is not held.

  • US designations under EO 14098: Al Junaid Multi Activities Co (RSF-controlled; gold mining and export since the 2017 takeover of Jebel Amer) on 1 Jun 2023; on 7 Jan 2025 RSF leader Hemedti and UAE companies incl. Al Zumoroud and Al Yaqoot Gold & Jewellers (bought Sudanese gold for the RSF and moved it to Dubai) and Capital Tap. No gold-specific US designations found in 2026 actions (Mar, Apr, Jun 2026).

    Kind
    Sanctions
    Valid from
    2023-06-01
    Official guidance

    Legal basis: Executive Order 14098

  • Dealers in metals or precious stones are "non-financial institutions" under the AML/CFT Act 2014 when they conclude cash transactions above a threshold the Minister sets by decision (s.3): customer due diligence (s.5), record keeping and suspicious-transaction reports to the Financial Information Unit (s.6).

    Kind
    Anti-money laundering
    Threshold
    Cash transactions above the Minister's threshold (not found)
    Primary law

    Legal basis: Anti-Money Laundering and Counter-Terrorist Financing Act 2014, s.3, s.5, s.6

    Researcher's note: The Minister's threshold decision is not held.

  • EU ban on selling, supplying, transferring or exporting mercury (CN 2805 40) and sodium cyanides (CN 2837 11) to Sudan, with related services; humanitarian exceptions; sodium cyanide contracts concluded before 15 Jul 2026 may be executed until 16 Jan 2027.

    Kind
    Sanctions
    Valid from
    2026-07-15
    Primary law

    Legal basis: Council Regulation (EU) 2026/1724, art.1b

Trade flows

  • Pre-war: 2022 exports worth USD 2.29bn to the UAE, small amounts to Italy, Egypt and Turkey.

    Figures: UAE USD 2.29bn (2022)

    SecondaryNot recorded
  • Official exports: 27.96 t / ~USD 1.6bn in 2024; 14.7 t / USD 1.536bn in 2025; gold is over 58% of export value. About 88% went to the UAE in Q1 2025 before the UAE suspension.

    Figures: 2024: 27.96 t / USD 1.59bn (SMRC; CBOS figure 22.92 t / USD 1.57bn); 2025: 14.7 t

    SecondaryNot recorded
  • Declared production: 64.36 t in 2024 (artisanal 53.71 t / 83%; tailings 4.95 t; industrial 5.70 t); 53 t in the first nine months of 2025 in government-held areas; about 70 t for 2025 per exporters. RSF areas add perhaps 10 t (UN Panel estimate for 2024).

    Figures: 2024: 64.36 t; 2025 (9m): 53 t

    SecondaryNot recorded

Where practice departs from the law

What credible sources show happening that the law does not provide for.

  • [conflict] Sharing of the artisanal royalty: the Traditional Gold Mining Regulation 2016 art.8 gives 50% to the national government and 50% to the producing state; MoF Decision 90/2021 gives the producing state and the locality 20% each of "traditional mining revenues" (federal column illegible). The later decision is presumably applied in practice [inferred].

    Primary lawOCR
  • [conflict] Border declaration: the r1 model applied s.36 of the 2009 AML text (money, bearer instruments, metals and valuable gems). The 2014 Act in force (s.31) covers currency and bearer negotiable instruments only; traveller gold is governed by the Currency Dealing Regulation 2013 (ten ounces of worked gold) and the Customs Disclosure Regulation 2015 (not held).

    Primary lawOCR
  • [conflict] Traditional mining contract fees: the MMDA 2015 Schedule sets issue at SDG 7,000 (plus 3,000 application, 40,000 regularisation, 15,000 new contract); the Traditional Gold Mining Regulation 2016 Schedule sets a licence of SDG 3,000 and contract fees from 7,000 (well) to 250,000 (large pit). The Minister may amend Act fees with the Finance Minister's approval (s.20(3)); no amending decision was found.

    Primary lawOCR
  • [conflict] Concession royalty rate: the 2016 Exploitation Regulation (art.15) leaves the rate to the Minister by mineral and location and no gold decision was found, while secondary sources give 5-7% (USGS 2019) or "28.5% as royalties" (Sudan Transparency 2024). The model shows the USGS rate at secondary level.

    SecondaryNot recordedOCR
  • [conflict] Press dated the single-buyer directive 16 Sep 2025 and reported 100% advance payment, a 21-day deposit and local refining for concession exports; Circular 14/2025 is dated 14 Sep 2025, covers only free and tailings gold and leaves concession and small-mining gold to Circular 2/2025, which allows advance payment or confirmed L/C and says nothing on refining.

    Official guidanceNot recordedOCR
  • [conflict] Press (Actum, June 2026) described "June 2026" measures under which CBOS buys 100% of tailings output; the rule is Circular 11/2026 of 13 May 2026 (item 2), and it was cancelled by Circular 18/2026 on 21 Sep 2026.

    Official guidanceNot recordedOCR
  • About 60% of production from SAF-held Northern, River Nile and Red Sea states goes informally to Egypt (100-280 kg a day reported), paid in Egyptian pounds and converted via the Bankak app, while official exports to Egypt were USD 16m (1%) in 2024. Driven by price gaps (Oct 2024: 21-carat USD 85/g in Egypt vs USD 55-60/g in Sudan).

    Figures: >60 t to Egypt since April 2023 (estimate)

    SecondaryNot recorded
  • The legal channel changed repeatedly: 21 Jan 2025 Circulars 2/2025 and 3/2025 (private exports of free and tailings gold); 14 Sep 2025 Circular 14/2025 (CBOS sole buyer and exporter, after Cabinet Decision 132/2025); 5 Nov 2025 Circular 17/2025 (reopening, 10 kg minimum); 13 May 2026 Circulars 11-13/2026 (1 kg minimum, CBOS daily price, 100% CBOS purchase of tailings gold, freer use of proceeds); 21 Sep 2026 Circular 18/2026 (tailings gold may again be sold to exporters and exported). Smuggling historically rises whenever the official price falls below neighbouring markets (press).

    Official guidanceNot recordedOCR

    Researcher's note: Dates official; the smuggling statement is secondary.

  • RSF-area gold (Jebel Amer, Darfur, West Kordofan) leaves via Chad, the Central African Republic, Libya and South Sudan (Raja - Entebbe) to the UAE; RSF looted about 1.3 t of unrefined gold from the Sudan Gold Refinery in May 2023.

    SecondaryNot recorded
  • Most gold leaves outside the official channel: SMRC's director put 2024 smuggling at about 48%; exporters estimate 48-60%; 2025 official exports were 14.7 t against ~70 t produced. Pre-war estimates were 50-80% (Sudan Democracy First Group: 95-100 t produced a year, no more than 30 t reaching the treasury).

    Figures: 48-60% (2024-2025)

    SecondaryNot recorded
  • Both sides use state and military companies: the UK designated three state-owned miners (Omdurman Mining, Ariab, Sudamin) in July 2026 for financing the war; pre-war, senior officials used the Khartoum airport VIP lounge to fly gold out.

    SecondaryNot recorded

What we could not obtain

Documents the research needed and could not get, where they might be, and why.

  • Minister's decision fixing the cash threshold above which dealers in metals and precious stones are covered (AML/CFT Act 2014 s.3); regulations fixing declaration amounts (s.31); the 2010 Act.

    Missing document
    AML/CFT threshold decision and regulations
    Where it might be
    Sudan FIU; Ministry of Finance; MENAFATF mutual evaluation
    Why not obtained
    Not on the CBOS site; no search budget left.
  • Transitional Council of Ministers Decision No. 132 of 2025 (2 Sep 2025) approving the Supreme Committee for Economic Emergencies' recommendations, implemented by Circular 14/2025.

    Missing document
    Council of Ministers Decision 132/2025
    Where it might be
    Council of Ministers secretariat; SUNA
    Why not obtained
    Not published on any site reached.
  • Council of Ministers Decision No. 98 of 2024, read with MoM Decision 45/2024, which presumably designates the competent authority under MMDA 2015 [inferred].

    Missing document
    Council of Ministers Decision 98/2024
    Where it might be
    Ministry of Minerals; SMRC
    Why not obtained
    Not on Minerals Gate.
  • Customs Disclosure Regulation 2015 (amended 2022): the limit on worked gold carried by travellers that customs enforce under Circulars 14/2025 and 17/2025.

    Missing document
    Customs Disclosure Regulation 2015 and 2022 amendment
    Where it might be
    Sudan Customs Authority
    Why not obtained
    Not published online in any source reached.
  • Consolidated English text of Council Regulation (EU) 2023/2147 (Annex I listings of RSF-linked gold companies).

    Missing document
    Regulation (EU) 2023/2147, consolidated, English
    Where it might be
    EUR-Lex (bot challenge); Publications Office cellar 4271e473-908b-11f1-9262-01aa75ed71a1 (English expression number unknown)
    Why not obtained
    The expression fetched (.0006) was Estonian; queued in laws/_work/sd-fetch.tsv.
  • Specimens of the CBOS export approval, MoIT export licence, SSMO certificate, Sudan Gold Refinery certificate, customs declaration and certificate of origin for gold.

    Missing document
    Gold export document specimens
    Where it might be
    Minerals Gate app (mineralsgate.com/app); Sudan Customs; SSMO
    Why not obtained
    Not published; portal requires login.
  • CBOS import-procedures Circular 2026/02 (6 Jan 2026), amended by 12/2026, which sets the import account rules for gold proceeds.

    Missing document
    CBOS Policies Department Circular 2026/02
    Where it might be
    cbos.gov.sd circulars page (after 15 April 2023)
    Why not obtained
    Not queued this session; URL to be taken from the circulars index.
  • The Miscellaneous Amendments (Anti-Smuggling) Act 2019 and the Miscellaneous Amendments (Public Funds) Act 2023, known only as footnotes in the consolidated MMDA text.

    Missing document
    Amending Acts 2019 and 2023
    Where it might be
    Ministry of Justice legislation database
    Why not obtained
    Not on Minerals Gate; no search budget left.
  • Whether the Sudan Gold Refinery is operating after the May 2023 looting, and where export lots are now refined/assayed.

    Why not obtained
    No source read addresses it.
  • The Minister's decision fixing the royalty percentage for gold produced by concession, small-mining and tailings companies (Exploitation Regulation 2016 art.15).

    Missing document
    Minister of Minerals decision on gold royalty rates
    Where it might be
    Ministry of Minerals (Port Sudan); SMRC; Minerals Gate document list
    Why not obtained
    Not among the ten Minerals Gate documents (doc6 covers gypsum, salt and cement only).
  • Instrument and scope of the UAE's August 2025 suspension of trade with Sudan, and whether it still applies.

    Where it might be
    UAE Ministry of Economy / Federal Authority for Identity, Citizenship, Customs and Port Security
    Why not obtained
    Bloomberg and a secondary article blocked or timed out.
  • UK 2023 designations (Al Junaid, Tradive) and EU January 2024 listings of RSF gold companies were not confirmed from the notices.

    Where it might be
    https://www.gov.uk/guidance/sudan-list-of-designations-and-sanctions-notices; EUR-Lex implementing regulations 2024
    Why not obtained
    Guessed URLs returned 404; the GOV.UK notices page was withdrawn on 30 Jan 2026 and later notices moved to "Sudan: list of designations and sanctions notices" (not fetched).
  • VAT or sales tax treatment of gold sales and exports.

    Why not obtained
    No source found within the search budget.

Routes through Sudan

Country pairs

Sources

Every source this country's research cites, with how much of it was read and how.