Complicit Dossier

State-owned and co-opted commercial entities · Free-zone operator · Sudan

Sudanese Free Zones and Markets Company

السودانية للمناطق والأسواق الحرة

  • Context only
  • Grade C: Single sourceStrongest record: single source
  • 3 documented ties · 2 steps from the SAF

Not shown to be military-controlled. Listed because the network analysis flagged it; the evidence does not support treating it as a SAF company.

Reg. 8323, sector 'Investment'. Only historical shareholder rows exist: 'The Islamic Bank of Dubai' 74.28%, one natural person 24.7%, Ministry of Finance 0.74%, Omdurman National Bank 0.25%, and near-zero holdings for Sheikan Insurance, Bank of Khartoum, the National Pension Fund, the Sudanese Development Foundation and a body labelled 'Founder of the Popular Armed Forces'. The dataset shows no current shareholder. In August 2026 the secretary-general of the armed forces' social security fund told the industry minister the fund supports 'free zone development projects' (state news agency); that statement does not name this company.

Response

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

Records

1

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

Grade C: Single source

Shareholders in the inventory

2019-2021 inventory (historical rows older)

Reg. 8323, sector 'Investment'. Only historical shareholder rows exist: 'The Islamic Bank of Dubai' 74.28%, one natural person 24.7%, Ministry of Finance 0.74%, Omdurman National Bank 0.25%, and near-zero holdings for Sheikan Insurance, Bank of Khartoum, the National Pension Fund, the Sudanese Development Foundation and a body labelled 'Founder of the Popular Armed Forces'. The dataset shows no current shareholder. In August 2026 the secretary-general of the armed forces' social security fund told the industry minister the fund supports 'free zone development projects' (state news agency); that statement does not name this company.

Response
No response sought by this desk; none found in the sources read.
›Research notes

Single dataset: C4ADS's relay of the Sudanese Ministry of Finance inventory (2019-2021). 'Historical' rows are older filings; 'current' means current in that snapshot, not in 2026. English labels are machine translations. The 74.28% figure for a Dubai bank could not be corroborated; two searches found no shareholder list (the ESCWA archive page returned HTTP 403). The military-linked holdings are fractions of one per cent. Its high network score comes from many tiny shareholders, not from control.

  1. 1C4ADS, Sudan State-Controlled Enterprise Explorer (Ministry of Finance inventory and Regime Dismantlement Committee records, 2019-2021 snapshot; machine-translated labels). Local extract: raw/c4ads_sce_nodes.json, raw/c4ads_sce_edges.json · sudansce.c4ads.org · 2022
  2. 2Sudan News Agency via allAfrica, Industry Minister discusses reconstruction and investment projects with Armed Forces Social Security Fund · allafrica.com · 3 Aug 2026

NamesONBBank of Khartoum

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

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

Relationships

3

← 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.

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 (2)
Places
Khartoum, Omdurman, Dubai

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. Ranks 23 in the file for how often it sits on the shortest documented chain between two others.

›Possible links to investigate · 2