Financial Crime World

Beneficial Ownership Disclosure Now Mandatory for Egyptian Companies

The Egyptian government has introduced new amendments to the Commercial Register Law No. 34/1976, making it mandatory for companies to disclose their ultimate beneficial owners (UBOs). The changes aim to increase transparency in corporate ownership and provide stakeholders with access to crucial information.

Key Changes to the Commercial Register Law

  • Maintenance of UBO register: As of March 9, 2020, all Egyptian companies are required to maintain a register of UBOs.
  • Registration requirements: The register must include:
    • Name
    • Nationality
    • National ID number for Egyptian individuals
    • Passport number for non-Egyptian individuals
    • Registration number for juristic persons that enjoy beneficial ownership/control over the company
  • Regular updates: The register must be updated regularly with any changes to this information.
  • Publicly accessible UBO information: The commercial register extracts will now include a new column reflecting the most up-to-date UBO information, making it publicly accessible.

Consequences of Non-Compliance

While the regulations do not specify a grace period for compliance or consequences for non-compliance, companies must adhere to these requirements upon renewal of commercial registration or introduction of updates to the register. Failure to comply may result in:

  • Fines: ranging from EGP 10 (approximately USD 0.64) to EGP 100 (approximately USD 6.37)
  • Duplicated fines for recurrence of violations

Implementation and Impact

The implementation of these regulations aims to enhance transparency and accountability in corporate ownership, providing stakeholders with access to critical information about UBOs. As the law takes effect, companies must ensure compliance to avoid potential penalties and maintain a good reputation.

Timeline

  • March 9, 2020: All Egyptian companies are required to maintain a register of UBOs.
  • Five years after de-registration or cessation of business: Companies must continue to maintain the register.