EGYPT Law and Practice Contributed by: Dina Kamel, Helal El Hossary, Omar Fouda and Kareem Hashem, Zaki Hashem
2.14 Impact of AML and Sanctions Rules CBE (Regulated Fintechs and Vendors Partnering With Banks) Banks and CBE-supervised payment actors are required to comply with the Anti-Money Launder - ing Law (as amended by PM Decree No 3331/2023), including as it pertains to customer due diligence (with heightened focus on higher-risk customers/transac - tions) and prompt reporting of suspicious transac - tions to the Egyptian Money Laundering and Ter - rorist Financing Combating Unit (EMLCU). The CBE approved updated AML/CFT controls for banks on 19 December 2023. FRA (Fintechs Providing NBFS) FRA Board Decree No 161/2024 requires FRA-super - vised NBFS entities to: • maintain an internal AML/CFT manual covering systems and procedures; • perform due diligence in line with EMLCU-issued procedures; and • immediately notify the EMLCU of suspected money laundering/terrorist financing-related transactions (including attempts), using internal escalation channels and systems to detect/report suspicious activity. 2.15 Financial Action Task Force (FATF) Standards Egypt’s AML/CFT framework is designed to align with the FATF Recommendations, and Egypt is assessed through Middle East and North Africa Financial Action Task Force (MENAFATF) mutual evaluations, which assess technical compliance to the FATF 40 Recom - mendations and the FATF methodology. The primary domestic law relevant here is the Anti-Money Laun - dering Law and its Executive Regulations. Egypt is a member of the MENAFATF but not of the FATF. Nevertheless, in line with the FATF, Egypt is expected to implement targeted financial sanctions linked to UN Security Council resolutions (with respect to terrorism and proliferation financing). 2.16 Reverse Solicitation The CBE licensing rules require that institutions out - side Egypt providing PSO/PSP services to residents
obtain a CBE licence. The rules list preconditions such as home authorisation and experience, but do not pro - vide reverse solicitation protection. However, Egyptian citizens may use the services of foreign banks or fin - techs located offshore. In this case, the services are offered offshore. Regarding NBFS, any such services may only be pro - vided by an Egyptian joint stock company. However, the FRA recently – as per Decree No 158 of 2025 – allowed non-resident foreign reinsurance brokers to be registered in the Non-Resident Foreign Reinsur - ance Brokers Register. Insurance and reinsurance companies are not allowed to deal with reinsurance brokers who are not registered in this register. 3. Robo-Advisers 3.1 Requirement for Different Business Models Crypto/e-money activities, including issuance, trad - ing, promoting and operating trading platforms, are prohibited absent a specific CBE board licence (Law 194/2020 Article 206). 3.2 Legacy Players’ Implementation of Solutions Introduced by Robo-Advisers FRA Board Decision No 57 of 2024, issued within the broader framework of the Law Regulating and Devel - oping the Use of Financial Technology in Non‑Banking Financial Activities, sets the rules for the provision of “robo-adviser for investment” services by FRA- licensed portfolio formation and management firms. In practice, legacy players implement robo-adviser solutions through hybrid models that automate risk profiling and suitability assessment, offer model port - folios and use rules-based monitoring and rebalanc - ing triggers, while still retaining human oversight and maintaining governance documentation for algorithm design, review and updates to meet auditability and accountability expectations. 3.3 Issues Relating to Best Execution of Customer Trades Best execution issues arise even where a retail trad - ing app routes orders straight to the exchange and
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