A state government minister recently told a national newspaper that his state alone holds 9.9 million head of cattle. For an international investor scanning African livestock markets for scale, that single figure should stop the scroll. But for anyone who has actually tried to close a deal in Sudan's agricultural sector, the number raises a harder question: scale of what, exactly, and secured how?

That is the real problem facing foreign investment in Sudan's agriculture and livestock sectors today. The resource base is not in doubt — White Nile State's own minister put dairy cattle productivity at two to three litres per head, a fraction of commercially viable yields, and pointed to weak cold-chain and processing infrastructure as the binding constraint, not herd size. For an investor, that gap between raw resource and realisable value is exactly where deals get made — and exactly where they get lost, if the underlying land tenure, licensing, and market-access framework is not properly diligenced before capital moves.

Reading a livestock story like this as a purely agronomic one is the mistake. Herd counts, fattening cycles and quarantine capacity are operational facts. Whether an investor can actually own, lease, finance, and eventually export against that resource is a legal fact — governed by a different, less visible framework that rarely appears in the press coverage.

What Sudan's investment law actually offers

Sudan's Investment Encouragement Act 2021 is the relevant starting point. It replaced the 2013 Act and requires foreign investors to deposit a minimum of USD 250,000 to obtain an investment licence, while formally guaranteeing equal treatment between Sudanese and non-Sudanese investors and protection against uncompensated expropriation. On paper, agriculture and livestock sit squarely within the Act's encouraged sectors, alongside energy, mining and infrastructure.

The gap is not in the headline guarantees. It is in what happens beneath them — specifically, in how land is allocated to the investment project in the first place, and what happens to the customary users who were on that land before the project arrived.

Where the framework thins out

This is the critical piece too many feasibility studies skip. Sudan's land-tenure reforms since the 1990s were explicitly designed to attract exactly this kind of large-scale agricultural investment, by shifting leasing authority from federal to state government and — as the peer-reviewed literature documents — removing the ability of prior communal land users to bring a claim against the government or a registered investment landholder once land has been allocated. Research tracking Landsat imagery over the Butana rangeland found that large-scale mechanised agriculture expanded from 2.5% of the area in 2000 to 17.6% by 2014, converting communal pastoral land into commercial holdings at a pace the legal framework was built to accommodate but never designed to reconcile with existing land rights. The result, documented across multiple studies of Sudan's rangelands, has been recurring land-based conflict rather than the broad-based value creation the investment framework was meant to unlock. For a foreign investor, that history is not background colour — it is precisely the kind of legacy dispute risk that can surface years into a project, attached to land that looked clean on paper at signing.

How Sudan compares

Set against a regional comparator, the gap becomes concrete. South Sudan's Investment Promotion Act explicitly names livestock and dairy development — and downstream value addition such as abattoirs, meat and fish processing — as a designated investment priority sector directly in the statute, alongside detailed regulations governing land registration and technical planning before allotment to an investor. Sudan's Investment Encouragement Act encourages the same sectors in principle but leaves the leasehold and title-security mechanics largely to case-by-case state-level allocation, layered on top of the historically contested tenure system described above. The commercial implication is straightforward: an investor structuring a livestock, feedlot, or cold-chain deal in Sudan should not treat the Investment Encouragement Act's protections as self-executing. Title diligence at the state and local level, and a clearly seated dispute-resolution clause — ICC or LCIA arbitration rather than reliance on domestic land litigation alone — are not optional extras. They are the mechanism that actually stands behind the statutory guarantee.

The proof is in what already works

None of this makes Sudan uninvestable — it makes it a jurisdiction where the deal structure carries more of the risk allocation than the statute does, and where experienced Sudan counsel earns its fee. SCLO has been ranked by Chambers Global for Sudan general business law continuously since 2013, and has advised directly on the IFAD Livestock Marketing Project's public-private partnership structuring and regulatory compliance — the kind of livestock-sector mandate that requires reconciling investment law, land allocation, and export licensing in practice, not just on paper. That sits alongside SCLO's work advising the World Bank and Castalia on Sudan's national PPP legal framework, the same regulatory architecture that governs how infrastructure like quarantine stations and cold-chain facilities gets financed and structured. That is the combination — livestock-specific transactional experience plus the underlying PPP framework — that closes the gap between a resource story and a bankable one.

Why foreign investment in Sudan can't wait for full stability

The macro picture reinforces the urgency of getting the structuring right rather than waiting it out. Sudan's economy contracted 29.4% in 2023 and a further 14% in 2024 before a modest 3.1% rebound in 2025, according to the World Bank — while the African Development Bank puts the 2025 poverty rate at 71%, up from 36% pre-war. Agriculture and livestock, sectors the World Bank estimates support livelihoods for roughly two-thirds of Sudan's population, are the fastest realistic channel for recovery precisely because the underlying resource — millions of head of cattle, arable land, water access — was never destroyed the way urban infrastructure was. The investment thesis is not speculative: it is a bet on converting an already-existing resource base into export-grade value chains, in a market still ranked 171st of 190 for ease of doing business, where the legal spadework is what separates a viable entry from a stranded one.

Before that resource base is recapitalised at scale, the investors who move first need a legal partner who has already mapped where the statutory guarantees end and the practical diligence begins. If a livestock, agribusiness, or agri-processing opportunity in Sudan is on your desk, SCLO's team in Khartoum and Cardiff can run the land-tenure and regulatory diligence before you commit capital, not after. Contact us directly to start that conversation.

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