Egypt adopts ‘Anti-Money Laundering And Terrorist Financing’ Decree

9 June 2021 – The Financial Regulatory Authority of Egypt implemented “Anti Money Laundering and Terrorist Financing” Decree no. 2/2021 (the Decree) as a continuation to the Egyptian Anti-Money Laundering Law no. 80 of 2002, on 19 January 2021. As a result, entities in non-banking financial services are subject to the following requirements:

1. To prepare an internal procedural guide outlining ways to combat Money Laundering, which shall be approved by the Board and further submitted to the Financial Regulatory Authority (‘FRA’). Such a guide shall consist of AML mechanisms, KYC analysis, committee procedures as well as training programs to the employees, to be completed on an annual basis;
2. Specifically for entities whose branches operate abroad, it is mandatory to establish a separate Audit Unit to test AML System, implement policies and obtain relevant information on transactions;
3. To retain clients’ records (including their identification and ultimate beneficiaries) for at least 5 years after the end of the business relationship;
4. To appoint an officer, to be in charge of AML mechanisms. Such person must fulfill minimum threshold standards (such as 3 years’ experience in internal auditing) and must be registered in the FRA upon his/her appointment.