Egypt's AML/KYC Legal Framework
Egypt's primary AML/KYC legislation is Law No. 80 of 2002 on Anti-Money Laundering, as amended by Law No. 78 of 2003 and Law No. 36 of 2014. The 2014 amendment significantly strengthened the framework by expanding the list of predicate offences, introducing beneficial ownership requirements, and aligning the law more closely with the FATF 40 Recommendations. The law is supplemented by the Counter-Terrorism Law No. 94 of 2015for terrorist financing obligations.
Egypt is a member of the Middle East and North Africa Financial Action Task Force (MENAFATF) and completed its 4th Round Mutual Evaluation in 2020. The evaluation found Egypt largely compliant with FATF Recommendations, with particular strengths in the banking sector and areas for improvement in the DNFBP sector and virtual asset regulation.
Supervisory Architecture
| Body | Role | Supervised Sectors |
|---|---|---|
| EMLCU | Egyptian Money Laundering and Terrorist Financing Combating Unit — national FIU, receives STRs, issues AML guidelines | All reporting entities |
| CBE | Central Bank of Egypt — prudential and AML supervision of banks and payment service providers | Banks, exchange companies, payment service providers, fintechs |
| FRA | Financial Regulatory Authority — non-banking financial sector supervision | Capital markets, insurance, mortgage finance, financial leasing, microfinance |
| GAFI | General Authority for Investment and Free Zones — business registry and DNFBP supervision | Company formation agents, free zone entities |
Reporting Entities Under AML Law 80/2002
| Category | Examples |
|---|---|
| Banks | Commercial banks, investment banks, Islamic banks, specialised banks |
| Exchange Companies | Licensed foreign exchange companies and money transfer operators |
| Capital Markets | Brokerage firms, fund managers, investment banks, custodians, the Egyptian Exchange (EGX) |
| Insurance | Life and non-life insurers, reinsurers, insurance brokers |
| Real Estate | Real estate developers and agents involved in property transactions above EGP 200,000 |
| DNFBPs | Lawyers, accountants, notaries, dealers in precious metals and stones |
| Free Zone Entities | Companies operating in GAFI-administered free zones (Suez Canal Economic Zone, etc.) |
Core KYC Obligations
| Obligation | Law Reference | Requirement |
|---|---|---|
| Customer Identification | Art. 9 | Verify identity using National ID card, passport, or commercial registration before establishing a relationship or conducting transactions above EGP 30,000 |
| Beneficial Ownership | Art. 9(3) | Identify natural persons owning or controlling ≥25% of a legal entity; verify using GAFI commercial registry and beneficial ownership declaration |
| PEP Screening | Art. 9(5) | Apply Enhanced Due Diligence to domestic and foreign PEPs; obtain senior management approval; conduct enhanced ongoing monitoring |
| Suspicious Transaction Reports | Art. 14 | File STRs with EMLCU within 3 working days of suspicion arising; tipping-off prohibited |
| Record Keeping | Art. 11 | Retain CDD records and transaction records for a minimum of 5 years from the end of the relationship |
| AML Compliance Programme | Art. 13 | Maintain a written AML compliance programme; appoint a designated AML Compliance Officer; conduct annual AML training |
Egypt's National ID and GAFI Business Registry
Egypt's primary identity document for KYC purposes is the National ID Card (بطاقة الرقم القومي), issued by the Ministry of Interior to all Egyptian citizens aged 16 and above. The card contains a unique 14-digit National ID Number (NIN) linked to the Civil Registry database. For non-citizens, a valid passport or residence permit is used.
For corporate customers, the primary verification documents are the Commercial Registration Certificate and the Tax Registration Card, both issued through the General Authority for Investment and Free Zones (GAFI) or the Commercial Registry offices. Egypt has been progressively digitising its business registry through the GAFI InvestGate portal, which provides online access to company registration data and beneficial ownership information.
Textile and Manufacturing Sector KYC
Egypt is Africa's largest textile exporter and a major supplier to EU fast-fashion brands. The Egyptian textile sector is subject to EU ESPR compliance obligations from mid-2027, requiring verified entity records for all export shipments. Egyptian textile manufacturers must complete their GAFI entity verification and AML Law KYC obligations before accessing the Three Gates Framework for DPP minting.
Penalties for Non-Compliance
| Contravention | Penalty |
|---|---|
| Failure to conduct CDD | Fine of EGP 50,000–500,000; suspension of licence |
| Failure to file STR | Fine of EGP 50,000–500,000; criminal referral |
| Money laundering conviction | 3–7 years imprisonment + fine equal to the value of laundered funds + asset confiscation |
| Terrorist financing conviction | Life imprisonment or death penalty in aggravated cases |
Relevance for African Exporters and the Three Gates Framework
Egyptian exporters — particularly in the textiles, agriculture, and chemicals sectors — must complete their GAFI entity verification and AML Law 80/2002 KYC obligations before accessing Gate 2 (CBAM) or Gate 3 (Digital Product Passport). The Commercial Registration Certificate and the beneficial ownership declaration are the primary documents required to establish the verified entity node at the DPP Registry.