Complicit Dossier

Financial enablers and gatekeepers · central bank · Sudan

Central Bank of Sudan

بنك السودان المركزي / مجلس السيادة

  • Part of the SAF or state-controlled
  • Grade A: Official recordStrongest record: official record
  • 10 documented ties · 1 step from the SAF

Also recorded as: Bank of Sudan; CBoS; Central Bank of Sudan (CBOS); Abu Dhabi Islamic Bank (Abu Dhabi); Bank of Khartoum (Abu Dhabi); El Nilein Bank (Abu Dhabi); Al Salam Bank-Bahrain B.S.C.; Alubaf Arab International Bank (Bahrain); …

Banks listed by CBOS as its correspondents (AED, EUR, GBP, SAR, TRY, USD). Provides the Port Sudan authorities' access to international payments. Correspondent banking with a central bank is ordinary, lawful commerce; listing implies no wrongdoing.

Their response

  • No right-of-reply from SAF/Bank of Sudan recorded; RSF refused to answer the researchers on its own finances.
  • n/a
  • Not applicable (official statistics).

Records

11

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

Grade A: Official record

Central Bank of Sudan correspondent banks (official list)

page undated; live on 2026-10-03

Banks listed by CBOS as its correspondents (AED, EUR, GBP, SAR, TRY, USD). Provides the Port Sudan authorities' access to international payments. Correspondent banking with a central bank is ordinary, lawful commerce; listing implies no wrongdoing.

Response
No response located in the sources reviewed.
Sanctions
None found in OFAC SDN / EU / UK lists checked 2026-10-03
Grade A: Official record

Central Bank of Sudan - official list of licensed banks, exchange and transfer companies

Reference list only. A licence from the Port Sudan central bank is ordinary regulated business and is not evidence of support for the SAF. It shows which foreign state-linked banks keep a licensed presence under the SAF-led authorities, and that the RSF-linked Gulf (Al Khaleej) Bank is still listed.

Why this grade
A (official list)
›Research notes

Sovereign-fund link: Ziraat Katilim belongs to Ziraat Finance Group, which Wikipedia says is owned by the Turkey Wealth Fund (tertiary source). No ONB shareholder list, board list or annual report could be reached (onb-sd.com and kse.com.sd do not connect); ONB board and post-2019 shareholding remain a gap. English transliterations of exchange-company names are mine.

Grade A: Official record

Central Bank of Sudan - correspondent list unchanged on 3 October 2026

as displayed 3 Oct 2026

The central bank's correspondent page was read again on 3 October 2026. It lists the same nine institutions as before: Abu Dhabi Islamic Bank (Abu Dhabi); Al Salam Bank-Bahrain; Bank of Khartoum, Abu Dhabi; El Nilein Bank, Abu Dhabi; Alubaf Arab International Bank (Bahrain); Aktif Yatirim Bankasi (Istanbul); Bank Al Etihad (Amman); Bank of Beirut; British Arab Commercial Bank (London). The page is still undated and pass 2 dated its creation to about July 2021. No bank on the list has confirmed or denied a current relationship in any source found.

Response
None of the nine banks has commented publicly, as far as found.
›Research notes

A is for 'this is what the official page shows'. It is not confirmation that the relationships are live. Listing implies no wrongdoing; each bank should be asked before publication.

Grade A: Official record

Official record of foreign loans and grants: no bilateral state money in 2025

2025 - Q1 2026

The central bank's Economic & Financial Statistics Review for January-March 2026 (Table 2, source: Ministry of Finance) records US$1,204.7m of loan and grant drawings in 2025. US$617.1m was commodity grants; US$585.7m came from international organisations, almost all as grants (UN agencies 471.5, World Bank 65.7, African Development Bank 30.0, IFAD 7.4 grant plus 7.4 loan, donor fund 3.1); US$2.0m came from the Arab Fund (half grant, half loan). Every bilateral line is zero: Saudi Fund, Qatar, Oman, UAE, Kuwait, Russia, China, Turkey, Iran, India. The first quarter of 2026 shows zero across the table (preliminary). Loan repayments were US$31.9m in 2025, to the World Bank group and the African Development Bank only.

Response
Not applicable (official statistics).
›Research notes

The table covers what passes through the Ministry of Finance. Off-budget transfers, military aid in kind, supplier credit and third-party payment for arms (as reported for Saudi Arabia and Qatar in the arms thread) would not appear in it. The same review shows no change in central-bank external loan liabilities that could be tied to a state deposit.

Grade A: Official record

Official trade data, Q1 2026: gold US$370.7m; UAE almost gone as a destination

2024 - Q1 2026

The same review gives gold exports of US$1,536.3m in 2025 and US$370.7m in January-March 2026. By destination (all goods): UAE US$1,664.8m in 2024, US$926.2m in 2025 and US$7.7m in Q1 2026; COMESA countries (which include Egypt) US$289.5m, US$759.4m and US$319.3m; Saudi Arabia US$437.4m, US$409.7m and US$136.6m; 'other Arab countries' US$62.1m, US$180.6m and US$121.7m. The review does not break gold out by destination.

Response
Not applicable (official statistics).
›Research notes

The New Arab reports US$225m of gold exports to Egypt in Q1 2026, which fits the COMESA line. 'Other Arab countries' would include Oman and Qatar. Data are marked amended (2025) and preliminary (2026).

Grade A: Official record

Central bank's wartime correspondent and cooperation deals: Oman, Azerbaijan, Qatar, Pakistan (2026)

2026-01 to 2026-06

Official posts record: (1) Feb 2026 - the governor told the prime minister she had signed a memorandum with the Central Bank of Oman and that 'correspondent relations were created between the Central Bank of Oman and a number of Sudanese banks'; Omani institutions agreed to invest in energy, mining, transport and ports. (2) 17 Jun 2026, Baku - memorandum on banking cooperation with the Central Bank of Azerbaijan, a 'general framework to develop correspondent banking relations and open branches and windows' of commercial banks. (3) 28 Jan 2026, Doha - the finance minister and governor met the Qatar Central Bank governor and agreed to 'update the agreements concluded between the two central banks'. (4) 17 Apr 2026, Washington - the governor and the State Bank of Pakistan governor discussed correspondent relations between commercial banks 'directly or indirectly'.

Why this grade
Grade A is for the fact that the page announced this. The page was identified as official by its name and content; no verification badge was detected.
Response
No statement from the foreign central banks looked up.
Sanctions
CBOS not designated.
›Research notes

Source alignment: official SAF-side channel. Grade applies to the fact that the announcement was made, not to its content. Which Sudanese banks gained Omani correspondents is not stated. The timing matches Omdurman National Bank's February 2026 statement about 'three correspondent banking relationships in a single country', but no source names Oman for that bank: a lead, not a finding.

Grade B: Corroborated

Central Bank of Sudan foreign-exchange and AML enforcement, 2026

2026-01 to 2026-09

Context, not support. January 2026: new transfer rules (sanctions screening, unified customer reference, reporting to the Financial Intelligence Unit; daily transfer cap raised to SDG 3m). July 2026: unnamed commercial banks penalised and bankers suspended from export/import transactions after inspections found FX violations. August 2026: customer-data (KYC) update deadline linked to the SUDAPASS digital ID, later extended to 31 Dec 2026. September 2026: two currency traders sentenced to two years and SDG 15m fines by Haj Youssef Criminal Court; pound at SDG 7,300 per US$ on the parallel market. The central bank injected about AED 400m into the banking system from 23 June 2026.

Response
n/a
›Research notes

No exchange company was named in any crackdown report found. No source found links a named Sudanese exchange house to the army. Dabanga items on forex-dealer arrests returned by search could not be dated and appear to be from 2018; not used.

  1. 1Sudan Tribune: Bank of Sudan tightens transfer rules to combat money laundering · sudantribune.com · 7 Jan 2026read via summary
  2. 2Sudan Tribune: Sudan central bank penalizes banks over foreign exchange violations · sudantribune.com · 12 Jul 2026read via summary
  3. 3Sudan Tribune: Sudan's pound hits record low amid currency crisis · sudantribune.com · 5 Sep 2026read via summary
  4. 4STPT, Sudan Economic Monitor #2 · sudantransparency.org · 14 Sep 2026
Grade B: Corroborated

Central Bank of Sudan correspondent-bank list - dating

Page created c. 15-16 July 2021; still live 3 Oct 2026

The undated page listing nine correspondent banks is Drupal node 22309/22310 on cbos.gov.sd. Neighbouring nodes are dated daily exchange-rate posts: node 22305 is 15 July 2021 and node 22311 is 16 July 2021. The page was therefore created on about 15-16 July 2021, before the October 2021 coup and the war. It has not been shown to reflect wartime relationships. One listed bank's group has since withdrawn from Sudan (Abu Dhabi Islamic Bank's local branch, liquidated June 2026).

Response
n/a
›Research notes

Creation date is inferred from sequential node IDs; the date of the last edit cannot be seen. web.archive.org is blocked from this environment (both the fetch tool and curl), so no archived snapshot was checked. A human should confirm with the Wayback Machine. The first-pass grade of A for this list should be read as 'official but 2021-vintage'.

Grade C: Single source

Central Bank of Sudan (CBOS)

2023-04 to present

Issues gold export certificates against advance payment; publishes the Foreign Trade Statistical Digest. STPT (citing a CBOS contact) reports most gold revenue was directed to the war effort, 'primarily for the import of weapons, ammunition, and drones', with government funds at CBOS 'handled by military leaders in the Sovereignty Council, with economic matters under General Ibrahim Jaber'. Dec 2024 currency replacement confined to six SAF-held states.

Why this grade
Regraded from B: one report citing one central-bank contact.
Response
No response located in the sources reviewed.
Sanctions
None found in OFAC SDN / EU / UK lists checked 2026-10-03
Grade C: Single source

Central Bank of Sudan / Sovereignty Council – gold sales to fuel importers

STPT investigative report (Jan 2025), citing unnamed Bank of Sudan sources, says gold sales at the central bank are often made by Sovereignty Council decisions, that the SAF commander personally intervenes in gold sales for the benefit of (fuel) importers, and that importers enjoy major privileges from SAF.

Response
No right-of-reply from SAF/Bank of Sudan recorded; RSF refused to answer the researchers on its own finances.
Source
Sudan Transparency and Policy Tracker (independent Sudanese policy/research group)
Grade D: Unverified lead

Central Bank of Sudan – 'rose to support the war effort' (pro-army columnist)

A pro-army columnist, reposted 12 Jan 2024, wrote that the central bank kept its cohesion and 'rose to support the war effort by quickly reorganising the export sector' and preserved its foreign correspondents.

Fact-check
None.
Source
pro-SAF (unofficial news-aggregator channel 'السودان', ~212K subscribers; reposts official and partisan items)

5 more records below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see them.

3 more records at grade C (single source) or D (unverified lead). Change “Evidence shown” to see them.

1 more record at grade D (unverified lead). Change “Evidence shown” to see it.

Checked against the document

1

Statements compared with the wording of the primary document.

  • “The Port Sudan authorities depend mainly on the Abu Dhabi branch of the state-owned El-Nilein Bank to manage international transactions, a critical asset considering Sudan’s post-coup international isolation.”

    Chatham House, "Gold and the war in Sudan"Mar 2025verified substance wording differs

    Correction: finance.json #25 ends the quotation with a full stop after "international transactions"; the sentence continues. Minor.

Relationships

11

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

Ownership and control · 3

3 more relationships below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see them.

Money · 8

6 more relationships below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see them.

3 more relationships at grade C (single source) or D (unverified lead). Change “Evidence shown” to see them.

Weapons, sites and other subjects

3

Recorded links to things, places, events and authorities rather than to organisations or people.

  • From Sudanese gold exporters (SAF-held areas)

    deposit export proceeds at · 2023-10 to 2024-01

    Grade C: Single source
  • From Sudanese gold exporters (SAF-held areas)

    deposit export proceeds at Abu Dhabi branch of · 2023-10 to 2024-01

    Grade C: Single source
  • To Exchange companies seized by the Empowerment Removal Committee (five) and the central bank's authorised list

    lists as authorised exchange bureaus (undated page; name match by transliteration) · undated

    Grade C: Single source

Dated events

5
  1. Global Witness reports that UAE refiner Kaloti bought gold from Sudan's central bank between 2012 and 2019; Kaloti denies sourcing conflict gold. globalwitness.org

    Grade C: Single source
  2. Reuters: most government transactions still go through El Nilein Bank's Abu Dhabi branch; alternative gold markets in Qatar, Oman, Egypt and Saudi Arabia had not yet worked out. al-monitor.com

    Grade B: Corroborated
  3. Central bank governor reports a memorandum with the Central Bank of Oman and correspondent relations for several Sudanese banks. facebook.com

    Grade A: Official record
  4. Central Bank of Sudan signs a banking memorandum with the Central Bank of Azerbaijan in Baku. facebook.com

    Grade A: Official record
  5. STPT paper on the shift of gold exports from the UAE to Egypt estimates 55 tonnes left Sudan off the books in 2025. sudantransparency.org

    Grade B: Corroborated

3 more events below grade A (corroborated, single-source or unverified). Change “Evidence shown” to see them.

1 more event at grade C (single source) or D (unverified lead). 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
Also named
United Arab Emirates (8), Oman (8), Qatar (6), Türkiye (3), Saudi Arabia (3), Azerbaijan (3), Egypt (2), Pakistan (2)
Places
Port Sudan, Khartoum, Omdurman, Abu Dhabi, Istanbul, Doha, Baku, Washington

Position in the network

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

Still connected to the SAF when only official records are counted. Ranks 19 in the file for how often it sits on the shortest documented chain between two others.

›Possible links to investigate · 7
  • United Arab Emirates (gold market and banking channel) hypothesis

    No direct tie is documented. Basis: shared intermediary; cited in the same source (via El Nilein Bank (Abu Dhabi branch)).

  • MTN Sudan hypothesis

    No direct tie is documented. Basis: named in the other actor's record; cited in the same source.

  • Sudan Gold Refinery hypothesis

    No direct tie is documented. Basis: named in the other actor's record; cited in the same source.

  • Türkiye hypothesis

    No direct tie is documented. Basis: named in the other actor's record; cited in the same source.

  • Egypt hypothesis

    No direct tie is documented. Basis: cited in the same source.

  • China hypothesis

    No direct tie is documented. Basis: named in the other actor's record.

  • Sudamin Company Limited hypothesis

    No direct tie is documented. Basis: named in the other actor's record.