EGYPT Law and Practice Contributed by: Dina Kamel, Helal El Hossary, Omar Fouda and Kareem Hashem, Zaki Hashem
2-3 (d)). PSPs that are not PSOs must use authorised systems and stay within their licensed scope. 5.2 Regulation of Cross-Border Payments and Remittances Cross-border payments and remittances in Egypt are primarily under CBE oversight, and are conduct - ed through banks and CBE-licensed money trans - fer companies. Money transfer companies require a CBE licence under the Central Bank and Banking System Law (Article 209), with minimum capital and a CBE-registered auditor, and cross-border transfers are expected to be routed through licensed chan - nels under the foreign exchange perimeter.The main regulatory focus areas are licensing and operational controls, foreign exchange compliance and FX fraud, and AML/CFT and sanctions compliance – including risk-based customer due diligence and suspicious transaction reporting to the EMLCU. Fintechs provid - ing remittance-like payment services are under the CBE payments licensing and oversight framework. 6. Marketplaces, Exchanges and Trading Platforms 6.1 Permissible Trading Platforms The following are permissible. • Regulated securities exchanges (public market): Trading in listed securities occurs on a licensed stock exchange under the Capital Market Law. Trades outside the exchange are void, with execu - tion required through a licensed securities com - pany (the Capital Markets Law, Articles 15–18). • Exchange-registered transactions for non-listed securities (OTC): Egyptian rules provide for unlisted securities to be registered with an exchange rather than traded in an unregulated OTC market. The FRA issues rules governing the trading and owner - ship transfer of unlisted securities (the Executive Regulations of the Capital Market Law). • Private exchanges and specialised venues (alterna - tive trading systems (ATSs): The Executive Regula - tions allow “private exchanges” operating as joint stock companies, with trading limited to speci - fied securities subject to FRA board approval and
licensing, and with compliance obligations aligned to securities company rules (Articles 104–106). • Non-banking fintech digital platforms: Where a platform functions as a marketplace for non-bank - ing financial products, the FRA applies a two-layer approach: (i) the platform must be in scope of the fintech framework for NBFS activities, and (ii) it must remain subject to the underlying sector laws for that activity. The FinTech Law explicitly defines a “digital platform” business model for offering products and completing transactions (the Law Regulating and Developing the Use of Financial Technology in Non‑Banking Financial Activities). 6.2 Regulation of Different Asset Classes Traditional capital markets instruments (such as shares, bonds, sukuk and other regulated instru - ments) are under the FRA capital markets perimeter and exchange rules approved by the regulator (the Capital Market Laws). “Security tokens” do not have their own “token” regime in the primary legislation, so treatment is gen - erally substance-based: if the token economically rep - resents a regulated security, it is subject to the Capital Markets Law. Cryptocurrencies and crypto platforms are treated fundamentally differently: the issuance, trading or promotion of cryptocurrencies is prohibited without a CBE-board licence (the Central Bank and Banking System Law, Article 206). As of 30 December 2025, there are no indications that the government or the CBE will change its stance on legalising or licensing any crypto-asset. 6.3 Impact of the Emergence of Cryptocurrency Exchanges The CBE has clearly indicated prohibition by default on any form of trading or commercialisation of cryp - tocurrency, as well as any formal government involve - ment in the use or adoption of cryptocurrency, with a licensing gateway controlled by the CBE board for crypto issuance/trading/promotion/platform opera - tion (the Central Bank and Banking Sector Law, Arti - cle 206).
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