Introduction
Residents of Sudan and South Sudan face an almost universal barrier when attempting to open accounts with international Forex brokers. While a handful of offshore or less-regulated brokers may accept clients from these nations, the vast majority of reputable, well-regulated Forex platforms explicitly exclude Sudanese and South Sudanese nationals from their services. This exclusion is not arbitrary discrimination but rather the result of a complex web of international sanctions, anti-money laundering (AML) regulations, counter-terrorism financing (CTF) requirements, and the practical realities of correspondent banking relationships.
This article examines the multifaceted reasons behind this systematic exclusion, tracing the historical development of sanctions against both nations, explaining the regulatory framework that governs international financial services, and analyzing why even the partial lifting of sanctions has failed to reintegrate these countries into the global financial system.
The historical context: US sanctions against Sudan
The financial isolation of Sudan began in earnest in 1997, when the United States imposed comprehensive economic, trade, and financial sanctions through Executive Order 13067. These sanctions were implemented in response to Sudan's alleged support for international terrorism, its destabilization of neighboring governments, and human rights violations. The sanctions prohibited virtually all commercial and financial transactions between US persons and Sudan, including the Government of Sudan.
The sanctions regime was further strengthened in 2006 through Executive Order 13412, which imposed additional restrictions related to the conflict in Darfur. Sudan was also designated as a State Sponsor of Terrorism in 1993, a designation that carried additional penalties including restrictions on US foreign assistance, a ban on defense exports and sales, and various financial restrictions.
From 1997 to 2017, Sudan endured two decades of comprehensive US sanctions that effectively cut the country off from the dollar-denominated global financial system. While some sanctions were lifted in October 2017, and Sudan was removed from the State Sponsors of Terrorism list in December 2020, the legacy of these sanctions continues to shape how financial institutions treat Sudanese clients.
South Sudan: a separate sanctions regime
South Sudan, which gained independence from Sudan in 2011, operates under an entirely separate US sanctions program. Executive Order 13664, signed in April 2014, established targeted sanctions against individuals and entities threatening the peace, security, or stability of South Sudan. Unlike the now-largely-revoked Sudan sanctions, the South Sudan sanctions remain fully in force.
The US Treasury's Office of Foreign Assets Control (OFAC) continues to actively designate individuals and entities under this program. As recently as January 2024, OFAC sanctioned entities funding both the Sudanese Armed Forces (SAF) and the Rapid Support Forces (RSF), the two main belligerent parties in the ongoing Sudanese civil war. This demonstrates that sanctions activity in the region remains dynamic and evolving.
For Forex brokers, the distinction between Sudan and South Sudan matters less than the overall risk profile. Both countries present significant compliance challenges, and the administrative burden of distinguishing between nationals of the two countries — particularly given the historical ties and ongoing conflict — makes blanket exclusion the simpler and safer approach.
The FATF grey list: elevated AML/CFT concerns
The Financial Action Task Force (FATF), the global watchdog for money laundering and terrorism financing, maintains two lists of jurisdictions with strategic deficiencies in their anti-money laundering and counter-terrorism financing (AML/CFT) frameworks. South Sudan has been on the FATF's "grey list" (officially titled "Jurisdictions under Increased Monitoring") since June 2021.
According to the FATF's October 2025 assessment, South Sudan has made limited progress across its action plan, with all deadlines now expired and significant work remaining. The FATF has identified specific deficiencies including: inadequate risk-based supervision of financial institutions; lack of a comprehensive legal framework for beneficial ownership information; a non-functioning Financial Intelligence Unit (FIU); failure to implement targeted financial sanctions for terrorism and weapons of mass destruction proliferation financing; and insufficient supervision of non-profit organizations at risk of terrorism financing abuse.
When a country appears on the FATF grey list, financial institutions worldwide are required to apply enhanced due diligence (EDD) measures to business relationships and transactions involving that jurisdiction. This means Forex brokers accepting clients from South Sudan would need to implement additional verification procedures, ongoing monitoring, and risk assessments that significantly increase operational costs. For many brokers, the cost-benefit analysis simply does not support accepting these clients.
The OFAC compliance imperative
Even for Forex brokers based outside the United States, OFAC compliance is often non-negotiable. The US dollar's dominance in global Forex trading means that virtually all significant brokers must maintain correspondent banking relationships with US financial institutions. These relationships come with strict requirements to comply with US sanctions regulations.
The consequences of OFAC violations can be severe. The 2014 settlement with BNP Paribas, which resulted in an $8.9 billion fine, remains a watershed moment for the financial industry. BNP Paribas had served as the primary correspondent bank for Sudanese government institutions and facilitated transactions that violated US sanctions. The bank's Geneva branch had processed a quarter of all Sudanese exports and a fifth of all imports. This case demonstrated that foreign banks with no physical US presence could still face massive penalties for sanctions violations.
Following the BNP Paribas settlement, correspondent banks globally reassessed their exposure to high-risk jurisdictions. Many banks decided that the compliance costs and potential liability simply weren't worth maintaining relationships with clients connected to Sudan or South Sudan. This phenomenon, known as "de-risking," has left both countries largely cut off from international banking channels.
The collapse of correspondent banking
Correspondent banking relationships are the backbone of international financial transactions. These arrangements allow banks in one country to access financial services and conduct transactions in another country through a relationship with a local bank. For countries like Sudan and South Sudan, the loss of correspondent banking relationships has been catastrophic.
Since mid-2014, correspondent banks have systematically closed accounts of clients in Sudan and have refused to conduct financial transactions involving Sudanese individuals, businesses, or institutions — even those holding valid OFAC licenses. The relatively low volume and value of business from these countries, combined with tepid interest from international investors, has made it easier for foreign banks to simply close the door rather than incur the compliance costs associated with maintaining these relationships.
For Forex brokers, the absence of reliable correspondent banking channels to Sudan and South Sudan creates a fundamental operational problem. Even if a broker wished to accept clients from these countries, processing deposits and withdrawals would be extremely difficult or impossible without functioning banking relationships. The practical infrastructure for serving these clients simply does not exist.
KYC and AML compliance challenges
Know Your Customer (KYC) requirements mandate that Forex brokers verify the identity of their clients and understand their background and transactional behavior. For clients from Sudan and South Sudan, these verification processes face multiple obstacles.
First, the ongoing conflict and governmental instability in Sudan has disrupted the issuance and verification of identity documents. Brokers rely on document verification services that cross-reference submitted documents against government databases and known document formats. In countries experiencing active conflict, these systems may be compromised, outdated, or simply inaccessible.
Second, South Sudan's weak AML/CFT framework, as identified by the FATF, means that domestic financial institutions may not be conducting adequate customer due diligence. When a Forex broker cannot rely on the home country's financial system to have performed basic screening, it must conduct more extensive verification independently — a costly and time-consuming process.
Third, both countries face elevated risks of politically exposed persons (PEPs), individuals subject to sanctions, and individuals connected to armed groups or terrorist organizations. Screening against sanctions lists, PEP databases, and adverse media becomes more complex and higher-stakes when dealing with nationals from conflict zones.
Regulatory requirements from multiple jurisdictions
Reputable Forex brokers typically hold licenses from one or more respected regulatory bodies such as the UK's Financial Conduct Authority (FCA), the Australian Securities and Investments Commission (ASIC), the Cyprus Securities and Exchange Commission (CySEC), or similar agencies. These regulators require their licensees to implement robust AML/CFT programs and to avoid relationships that pose unacceptable compliance risks.
The European Union maintains its own list of high-risk third countries with strategic deficiencies in their AML/CFT regimes. Financial institutions within the EU are required to apply enhanced due diligence to transactions involving these countries. Many individual countries maintain additional national lists and restrictions.
For a broker operating in multiple jurisdictions, the compliance burden compounds. A broker licensed in Cyprus, for example, must comply with CySEC regulations, EU directives, and also ensure that its operations don't violate US sanctions if it maintains any US dollar operations or correspondent relationships. The safest approach for multi-jurisdictional brokers is often to apply the strictest applicable standard globally — which typically means excluding high-risk countries entirely.
The ongoing Sudanese civil war
The civil war that erupted in Sudan in April 2023 between the Sudanese Armed Forces and the Rapid Support Forces has dramatically worsened the country's financial isolation. The conflict has displaced millions, destroyed critical infrastructure, and led to new rounds of targeted sanctions against individuals and entities on both sides of the fighting.
The United Nations Security Council extended sanctions against Sudan in September 2024, including asset freezes, travel bans, and an arms embargo, with these measures set to continue through at least September 2025. International bodies have documented systematic human rights abuses by both the SAF and RSF, further cementing Sudan's status as a pariah state in international financial circles.
For Forex brokers, the active conflict creates additional risks including potential sanctions evasion by parties to the conflict, the possibility of funds being diverted to military purposes, and reputational risks associated with any perceived support for either side. The prudent business decision is to avoid exposure to Sudanese clients entirely until the conflict is resolved and stability returns.
South Sudan's unique challenges
South Sudan presents its own distinct challenges that compound the general regional concerns. The country has one of the world's most volatile currency environments, with the South Sudanese pound losing nearly 40% of its value in twelve months through November 2025. Inflation reached 107.9% in September 2025 alone. The parallel market premium — the gap between official exchange rates and black market rates — hit 30.8% in June 2025.
South Sudan's economy is overwhelmingly dependent on oil exports, which account for over 90% of foreign exchange earnings. When the civil war in neighboring Sudan disrupted pipeline operations in February 2024, oil exports stopped completely for a year, devastating the economy and further destabilizing the financial system.
The country lacks dedicated Forex regulatory oversight. While the Bank of South Sudan handles monetary policy and banking supervision, there is no specialized Forex regulator, no licensing regime for Forex brokers, and no enforcement standards. Foreign brokers operating in South Sudan do so without local oversight, which creates additional compliance uncertainty for brokers considering whether to accept South Sudanese clients.
Payment processing barriers
Beyond regulatory restrictions, practical payment processing barriers prevent Sudanese and South Sudanese residents from accessing international Forex platforms. Major credit card processors and payment service providers have their own compliance programs and country restrictions that often mirror or exceed regulatory requirements.
Bank wire transfers from Sudan and South Sudan face extensive scrutiny and delays. Correspondent banks often reject transactions involving these countries outright. E-wallet services like PayPal have historically restricted service to Sudan. Even cryptocurrency, which some view as a potential workaround for banking restrictions, faces its own compliance requirements at the point where crypto assets are converted to fiat currency or vice versa.
The combination of regulatory restrictions and payment processing barriers creates a practical reality in which Sudanese and South Sudanese residents simply cannot access the funding mechanisms that Forex trading requires, regardless of any broker's theoretical willingness to accept them as clients.
The risk-reward calculation for brokers
From a Forex broker's perspective, the decision to exclude Sudanese and South Sudanese residents represents a straightforward risk-reward calculation. The potential revenue from clients in these countries is minimal given the small, impoverished population with limited access to foreign currency. Meanwhile, the risks are substantial: potential sanctions violations carrying multimillion-dollar fines, loss of banking relationships, loss of regulatory licenses, reputational damage, and increased compliance costs.
Even sophisticated brokers with robust compliance programs generally conclude that the costs of implementing the enhanced due diligence, transaction monitoring, and ongoing surveillance required for high-risk clients exceeds any reasonable profit expectation. The economics simply don't work, especially when there are millions of potential clients in lower-risk jurisdictions to pursue instead.
Limited options for affected residents
Residents of Sudan and South Sudan seeking to participate in Forex trading have extremely limited options. Some offshore or unregulated brokers may accept clients from these countries, but such brokers often lack the investor protections, fund segregation, and regulatory oversight that legitimate platforms provide. Trading with unregulated brokers exposes clients to risks of fraud, manipulation, and difficulty recovering funds.
Some individuals attempt to circumvent restrictions by establishing residency in third countries or using virtual private networks (VPNs) to mask their location. However, such practices violate the terms of service of reputable brokers and can result in account termination, frozen funds, and other consequences. Brokers increasingly employ sophisticated geolocation and identity verification technologies to detect such evasion attempts.
Conclusion
The exclusion of Sudanese and South Sudanese residents from international Forex trading platforms reflects the cumulative impact of decades of sanctions, regulatory requirements, correspondent banking de-risking, and practical payment processing barriers. While some sanctions against Sudan have been lifted, the legacy of financial isolation persists. South Sudan remains under active US sanctions and on the FATF grey list, with no near-term prospect of improved financial access.
The ongoing civil war in Sudan and the continued instability in South Sudan suggest that the current situation is unlikely to change soon. Until both countries achieve political stability, implement robust AML/CFT frameworks satisfactory to international standards, and rebuild correspondent banking relationships with the global financial system, their residents will continue to face systematic exclusion from legitimate international Forex trading platforms.
For Forex brokers, the exclusion of these countries represents not discrimination but prudent risk management in the face of substantial regulatory, operational, and reputational risks. The path to financial inclusion for Sudan and South Sudan runs through political resolution, institutional reform, and the slow rebuilding of international trust — a process that will take years, if not decades, to complete.
