EGYPT Law and Practice Contributed by: Dina Kamel, Helal El Hossary, Omar Fouda and Kareem Hashem, Zaki Hashem
Practically, this means centralised and decentralised cryptocurrency exchanges cannot lawfully operate or market in Egypt. 6.4 Listing Standards Regulatory listing standards for Egyptian Exchange (EGX) listing/delisting are under the FRA’s listing framework (FRA Board Decision No 11 of 2014 on the Listing and Delisting Rules). Regulatory standards typically cover eligibility and documentation requirements for admission, ongoing disclosure and periodic reporting, governance-related conditions and delisting triggers – all implemented through exchange committees under the regulator’s framework (FRA Board Decision No 11 of 2014). Industry norms include audited financials, consist - ent disclosure discipline, governance hygiene and predictable ongoing reporting, mainly because the exchange and regulator can suspend or intervene where trading would harm the market or where there is manipulation risk (the Capital Markets Law, Articles 20 bis and 21). 6.5 Order Handling Rules Order handling rules apply in Egypt, and they are governed by a combination of executive regulations, exchange internal rules and market-specific guide - lines. The executive regulations of the Capital Market Law require transparent and fair execution, proper docu - mentation and record-keeping with respect to client instructions, and honest, competent broker conduct (governed by the Capital Markets Law as it pertains to general trading principles). In 2024, the EGX issued the Trading Rules Book – 5th Edition, which further elaborates on the rules govern - ing the trading of listed and unlisted securities on the EGX. This updated book includes provisions on: • order handling, covering order execution proce - dures; • limit orders, market orders, stop-loss orders and margins; and • matching buy and sell orders.
The Trading Rules Book ensures that all market partic - ipants comply with the necessary standards to ensure market integrity, fairness and investor protection. 6.6 Rise of Peer-to-Peer Trading Platforms According to the Capital Markets Law, Article 17, any trading of listed securities outside of the exchange is null and void. 6.7 Rules of Payment for Order Flow The Egyptian Capital Markets Law, FRA decrees and EGX trading rules do not regulate payment for order flow. However, it is prohibited for any brokerage firm to follow a policy or conduct operations that may harm its clients or violate their rights, and it is also prohib - ited for them to engage in operations for their own interests. The EGX Trading Rules Book mentions some of the most important types of illegal trading practices, including: “Exploiting an order or a group of orders issued by a client or a group of clients, where the quantities of these orders could potentially move the price of a security, or engaging in trades in the same direction as these orders before their execution, in a manner that could generate profits through the illicit exploitation of client orders. It is also prohibited to agree with others or issue recommendations for them to move in the same direction as these orders before their execution”. 6.8 Market Integrity Principles Three core pillars under the Capital Markets Law, Arti - cle 20 are: • insider dealing restrictions; • anti-manipulation powers; and • disclosure discipline. The Law prohibits trading on the basis of material non- public information, and it also prohibits tipping (Arti - cle 20). The Executive Regulations further define and give instructions regarding price manipulation, the use of inside information and insider dealing, with these activities being strictly prohibited across all market participants (the Capital Markets Law, Articles 316– 319).
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