Financial Crime World

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Know Your Customer Regulations in Egypt: A Comprehensive Guide

The know your customer (KYC) guidelines and regulations for financial services in Egypt require professionals to verify the identity, suitability, and risks involved with maintaining a business relationship. The Anti-Money Laundering law no 80 of year 2002 and its executive regulation constitute the regulatory framework regarding anti-money laundering (AML) in Egypt.

National Regulatory Framework

The AML law came into force in 2002 and has since undergone several amendments. The relevant authority for AML controls is the Money Laundry & Terrorist Financing Combating Unit, established by virtue of the law and falls under the umbrella of the Central Bank of Egypt. The unit reviews suspicious transaction reports from financial institutions or other organizations and reports any detected crimes to law enforcement.

Customer Due Diligence

Entities must identify customers before conducting any business relation. This includes obtaining personal details such as:

  • Full name
  • Nationality
  • Date of birth
  • Gender
  • Registered address
  • Phone number
  • Email address (if any)
  • Job title
  • Workplace address
  • Purpose of creating an account
  • Other parties with control/access over the bank account

For juristic persons, entities must obtain:

  • Company commercial register
  • Tax card
  • Minutes of the board of directors meeting
  • Shareholders who own at least 25% of the company’s shares
  • Board members’ IDs (passports)

Reliance on Third Parties

In the absence of explicit regulations, clients may seek services from a third party to fulfill AML/KYC obligations. However, the client remains liable for maintaining regulatory compliance and fulfilling AML and KYC obligations.

Entities can also outsource customer due diligence by contract to other third parties that are not obliged by law to meet AML regulations. The obligated party may oblige the third party to meet AML regulations, attributing their actions as its own.

License Requirements

There is no need for an outsourcing company to obtain a license in order to conduct customer due diligence on behalf of the obligated party.

Entities That Can Be Relied Upon

According to law, entities that can be relied upon specifically as third parties to comply with AML regulations include:

  • Credit institutions
  • Financial institutions
  • Auditors
  • External accountants
  • Tax advisors
  • Notaries
  • Other independent legal professionals
  • Trust or company service providers