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Egypt Sanctions Regime: A Comprehensive Overview

In an effort to combat terrorism and money laundering, the Egyptian government has established a robust sanctions regime. This regime aims to prevent the proliferation of weapons of mass destruction and disrupt the financing of terrorist activities.

Lists of Sanctioned Individuals and Entities

There are several lists related to sanctions maintained by various authorities in Egypt, including:

  • General Prosecution: The General Prosecution is responsible for creating a list of sanctioned individuals and entities under the Law on Terrorist Organisations and Terrorists Lists. This list is reviewed and confirmed by the Felonies Court before being officially issued and published in the Official Gazette.
  • Ministry of Foreign Affairs (MFA): The MFA supervises and implements sanctions pertaining to the United Nations (UN) and other organizations, in accordance with Article 1(3) of Law 453 of 1955 on the MFA. The MFA channels the list of sanctioned individuals and entities to relevant government bodies, such as the Central Bank of Egypt (CBE) for asset freeze-related sanctions.
  • Financial Regulatory Authority (FRA): The FRA has also issued a decree requiring financial institutions to abide by its recommendations regarding individuals and entities placed on the list of targeted financial sanctions. This list is updated daily and includes names of individuals and entities subject to targeted financial sanctions for money laundering, terrorist financing, and weapons of mass destruction proliferation.

Challenging Sanctioned Listings

Individuals placed on the list of sanctioned individuals can challenge their listing within 60 days before the Court of Cassation’s Criminal Division. However, there is no institutionalized system regulating the issuance of licenses and authorizations exempting particular activities, transactions or types of transactions from UN or other international sanctions regimes.

Consequences for Breaching Sanctions

The consequences for breaching sanctions in Egypt include:

  • Criminal penalties: Imprisonment and fines
  • Administrative penalties: Seizure of proceeds of crime and suspension of licenses
  • Anti-Money Laundering Law: Penalties, including seizure of proceeds of crime and suspension of licenses

Contact Information for Regulators

For those looking to navigate the Egyptian sanctions regime, contact information for relevant regulators is available below:

  • Egyptian Ministry of Foreign Affairs:
    • Maspero Corniche El Nil, Cairo, Egypt
    • Tel: (+202) 2579 6334, (+202) 2574 6872, etc.
  • General Prosecution:
    • Office of the Attorney General, Court of Cassation, 26 July Street, Isaaf Square, Cairo, Egypt
    • Tel: (+202) 2576 0468, (+202) 2574 3751, etc.
  • Financial Regulatory Authority:
    • Smart Village, Building No. B 136 – Financial District, Giza, Egypt
    • Tel: (+202) 35345350, etc.

Disclaimer

This article is intended as a guide only and should not be taken as legal advice.