Complicit Dossier

Financial enablers and gatekeepers · commercial bank (majority foreign-owned) · Sudan / UAE (Abu Dhabi branch)

Bank of Khartoum (and Bankak platform)

  • Commercial or professional counterparty
  • Grade A: Official recordStrongest record: official record
  • 2 documented ties · 2 steps from the SAF

Also recorded as: BoK; Bankak

Largest commercial bank; its Bankak app carries transfers for millions of displaced people and public institutions. Chatham House: disruption 'would have severe consequences for the SAF and the public sector'. Its Abu Dhabi branch receives gold export proceeds (STPT) and is a CBOS correspondent. Ordinary banking: no source alleges it finances the military.

Response

No response is recorded. Named parties have not yet been asked for comment.

Records

2

Each record carries its own grade. A grade describes the source for that record, not the actor.

Grade A: Official record

Register check: no Bank of Khartoum licence on the Central Bank of the UAE register

2023-01 to 2026-08

The Central Bank of the UAE's registers of January 2023, October 2025 and August 2026 contain no entry for Bank of Khartoum under banks, wholesale banks, finance companies or representative offices (text search for 'Khartoum': no result in any of the three). The dossier's statement that gold proceeds are deposited in a Bank of Khartoum 'branch in Abu Dhabi' rests on the Sudan Transparency and Policy Tracker; the register does not support the existence of a licensed branch. The bank may operate through correspondent accounts or a non-CBUAE-licensed vehicle; that was not established.

›Research notes

A for the negative register result only. Desk should reword 'Abu Dhabi branch' for Bank of Khartoum unless another official record is found.

  1. 1Central Bank of the UAE: CB Register as of August 2026 · centralbank.ae · Aug 2026
  2. 2CB Register as of October 2025 · centralbank.ae · Oct 2025
  3. 3CB Register as of January 2023 · centralbank.ae · Jan 2023

NamesUAE

Grade B: Corroborated

Bank of Khartoum (and Bankak platform)

2023-04 to present

Largest commercial bank; its Bankak app carries transfers for millions of displaced people and public institutions. Chatham House: disruption 'would have severe consequences for the SAF and the public sector'. Its Abu Dhabi branch receives gold export proceeds (STPT) and is a CBOS correspondent. Ordinary banking: no source alleges it finances the military.

Response
No response located in the sources reviewed.
Sanctions
None found in OFAC SDN / EU / UK lists checked 2026-10-03
  1. 1Chatham House, 'Gold and the war in Sudan' (Soliman & Baldo) · chathamhouse.org · 25 Mar 2025
  2. 2Sudan Transparency and Policy Tracker (STPT), 'Fueling Sudan's War: How Gold Exports and Smuggling Are Prolonging the Conflict' · sudantransparency.org · 16 Oct 2024
  3. 3STPT, 'Sudan's Banking System: Challenges and Opportunities' · sudantransparency.org · Oct 2023
  4. 4Central Bank of Sudan, 'Correspondents Bank' page (undated; accessed 2026-10-03) · cbos.gov.sd · 3 Oct 2026
  5. 5Al Jazeera, 'Drones, gold, and threats: Sudan's war raises regional tensions' · aljazeera.com · 13 May 2025

NamesCentral Bank

1 more record below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see it.

Relationships

2

← means the other party acts on this one; → means this one acts on the other.

Ownership and control · 1

1 more relationship below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see it.

Money · 1

  • To Central Bank of Sudan

    listed correspondent bank (Abu Dhabi branch, AED); list dates from about July 2021 · list created c. July 2021; live 3 Oct 2026

    Grade B: Corroborated

1 more relationship below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see it.

Geography

Tags come from the recorded jurisdiction and from place names in the records. Coordinates on the map are approximate.

Based in
Sudan, United Arab Emirates
Places
Khartoum, Abu Dhabi

Position in the network

Derived by analysing the documented relationships. Nothing in this section is a finding.

Connected to the SAF through official or corroborated records.

›Possible links to investigate · 3