--- title: "Egypt (EG) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/egypt-eg/ source_html: /jurisdictions/egypt/index.html description: "Financial integrity intelligence for Egypt (EG): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T19:35:25Z content_sha256: 6c1bf31a2feaf09d13600c88c26934b20bbb2667b414ce52c3beabd86bc958bb generator: "fe-fleet/md-twin@1.0" --- # Egypt (EG) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Egypt EG Domains covered 8 of 8 Sources 150 Role actions 8 Horizon <90d 1 Jurisdiction profile FATF status: Largely Compliant Tier: B Risk direction: Stable Enablement vs enforcement: Mixed Egypt's AML/CFT regime rests on AML Law No. More 80/2002 (amended), implementing bylaws under PM Decree 951/2003 (amended 2023), and CBE Law 194/2020. FIU is the EMLCU. FATF/MENAFATF rate Egypt 11 Compliant, 26 Largely Compliant, 3 Partially Compliant (sanctions, MLA, extradition); Egypt remains in Enhanced Follow-up, not grey-listed. Key deficiencies - Targeted financial sanctions implementation rated Partially Compliant (R.35), weakening UN 1267/1988/2231 enforcement reliability - TCSP/DNFBP regulation gap: no legal prohibition on non-lawyer/accountant corporate-service provision (R.22 Partially Compliant) - Mutual legal assistance and extradition frameworks rated Partially Compliant (R.37, R.39), limiting cross-border illicit-finance cooperation - Legal system requires predicate-offense conviction before pursuing money laundering, structurally limiting stand-alone ML prosecutions and masking true laundering scale - 68% of cash transactions occur outside the formal financial system per Egypt's 2019 NRA, sustaining a large informal/hawala-adjacent TF and ML risk pool - Antiquities smuggling and organized-crime proceeds are large-value predicate crimes not fully captured in the National Risk Assessment or ML investigations - Cryptocurrency prohibited without CBE license (Law 194/2020, Art. 206) yet informal crypto adoption is reported growing, indicating enforcement/visibility gap Recent developments (18m) - MENAFATF adopted Egypt's 4th Enhanced Follow-up Report (3 Oct 2025), re-rating Recommendation 3 (ML offence) from Partially Compliant to Largely Compliant - Egypt remains under MENAFATF's Enhanced Follow-up Process, with a further progress report due at the next Plenary cycle - OFAC issued counter-terrorism designation updates in March 2025 and December 2025 affecting Egyptian-nationality individuals with historical al-Qaida/ISIS/ICC-adjacent links - Central Bank of Egypt continued its mechanism (Governor's Resolution No. 45/2023) to identify and act against unlicensed money-transfer operators Brief ## Lead signal #### Lead Signal Egypt's Financial Regulatory Authority approved thirteen non-bank entities for fintech-based financial activity across two decisions in October 2026, a pace of licensing that continues to widen the perimeter of Egypt's non-bank finance sector. The first tranche, approved 18 October 2026, covered six companies spanning securities custody and trading, SME lending, an outsourcing technology provider scoped to its own affiliates, and a consumer finance platform. The second tranche, approved 20 October 2026, covered seven further companies and entities, including a bond-dealing licence extension for an existing brokerage and the establishment of a new securities promotion and underwriting company. Together the two decisions mark a steady monthly cadence of growth in the population of licensed non-bank financial entities operating under the Authority's supervision. Read full brief #### Lead Signal Egypt's Financial Regulatory Authority approved thirteen non-bank entities for fintech-based financial activity across two decisions in October 2026, a pace of licensing that continues to widen the perimeter of Egypt's non-bank finance sector. The first tranche, approved 18 October 2026, covered six companies spanning securities custody and trading, SME lending, an outsourcing technology provider scoped to its own affiliates, and a consumer finance platform. The second tranche, approved 20 October 2026, covered seven further companies and entities, including a bond-dealing licence extension for an existing brokerage and the establishment of a new securities promotion and underwriting company. Together the two decisions mark a steady monthly cadence of growth in the population of licensed non-bank financial entities operating under the Authority's supervision. The structural significance of this expansion lies less in any single approval than in the rate at which Egypt's non-bank finance perimeter is growing relative to the oversight architecture built primarily around the banking channel. Securities trading, SME lending platforms, and outsourcing-technology arrangements sit outside the traditional banking supervisory lens even where they intersect with payments and consumer finance functions, and the volume of approvals in a single month is itself the signal worth tracking. #### Other Developments Bond-dealing licence extension. Among the seven approvals granted 20 October 2026, an existing bond brokerage received an extension of its licence to cover bond dealing, intermediation and brokerage activity, indicating the Authority is also willing to broaden the scope of already-licensed entities rather than only admitting new entrants. New underwriting entrant. The same decision included the establishment of a new company focused on securities promotion and underwriting, adding a further node to the population of licensed capital-markets intermediaries operating under the Authority's non-banking financial activities framework. #### Cross-Monitor Connections The licensing volume documented here sits adjacent to developments tracked on the payments side, where the same Financial Regulatory Authority decisions are read for their commercial and market-structure implications rather than their supervisory-perimeter implications. Readers following both the financial-crime and payments-infrastructure angles on Egypt should note that the underlying regulatory actions are the same two decisions, viewed through different lenses. #### Outlook If the pace of approvals observed in October 2026 continues, the non-bank financial activities population supervised by the Authority will keep growing faster than any visible parallel expansion of anti-money-laundering supervisory capacity specific to that population, as distinct from the banking-channel capacity exercised by the Central Bank. Whether supervisory resourcing and examination cadence for non-bank entities keeps pace with this licensing velocity is the structural question to watch in coming cycles, though no evidence currently available speaks to that question directly. Earlier periodic briefs (4) 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Egypt's AML/CTF regime registered a confirmed structural improvement this cycle. MENAFATF's 4th Enhanced Follow-up Report re-rated Egypt's technical compliance against FATF Recommendation 3 (the money laundering offence) from Partially Compliant to Largely Compliant, bringing the country's overall standing to 11 Compliant and 26 Largely Compliant ratings out of the FATF 40, with 3 Partially Compliant ratings remaining. This is a confirmed finding sourced directly from the FATF/MENAFATF primary publication page, and it sits alongside a probable regulatory development reported this cycle: the Central Bank of Egypt's AML unit issued updated customer due diligence guidance for banks and their foreign branches, formally incorporating electronic know-your-customer (eKYC) practice into the post-2020 AML Act framework. No primary circular text was independently obtained, so this second element is treated as probable rather than confirmed. Read together, the two developments describe a jurisdiction consolidating an existing architecture rather than responding to a single enforcement incident. Egypt is not on the FATF list of jurisdictions under increased monitoring as of 24 October 2025, and remains instead in the lower-visibility MENAFATF enhanced follow-up process, which is the appropriate structural channel for a country closing out residual technical-compliance gaps rather than facing grey-list pressure. #### Other Developments Sanctions posture unchanged. Egypt is not currently subject to an active EU, US, or UK country-level sanctions regime. The EU's 2011 Arab-Spring-era asset-freeze regime targeting Egypt-linked individuals was revoked in 2021, and no new country-level or entity-level Egypt-nexus designation was identified this cycle by OFAC, OFSI, or the EU Council. Crypto architecture holds at prohibition-by-default. Article 206 of the Central Bank and Banking Sector Law No. 194 of 2020 continues to render crypto-asset issuance, trading, promotion, or platform operation unlawful without prior Central Bank of Egypt approval, and no such approval has been granted since the law's enactment. This is reported at probable confidence, resting on a vendor-tier description of a primary statutory provision not independently retrieved this cycle. Beneficial ownership and enabler-jurisdiction coverage thin. No Egypt-specific beneficial ownership registry development or enabler-jurisdiction/professional-facilitator finding was surfaced this cycle. This reflects a coverage gap in research reach rather than a confirmed absence of activity, and should not be read as a finding of stability. #### Cross-Monitor Connections The CBE's eKYC-incorporating circular is a RegTech-adjacent development worth tracking jointly with compliance-technology coverage once primary text becomes available, since formal incorporation of electronic verification into customer due diligence obligations can reshape onboarding architecture for the banks it binds. The crypto prohibition-by-default under Article 206 continues to define the outer boundary within which any digital-asset-enabled payment or settlement innovation in Egypt would have to operate, a boundary condition relevant to monitors tracking payment-corridor and digital-money infrastructure in the same jurisdiction. #### Outlook The MENAFATF re-rating is a durable technical-compliance marker: Egypt now holds Largely Compliant or better ratings across the substantial majority of the FATF 40, a position that structurally reduces the likelihood of near-term grey-list escalation absent a new adverse event. Whether the CBE's October 2026 CDD circular is confirmed at primary-source level will determine whether the eKYC development hardens into a standing D7 architecture note or remains a probable development pending verification. The underlying AML/CFT regime, supervised by the Central Bank of Egypt for banks and the Financial Regulatory Authority for non-bank entities, with the Egyptian Money Laundering and Terrorist Financing Combating Unit operating as the financial intelligence unit via GoAML, continues to anchor this architecture independent of either development. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Egypt's anti-money laundering architecture registered a confirmed upgrade this cycle, through the mechanism that most durably moves a jurisdiction's technical-compliance standing: the mutual-evaluation follow-up process. MENAFATF's May 2024 enhanced follow-up report re-rated Egypt on Recommendations 14, 15, 22 and 23, lifting all four to Compliant or Largely Compliant. This is a standing record development rather than a new statute, and it leaves Egypt compliant or largely compliant on 36 of 40 FATF Recommendations. The underlying architecture remains Anti-Money Laundering Law No. 80 of 2002 and its Executive Regulations, which established the Egyptian Money Laundering and Terrorist Financing Combating Unit (EMLCU) as financial intelligence unit and AML supervisory coordinator. Alongside this regulatory signal, Egypt's payments and fintech sector produced two commercial developments of note: Paymob closed a 35 million dollar pre-Series C round co-led by Mubadala Investment Company and the European Bank for Reconstruction and Development, announced 21 September 2026, and MNT-Halan is reported to be pursuing a planned EGX listing of 20 percent of its shares in October 2026, following a June 2026 funding round that valued the company at 1.4 billion dollars. Both are probable-confidence findings resting on trade-press reporting rather than primary filings. #### Other Developments CDD threshold coverage remains thin. Reporting from a compliance-technology vendor describes customer due diligence obligations triggered at approximately 15,000 US dollars, enhanced due diligence for higher-risk customers, and a five-year minimum record-retention period under Law No. 80 of 2002 and CBE/FRA implementing regulations. No Tier-1 instrument text for the exact threshold figure was retrieved this cycle, so this remains a probable rather than confirmed finding. Grey-list status holds steady. Egypt remains off both the FATF grey list and blacklist as of the 19 June 2026 Plenary, with the next MENAFATF mutual evaluation on-site period not expected before January 2029. Sanctions exposure unchanged. No new Egypt-specific sanctions designation was located this cycle. The 2011 EU Arab-Spring-era regime targeting Egypt was revoked by Council Regulation (EU) 2021/445 in March 2021, and no EU, OFAC or UK country-level sanctions regime is currently active against Egypt. Crypto prohibition unmoved. Egypt's Central Bank and Banking Sector Law No. 194 of 2020, Article 206, continues to prohibit crypto-asset activity absent CBE authorisation; no licences have been issued under this article. #### Cross-Monitor Connections The commercial funding activity in Paymob and MNT-Halan sits squarely at the intersection of this monitor's Commercial Activity domain and the World Payments Monitor's Commercial Intelligence and Fintech tracking of the same entities; readers following payments-infrastructure investment in the MENA region should cross-reference that monitor's treatment of the identical events for a product and market-structure lens, as distinct from this monitor's financial-integrity lens on investor identity and sector exposure. #### Outlook The MENAFATF re-rating is a lagging record update rather than a live regulatory event, and no further FATF action on Egypt is expected before the next mutual evaluation on-site period, not anticipated before January 2029. The more immediate items to watch are whether Tier-1 primary-source confirmation of the CDD threshold figures becomes available, and whether Paymob's or MNT-Halan's disclosed transactions attract any CBE or FRA regulatory commentary as the MNT-Halan EGX listing process, as scheduled for October 2026, proceeds. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal FinCEN has proposed a Section 311 special measure against five United Arab Emirates branches of Banque Misr, an Egyptian state-owned bank, citing approximately USD 1.8 billion moved through 103 suspected Iranian shadow-banking front companies between January 2024 and June 2026. The proposal would, if finalised, prohibit covered US financial institutions from maintaining correspondent accounts for those UAE branches specifically. The measure is scoped narrowly: the Central Bank of Egypt and the UAE Central Bank have jointly confirmed no impact on Banque Misr's Egyptian domestic operations, and the finding concerns the bank's UAE branch structure rather than Egypt's own AML/CTF regulatory perimeter. The primary Federal Register instrument underlying the proposal was not directly retrieved this cycle, which caps confidence at the probable rather than confirmed tier. The UAE Central Bank responded independently, ordering a special and urgent examination into Banque Misr's UAE branches following the US warning. This domestic response is distinct from, and not contingent on, the US finding, and no parallel measure from the EU or UK has been located. #### Other Developments Sanctions-regime divergence as a standing watch item. The pairing of a unilateral US Section 311 proposal with an independent UAE domestic examination, absent any mirrored EU or UK listing, illustrates a modest but notable instance of enforcement-posture divergence across sanctions blocs. This is a cross-bloc architecture observation rather than a finding about Egypt's own regime. #### Cross-Monitor Connections The Banque Misr matter carries correspondent-banking access implications that intersect with payments-infrastructure monitoring of Gulf-exposed Egyptian state banking relationships, though the proposal's scope is confined to the UAE branch structure and does not itself alter Egypt's domestic payments or banking-access landscape. #### Outlook The Section 311 proposal remains at the proposed stage, with finalisation expected around Q4 2026 as scheduled, pending comment-period outcome; the timeline and ultimate scope of any final rule are not yet public. Because the primary Federal Register text has not yet been directly retrieved, the probable-tier assessment of the USD 1.8 billion flow figure and the UAE Central Bank's examination findings should be read as provisional pending confirmation from primary sources. 14 Sep 2026 · fim-2026-08-21 #### Lead Signal Egypt's anti-money-laundering and counter-terrorist-financing technical-compliance posture has continued to strengthen, according to a FATF-published 2025 follow-up report that rates the country compliant on eleven FATF Recommendations, largely compliant on twenty-six, and partially compliant on three (fim-2026-W34-001). This is a material improvement in technical-compliance terms relative to the 2021 mutual evaluation baseline, and it is the kind of architecture-level progress that the follow-up process is designed to track: incremental closing of gaps in legal framework, institutional capacity, and supervisory practice rather than a single enforcement event. Egypt has not exited FATF/MENAFATF enhanced follow-up, however, and the three partially-compliant ratings that remain open are the specific gap between the current position and full technical-compliance closure. Read against FIM's three-pillar standard, this cycle's Egypt signal is squarely an AML/CTF-architecture finding rather than a CPF-specific one: the FATF follow-up report and the EMLCU-UN engagement both speak to money-laundering and terrorist-financing technical compliance, and no proliferation-financing-specific development surfaced this cycle. This is consistent with, rather than a correction to, the volume bias that generally favours AML-pillar findings, and analysts should not read the absence of a CPF signal this cycle as evidence that Egypt's CPF framework is either strong or weak -- it is simply outside this cycle's evidentiary base. #### Other Developments EMLCU deepens international cooperation with the UN. Egypt's Money Laundering and Terrorist Financing Combating Unit (EMLCU), the financial intelligence unit housed within the Central Bank of Egypt, met with the UN Office of Peacebuilding and Peace Support to expand cooperation against illicit financial flows and transnational crime (fim-2026-W34-002). The unit's chairman is reported to have stressed capacity-building and adherence to international standards. This is an episodic bilateral engagement rather than a change to Egypt's domestic legal or supervisory architecture, and it should be read as a supporting signal alongside the FATF follow-up improvement rather than as an independent development. Standing AML/CTF architecture unchanged. Egypt's Anti-Money Laundering Law No. 80/2002 criminalises money laundering and established EMLCU as the FIU within the Central Bank of Egypt, and is supplemented by the Anti-Terrorism Law No. 8/2015 for terrorist-entity listing (fim-2026-W34-005). This baseline architecture is unchanged this cycle. It is nonetheless the necessary backdrop against which the FATF follow-up improvement should be read: the follow-up report is measuring implementation and effectiveness against this statutory foundation, and continued improvement within an unchanged legal architecture is itself an analytically meaningful signal about supervisory and institutional capacity building. #### Cross-Monitor Connections Egypt's improving AML/CTF technical-compliance trajectory has a direct, if indirect, read-across to World Payments Monitor coverage of Egypt's concurrent payments-licensing formalisation: a strengthening AML architecture is a structural precondition for the kind of payment-system-operator and digital-bank licensing regime the Central Bank of Egypt has been building out, and the two developments should be read as mutually reinforcing rather than independent signals of an Egyptian financial-sector regulatory environment maturing on multiple fronts simultaneously. No conflict-finance, enabler-jurisdiction, sanctions-evasion, or digital-asset-integrity signal specific to Egypt surfaced with qualifying material this cycle to connect to SCEM, WDM, or the crypto monitor's coverage. #### Outlook The determinative question for the coming cycles is whether Egypt's continued technical-compliance improvement translates into a full exit from FATF/MENAFATF enhanced follow-up, which requires closing the three still-partially-compliant Recommendation ratings while sustaining the eleven already rated compliant and the twenty-six rated largely compliant (fim-2026-W34-001). EMLCU's deepening engagement with international bodies such as the UN Office of Peacebuilding and Peace Support is a supportive but non-determinative signal of institutional trajectory; the substantive test remains the next formal FATF/MENAFATF assessment. Egypt's continued enhanced-follow-up status, notwithstanding this cycle's improvement, remains relevant to correspondent-banking risk assessment: institutions maintaining correspondent relationships with Egyptian financial institutions typically weight FATF/MENAFATF follow-up status as one input into due-diligence intensity, and a move toward full exit from enhanced follow-up would be expected to ease that intensity at the margin, absent any other intervening development. Absent a change to the underlying Anti-Money Laundering Law No. 80/2002 architecture, watch for further follow-up reporting and any announcement of an enhanced-follow-up exit as the events that would most directly move Egypt's AML/CTF risk posture. Domain intelligence (D1–D8) #### Sanctions The principal sanctions-architecture development this cycle is FinCEN's proposed Section 311 special measure against five UAE branches of Banque Misr, an Egyptian state-owned bank. The proposal cites roughly USD 1.8 billion moved through 103 suspected Iranian shadow-banking front companies between January 2024 and June 2026, and would, if finalised, revoke US correspondent-banking access for those specific branches. This is a significant sanctions-architecture signal because it operates through the correspondent-banking access lever rather than a direct asset freeze, and because it targets a named emerging-market state bank's offshore branch network rather than a shell company. Continue reading Critically for Egypt's own standing, the proposal is scoped exclusively to the UAE branches. The Central Bank of Egypt and the UAE Central Bank have jointly confirmed that Banque Misr's domestic Egyptian operations are unaffected. This distinction matters analytically: the finding says something about correspondent-banking risk for Gulf-exposed Egyptian state banking relationships, but it is not evidence of a weakness in Egypt's domestic AML/CTF regulatory perimeter, which is tracked separately. The UAE Central Bank's response is itself a notable data point. Rather than waiting on or mirroring the US finding, it ordered its own special and urgent examination into the Banque Misr UAE branches. That independent domestic action, absent any parallel EU or UK listing or measure, is read here as a modest instance of sanctions-regime divergence: different blocs reaching different procedural postures from the same underlying finding, with the UAE acting on its own supervisory authority rather than contingent on Washington's timeline. The evidentiary basis for the USD 1.8 billion figure and the front-company count rests on secondary reporting; the primary Federal Register notice of proposed rulemaking was not directly retrieved this cycle, which caps the confidence assignment at probable. This is a structural evidentiary gap worth flagging rather than a substantive doubt about the underlying finding, since multiple independent secondary sources converge on the same figures. No parallel finding implicating Banque Misr's Egyptian head office, other Egyptian state banks, or Egypt's sanctions-screening infrastructure has been located. The matter should therefore be read as a correspondent-banking-access risk concentrated in the UAE branch structure, with potential second-order relevance to how Gulf-exposed Egyptian banking relationships are perceived by US counterparties, rather than as a finding against Egypt's domestic sanctions-compliance architecture. #### Outlook The Section 311 proposal remains at the proposed rulemaking stage. Finalisation is expected around Q4 2026 as scheduled, pending the outcome of the public comment period, though the precise timeline has not been confirmed in primary sources. If finalised as proposed, covered US institutions would be barred from maintaining correspondent accounts for the five named UAE branches, which would have a bounded but concrete impact on correspondent-banking access for that specific branch network. Because the underlying Federal Register text has not yet been directly retrieved, both the ultimate scope of any final rule and the durability of the USD 1.8 billion flow estimate should be treated as provisional. The UAE Central Bank's parallel examination may independently generate its own findings or remedial measures on a separate timeline from the US process; no outcome from that examination has been reported yet. Absent from this cycle's substrate is any indication that the matter will extend to Banque Misr's Egyptian operations or to Egypt's broader AML/CTF posture, and nothing in the record points toward an EU or UK measure materialising in parallel. Judgment: No Egypt-nexus sanctions development located this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency Egypt sits outside the European Union's AML Package perimeter; the AMLR, 6AMLD, and AMLA Regulation do not apply directly to Egyptian obliged entities. The developments directly relevant to Egypt's own beneficial-ownership and corporate-transparency exposure are domestic: the Financial Action Task Force's December 2025 follow-up report to Egypt's mutual evaluation reaffirms that Egypt remains only partially compliant with Recommendation 24 on beneficial ownership, and that no centralised beneficial-ownership registry exists for legal persons. The same follow-up reaffirms partial compliance on the related Recommendations 28 (DNFBP oversight) and 3 (money-laundering offence). This stands in contrast to Egypt's progress elsewhere in its AML/CFT framework: the Central Bank of Egypt's digital-onboarding and customer-due-diligence practice was cited in FATF's June 2025 Guidance on Financial Inclusion and AML/CFT as an international best-practice example, a recognition CBE publicised in October 2025 and which is associated with an improved Recommendation 10 rating. The structural picture, read together, is of a jurisdiction advancing its CDD and onboarding technology layer while its underlying corporate-transparency infrastructure, the register that would let banks and DNFBPs verify who actually owns and controls a legal person, remains incomplete. Continue reading Globally, the EU AML Package sets the structural direction for beneficial-ownership supervision: the AML Regulation (Regulation (EU) 2024/1624) is directly applicable across the EU without national transposition, the sixth AML Directive requires Member State transposition, and the AMLA Regulation (Regulation (EU) 2024/1620) establishes the Anti-Money Laundering Authority with a direct and indirect supervisory perimeter that is shifting beneficial-ownership and broader AML supervision from purely national authorities toward a hybrid EU-level regime. This is durable structural backdrop rather than an Egypt-specific development: Egypt is not within AMLA's supervisory perimeter, and no AMLA-Egypt nexus was identified this cycle. It is presented here as the standing comparator against which Egypt's own partial-compliance position on Recommendation 24 can be read: where the EU is moving toward centralised, EU-level verification of beneficial-ownership data, Egypt has not yet established even a national centralised registry. #### Outlook The FATF follow-up cycle is the key variable to watch: Egypt's next assessment milestone will test whether the partial-compliance rating on Recommendation 24 moves, and whether a centralised beneficial-ownership registry is established or scheduled. Absent that movement, Egypt's beneficial-ownership transparency position will likely remain the primary flagged deficiency in an otherwise improving technical-compliance record, a status quo that this cycle's evidence does not suggest is about to change. Judgment: Egypt's non-public UBO register under Ministerial Decree No. 41/2020, accessible only to GAFI/ITDA and judicial officers, remains unchanged this cycle. Probable Judgment: No enabler-jurisdiction or professional-facilitator finding located this cycle. Uncertain Judgment: No conflict-finance finding located this cycle. Uncertain #### Crypto, Digital Assets, and Financial Innovation Egypt's own regulatory posture toward digital assets is one of total prohibition, not partial restriction. The Central Bank of Egypt maintains a categorical ban on cryptocurrency activity under Article 206 of the Central Bank and Banking System Law No. 194 of 2020, and no licence has ever been granted under that framework. This cycle's evidence includes a further, recent CBE warning statement reaffirming the ban, although the primary CBE text of that specific warning was not directly retrieved this cycle and the finding rests on a secondary source. Global frameworks such as MiCA and the FATF's virtual-asset standards are not the operative regime for Egypt: Egypt's posture is a domestic, total prohibition rather than a licensing or registration regime of the kind those frameworks are designed to govern, so they function only as distant comparators rather than as applicable law. Continue reading The more analytically significant point this cycle is the durability of the gap between that legal totality and practical reality: the underlying assessment notes reported informal cryptocurrency usage continuing among Egyptians despite the ban, an enforcement-versus-adoption divergence that a purely legal reading of Article 206 would understate. A total prohibition that is not accompanied by visible enforcement data against informal usage functions differently, from a risk-assessment standpoint, than one where enforcement and legal text are aligned. No new licensing move, sandbox, or CBDC development was identified for Egypt this cycle. #### Outlook Watch for either an enforcement action against a specific platform or channel enabling informal crypto usage, which would be the first indicator that the CBE is moving from statement-based reaffirmation to active enforcement, or any legislative signal of a shift away from total prohibition toward a regulated pathway. Neither was evidenced this cycle, and the honest reading is that the prohibition-versus-adoption gap is a standing rather than resolving condition. Judgment: Egypt's blanket cryptoasset prohibition under Article 206 of Law No. 194/2020 remains unchanged; no CBE licence has been granted to date. Probable #### Compliance Technology and Active Defence Egypt's compliance-technology backbone continues to mature this cycle. The GoAML platform is mandated for suspicious-transaction reporting across regulated entities under the coordination of the Egypt Money Laundering and Terrorist Financing Combating Unit, providing the operational infrastructure through which suspicious-activity data is centralised. Against that backbone, FATF's June 2025 Guidance on Financial Inclusion and AML/CFT cited the Central Bank of Egypt's digital-onboarding and customer-due-diligence practice as an international best-practice example, a recognition the CBE itself publicised in October 2025. The secondary reporting associated with that recognition describes an improved Recommendation 10 rating tied to digital onboarding specifically, meaning the compliance-technology gain is concentrated in the customer-identification stage of the AML lifecycle rather than across the full reporting chain. Continue reading Read together with Egypt's separately flagged beneficial-ownership transparency gap, the active-defence picture is uneven rather than uniformly strong: the reporting and onboarding technology layer, GoAML plus digitised CDD, is advancing and drawing international recognition, while the upstream data layer that would let that same technology surface beneficial-ownership risk, a centralised registry, does not yet exist. Active defence built on incomplete underlying data carries a structural ceiling regardless of how well the reporting technology itself performs. This is consistent with the broader pattern in Egypt's technical-compliance file: recognition and improvement concentrate where digital infrastructure already exists, while areas requiring new institutional infrastructure, such as a beneficial-ownership registry, lag behind. #### Outlook The key indicator to watch is whether FATF's positive Recommendation 10 assessment is followed by comparable movement on Recommendation 24, since a compliance-technology upgrade concentrated at onboarding without a parallel beneficial-ownership data layer will continue to leave a structural gap in what GoAML-fed reporting can actually surface. No new technology deployment beyond GoAML and the CDD improvement was evidenced this cycle. Judgment: No RegTech or active-defence development with an Egypt nexus located this cycle. Uncertain #### AML/CTF Regime Egypt's AML/CTF regime shows continued architecture-level improvement this cycle. The FATF-published 2025 follow-up report rates Egypt compliant on eleven Recommendations, largely compliant on twenty-six, and partially compliant on three, an improvement in technical-compliance terms relative to the 2021 mutual evaluation baseline (fim-2026-W34-001). Egypt remains within FATF/MENAFATF enhanced follow-up rather than having exited the process, meaning the three partially-compliant ratings are the specific, named gap between the current position and full technical-compliance closure. This is a High-confidence, Tier-1-sourced finding directly from FATF publication, and it should be read as a structural signal about the trajectory of Egypt's legal and institutional AML/CTF framework rather than a single enforcement data point. Continue reading The regime's statutory foundation is unchanged this cycle: Egypt's Anti-Money Laundering Law No. 80/2002 criminalises money laundering and established the Egyptian Money Laundering and Terrorist Financing Combating Unit (EMLCU) as the financial intelligence unit within the Central Bank of Egypt, supplemented by the Anti-Terrorism Law No. 8/2015 for terrorist-entity listing (fim-2026-W34-005). This is a High-confidence, Tier-1-sourced baseline claim. The follow-up improvement recorded this cycle is measured against this unchanged statutory architecture, which is itself analytically significant: Egypt is achieving better implementation and effectiveness outcomes without a parallel legislative overhaul, pointing toward supervisory and institutional capacity building as the operative driver of the improvement rather than new primary legislation. EMLCU's institutional posture is also active on the international-cooperation front. The unit met with the UN Office of Peacebuilding and Peace Support to expand cooperation against illicit financial flows and transnational crime, with the unit's chairman reported as stressing capacity-building and adherence to international standards (fim-2026-W34-002). This is an Assessed-confidence, Tier-3-sourced episodic bilateral engagement rather than a rule change, and it should be read as a supporting rather than determinative signal: it is consistent with, but does not itself establish, the technical-compliance improvement recorded in the FATF follow-up report. Read against the three-pillar AML/CTF/CPF standard, this cycle's Egypt signal is squarely AML/CTF-architecture in character. No proliferation-financing-specific development surfaced this cycle for Egypt, and that absence should not be read as either a positive or negative signal about Egypt's CPF framework specifically. Analysts should also note that Egypt's improving trajectory, while genuine, coexists with continued enhanced-follow-up status; the two facts are not in tension, since enhanced follow-up is itself a monitoring mechanism designed to track exactly this kind of incremental improvement toward eventual exit. #### Outlook The determinative question for coming cycles is whether Egypt's technical-compliance improvement translates into a full exit from FATF/MENAFATF enhanced follow-up. That would require closing the three remaining partially-compliant Recommendation ratings while sustaining the eleven already-compliant and twenty-six largely-compliant ratings (fim-2026-W34-001). EMLCU's deepening engagement with international bodies such as the UN Office of Peacebuilding and Peace Support is a supportive but non-determinative signal of institutional trajectory; the substantive test remains the next formal FATF/MENAFATF assessment cycle. For compliance and risk functions at institutions with Egyptian counterparty exposure, Egypt's continued enhanced-follow-up status remains a relevant input into correspondent-banking and cross-border due-diligence intensity, and a move toward full exit would be expected to ease that intensity at the margin, absent any other intervening development. No change to the underlying Anti-Money Laundering Law No. 80/2002 architecture is indicated this cycle, so the outlook is one of continuity in legal framework accompanied by incremental improvement in implementation and effectiveness outcomes. Judgment: Egypt's standing AML/CTF regime (Law No. 80 of 2002, as updated by Prime Ministerial Decree No. 3331/2023), supervised by the CBE/FRA with EMLCU as FIU and assessed via MENAFATF, is unchanged this cycle. Probable #### Commercial Activity Egypt's Financial Regulatory Authority approved thirteen non-bank entities for fintech-based financial activity across two decisions this period, continuing a steady monthly cadence of expansion in the licensed non-bank finance population. The first decision, dated 18 October 2026, approved six companies: a financial holding company and an affiliated securities trading company, an SME finance platform, a digital SME financing entity, a technology company registered as an outsourcing provider limited to its own affiliate group, and a consumer finance platform operating through an associated lending application. The second decision, dated 20 October 2026, approved seven further companies and entities, including an existing bond brokerage receiving an extension of its licence into bond dealing, intermediation and brokerage, and the establishment of a new securities promotion and underwriting company. Continue reading Read as commercial activity rather than as a compliance-perimeter question, the pattern is one of consistent regulatory throughput: the Authority is processing and clearing a steady stream of applications spanning securities services, SME lending, outsourcing arrangements and consumer finance, rather than concentrating approvals in any single sub-sector. The securities-side approvals, including the bond brokerage licence extension and the new underwriting entrant, indicate continued build-out of Egypt's non-bank capital-markets intermediary population alongside the SME-lending and consumer-finance fintech approvals. The outsourcing-technology registration, scoped specifically to the approved entity's own affiliates, is a narrower category of approval than a full market-facing licence and should be read accordingly. The commercial significance of this cadence is structural rather than incident-specific: thirteen approvals in roughly a two-week window represents a meaningful rate of market entry and licence-scope expansion for Egypt's non-bank financial sector, a sector that sits partly outside the banking-channel anti-money-laundering supervisory architecture built primarily around the Central Bank. No sanctions, enforcement action, or adverse finding attaches to any of the approved entities in the material reviewed; these are routine market-access approvals rather than remedial or corrective measures. #### Outlook The rate of non-bank fintech licensing observed in this window, if sustained across subsequent periods, will continue to grow the population of entities supervised by the Authority outside the banking channel. Whether examination and supervisory resourcing for this expanding non-bank population keeps pace with its growth is the structural question for coming periods; no evidence currently available addresses that question directly, and no further Authority decisions beyond the two described here fall within the period covered. Judgment: The FRA's approval of 13 non-bank fintech entities across two decisions this cycle continues a steady monthly cadence of fintech licensing growth in Egypt's non-bank finance sector. Probable Regulatory horizon In Force Pending 1 Nov 2026 · ±quarter ### Egypt PDPL Executive Regulations — AML/data-sharing interface From 1 November 2026, cross-border personal-data transfers, including compliance data-sharing, require PDPC licensing/consent absent an approved mechanism. [Personal Data Protection Center (PDPC) Source](http://www.pdpc.gov.eg/) 1 dated · 1 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Egypt non-bank fintech licensing population expanded by thirteen entities across two October 2026 decisions. The expanding non-bank finance perimeter sits partly outside the banking-channel AML supervisory architecture, which may be relevant to correspondent and counterparty due diligence on Egyptian non-bank financial entities. 2 evidence refs Compliance ### Thirteen new or extended non-bank financial licences were approved in Egypt in October 2026. Firms with Egyptian counterparties or correspondent relationships in SME lending, securities, or consumer finance should note the growing population of licensed non-bank entities as part of ongoing counterparty due diligence. 2 evidence refs Board ### Egypt's non-bank financial sector continued rapid licensing growth in October 2026. The scale of market entry into Egypt's non-bank finance sector is a structural development relevant to any strategic exposure assessment in the market, though it carries no adverse enforcement signal. 2 evidence refs Risk ### Egypt's non-bank fintech licensing population grew by thirteen entities in a single two-week window. The licensing velocity outpaces any visible parallel expansion of non-bank-specific AML supervisory capacity, a concentration and capacity consideration for risk functions tracking Egypt exposure. 2 evidence refs Audit ### Thirteen non-bank financial entities were approved for licensing in Egypt in October 2026. Audit scope involving Egyptian non-bank financial counterparties should account for the expanding, recently-licensed population when assessing documentation and control maturity. 2 evidence refs Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No Egypt-nexus development located this cycle. T2 · EU AML Package / AMLA no_change Not applicable as a direct instrument to Egypt (non-EEA, non-UK autonomous jurisdiction). T3 · FATF Grey List no_change Egypt is not on the current FATF increased-monitoring list; the next FATF Plenary (28-30 Oct 2026) falls after this cycle's cutoff. T4 · Beneficial-Ownership Register Status no_change Egypt's UBO regime (Ministerial Decree No. 41/2020, CBE Guiding Manual Jan 2025) remains non-public, GAFI/ITDA-accessible only. T5 · Crypto & Digital-Asset Integrity no_change Egypt's blanket cryptoasset prohibition under Article 206 of Law No. 194/2020 remains unchanged; no CBE licence granted. T6 · Sanctions Regime Divergence no_change No new Egypt-specific OFAC/EU-Council/OFSI designation located in this window. Registers ### Enforcement actions - 3 Oct 2025 - 18 Dec 2025 - 28 Mar 2025 - 3 Oct 2025 - 2026-01 - MENAFATF adopted Egypt's 4th Enhanced Follow-up Report, re-rating Recommendation 3 (money laundering offence) from Partially Compliant to Largely Compliant, while confirming 3 recommendations (sanctions, MLA, extradition) remain Partially Compliant. 3 Oct 2025 - OFAC added an Egyptian-born, Dubai-based individual to the SDN List under an ICC-related sanctions authority as part of a December 2025 designation action, alongside issuance of a related wind-down general licence. 18 Dec 2025 - OFAC updated existing SDGT designations to add secondary-sanctions-risk information for individuals of Egyptian nationality/origin with historical al-Qaida links, as part of a broader March 2025 administrative list update. 28 Mar 2025 - The CBE continued implementing its mechanism under Governor's Resolution No. 45/2023 to identify, track and act against unlicensed money-transfer businesses, coordinating internal CBE units, law enforcement and international supervisory counterparts. 3 Oct 2025 ### Sanctions changes - 18 Dec 2025 - 28 Mar 2025 - OFAC listed Hatem Elsaid Farid Ibrahim Sakr, an Egyptian-born individual based in Dubai, on the SDN List under ICC-related sanctions authority (Executive Order 14203) in a December 2025 action. 18 Dec 2025 - OFAC's March 2025 administrative update added secondary-sanctions-risk information to previously designated Egyptian-nationality SDGT individuals linked to historical al-Qaida networks, without new underlying conduct findings. 28 Mar 2025 ### Regulatory horizon (register) - Egypt Cybercrime Law amendments criminalising online betting applications - Egypt PDPL Executive Regulations — AML/data-sharing interface - FinCEN Section 311 proposed rule re: Banque Misr UAE branches - Egypt's next MENAFATF Enhanced Follow-up Report - FATF underground-banking/hawala typology report ### Active schemes - [HIGH] Sinai/Gaza informal cross-border financing corridor - Unregulated TCSP corporate-service layering gap - Informal crypto trade despite CBE prohibition - Antiquities-trafficking laundering channel Sources - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-egypt-2025.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-egypt-2025.html) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-egypt-2021.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-egypt-2021.html) - [https://www.cbe.org.eg/en/aml-cft/egyptian-fiu](https://www.cbe.org.eg/en/aml-cft/egyptian-fiu) - [https://www.dailynewsegypt.com/2026/04/19/egypts-anti-money-laundering-unit-un-seek-closer-ties-to-target-transnational-financial-crime/](https://www.dailynewsegypt.com/2026/04/19/egypts-anti-money-laundering-unit-un-seek-closer-ties-to-target-transnational-financial-crime/) - [https://amlwatcher.com/our-coverage/egypt/](https://amlwatcher.com/our-coverage/egypt/) - [https://www.shandpartners.com/insights/briefings/corporate/egypts-new-beneficial-owners-register-requirements/](https://www.shandpartners.com/insights/briefings/corporate/egypts-new-beneficial-owners-register-requirements/) - [https://www.bylawme.com/post/money-laundering-laws-in-egypt](https://www.bylawme.com/post/money-laundering-laws-in-egypt) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Egypt.html) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofegypt.html) - [Lexology](https://www.lexology.com/library/detail.aspx?g=7847a9bd-cfca-40d4-b749-8afe09010873) - [Voveid](https://blog.voveid.com/aml-compliance-in-egypt-a-2025-guide-for-fintechs-and-regulated-businesses/) - [Lexology](https://www.lexology.com/library/detail.aspx?g=a21a3371-3157-4c46-8ab2-1e15e9a59450) - [The Spotlite](https://thespotlite.net/egypt-crypto-ban-law-194-of-2020-explained) - [AML Watcher](https://amlwatcher.com/our-coverage/egypt/) - [AML UAE](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [Yogonet](https://www.yogonet.com/international/news/2026/09/09/126293-cambodia-tightens-casino-rules-with-new-license-standards-and-october-proxy-betting-ban) - [National Law Review](https://natlawreview.com/article/fincen-proposes-designate-banque-misr-uae-primary-money-laundering-concern-and) - [The National](https://www.thenationalnews.com/business/banking/2026/08/30/uae-central-bank-orders-urgent-probe-into-banque-misr-branches-after-us-warning/) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-egypt-2024.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-egypt-2024.html) - [https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Egypt-FUR-MENAFATF-May-2024.pdf](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Egypt-FUR-MENAFATF-May-2024.pdf) - [https://www.gafi.gov.eg/English/StartaBusiness/Laws-and-Regulations/Documents/MoneyLaunderingLaw.pdf](https://www.gafi.gov.eg/English/StartaBusiness/Laws-and-Regulations/Documents/MoneyLaunderingLaw.pdf) - [https://www.zigram.tech/article/transaction-monitoring-egypt](https://www.zigram.tech/article/transaction-monitoring-egypt) - [https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/](https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/) - [https://globalsanctions.com/region/egypt/](https://globalsanctions.com/region/egypt/) - [https://fintech.global/2026/09/21/paymob-raises-35m-to-fuel-mena-payments-growth/](https://fintech.global/2026/09/21/paymob-raises-35m-to-fuel-mena-payments-growth/) - [https://egyptinnovate.com/en/news/10-egyptian-fintech-companies-named-among-forbes-middle-easts-top-50-fintech-companies-2026](https://egyptinnovate.com/en/news/10-egyptian-fintech-companies-named-among-forbes-middle-easts-top-50-fintech-companies-2026) - [https://resourcehub.bakermckenzie.com/en/resources/global-financial-services-regulatory-guide/europe-middle-east-and-africa/egypt/topics/what-types-of-activities-require-a-license-in-your-jurisdiction](https://resourcehub.bakermckenzie.com/en/resources/global-financial-services-regulatory-guide/europe-middle-east-and-africa/egypt/topics/what-types-of-activities-require-a-license-in-your-jurisdiction) - [https://enterpriseam.com/egypt/2026/10/04/the-cbe-issued-updated-anti-money-laundering-rules-binding-on-banks-and-their-foreign-branches/](https://enterpriseam.com/egypt/2026/10/04/the-cbe-issued-updated-anti-money-laundering-rules-binding-on-banks-and-their-foreign-branches/) - [https://www.fatf-gafi.org/en/countries/global-network/middle-east-and-north-africa-financial-action-task-force--menafa.html](https://www.fatf-gafi.org/en/countries/global-network/middle-east-and-north-africa-financial-action-task-force--menafa.html) - [https://www.licentium.io/hub/egypt](https://www.licentium.io/hub/egypt) - [https://en.wikipedia.org/wiki/HSBC_Bank_Egypt](https://en.wikipedia.org/wiki/HSBC_Bank_Egypt) - [https://www.dailynewsegypt.com/2026/10/18/fra-approves-six-companies-to-conduct-non-banking-financial-activities-using-fintech/](https://www.dailynewsegypt.com/2026/10/18/fra-approves-six-companies-to-conduct-non-banking-financial-activities-using-fintech/) - [https://fra.gov.eg/en/](https://fra.gov.eg/en/) - [https://www.dailynewsegypt.com/2026/10/20/fra-approves-seven-companies-entities-for-non-banking-financial-activities/](https://www.dailynewsegypt.com/2026/10/20/fra-approves-seven-companies-entities-for-non-banking-financial-activities/) - [https://www.fatf-gafi.org/en/countries/detail/Egypt.html](https://www.fatf-gafi.org/en/countries/detail/Egypt.html) - [https://www.legalmondo.com/product/ultimate-beneficial-owners-egypt/](https://www.legalmondo.com/product/ultimate-beneficial-owners-egypt/) - [https://blog.voveid.com/aml-compliance-in-egypt-a-2025-guide-for-fintechs-and-regulated-businesses/](https://blog.voveid.com/aml-compliance-in-egypt-a-2025-guide-for-fintechs-and-regulated-businesses/) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [Egypt](https://www.fatf-gafi.org/en/countries/detail/Egypt.html) - [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Countries / Jurisdictions](http://www.fatf-gafi.org/countries/#Egypt) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [Outcomes FATF Plenary, 17-19 June 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [4th Enhanced Follow-up Report for the Arab Republic of ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Egypt-MENAFATF-FUR-2025.pdf.coredownload.inline.pdf) - [Egypt's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-egypt-2025.html) - [3rd Enhanced Follow-up Report for the Arab Republic of ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Egypt-FUR-MENAFATF-May-2024.pdf) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Egypt's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-egypt-2021.html) - [History of Anti-Money Laundering Laws | FinCEN.gov](https://www.fincen.gov/resources/history-anti-money-laundering-laws) - [FATF publishes new Guidance on Financial Inclusion and Anti-Money Laundering and Terrorist Financing Measures](https://www.fatf-gafi.org/en/publications/Financialinclusionandnpoissues/guidance-financial-inclusion-aml-tf-measures.html) - [FinCEN Proposes Rule to Fundamentally Reform Financial Institution Programs Designed to Fight Illicit Finance | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [OFAC Related Press Releases | Office of Foreign Assets Control](https://ofac.treasury.gov/press-releases) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [Russian Harmful Foreign Activities Sanctions](https://ofac.treasury.gov/faqs/topic/6626) - [Iran-related Designations; International Criminal Court-related Designations; Russia-related Designations Removals; Foreign Sanctions Evaders Determination Removal; Issuance of Iran-related and International Criminal Court-related General Licenses | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251218) - [Ukraine-/Russia-related Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/ukraine-russia-related-sanctions) - [Sanctions List Updates](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions) - [Counter Terrorism Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/counter-terrorism-sanctions) - [United States Department of the Treasury Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/advisory/advis30.pdf) - [Egypt Seizes $178 Million in Money Laundering Crackdown | OCCRP](https://www.occrp.org/en/news/egypt-seizes-178-million-in-money-laundering-crackdown) - [FinCEN Advisory](https://www.fincen.gov/sites/default/files/advisory/advis30.pdf) - [FinCEN Advisory - Issue 30 | FinCEN.gov](https://www.fincen.gov/resources/advisories/fincen-advisory-issue-30) - [The Arab Republic of Egypt May 2021](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/MENAFATF-MER-Egypt-2021-English.pdf) - [Egypt: Online Tools in Criminal Investigations - A Must to Combat Organized Crime and Money-Laundering](https://www.unodc.org/romena/en/Stories/2018/March/egypt_-online-tools-in-criminal-investigations--a-must-to-combat-organized-crime-and-money-laundering.html) - [Egypt: Expert group meeting on Financial Red Flags indicators for Trafficking in Persons and Smuggling of Migrants](https://www.unodc.org/romena/en/Stories/2019/August/egypt_-expert-group-meeting-on-financial-red-flags-indicators-for-trafficking-in-persons-and-smuggling-of-migrants.html) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [FSB thematic review 2025: Global crypto regulation remains fragmented despite market growth](https://www.elliptic.co/blog/fsb-thematic-review-2025) - [Global crypto regulation review 2025](https://www.elliptic.co/resources/global-crypto-regulation-review-2025) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Central bank digital currency (CBDC)](https://www.trmlabs.com/glossary/central-bank-digital-currency) - [2025 Crypto regulatory and policy outlook: 5 Trends to expect for the year ahead](https://www.elliptic.co/blog/2025-crypto-regulatory-and-policy-outlook-5-trends-to-expect-for-the-year-ahead) - [Cryptocurrency Regulation: How Governments Around the World Regulate Crypto](https://www.chainalysis.com/blog/cryptocurrency-regulation-explained/) - [Crypto-assets: how the EU is regulating markets - Consilium](https://www.consilium.europa.eu/en/policies/crypto-assets-how-the-eu-is-regulating-markets/) - [Closing of smuggling tunnels hits Gazans hard - Voice of America article/Non-UN document - Question of Palestine](https://www.un.org/unispal/document/auto-insert-194422/) - [Palestinian Smuggling Tunnels Destroyed | OCCRP](https://www.occrp.org/en/news/palestinian-smuggling-tunnels-destroyed) - [Hamas' Secret Tunnel Network Complicates Israel’s Gaza Ground Invasion Plans - Bloomberg](https://www.bloomberg.com/news/articles/2023-10-13/the-secret-tunnel-network-complicating-israel-s-ground-offensive-in-gaza) - [Why Egypt Is Flooding the Gaza Strip's Tunnels - Bloomberg](https://www.bloomberg.com/news/articles/2013-02-13/why-egypt-is-flooding-the-gaza-strips-tunnels) - [UK, US and Australia sanction key figures in Hamas’s financial network - GOV.UK](https://www.gov.uk/government/news/uk-and-us-sanction-key-figures-in-hamass-financial-network) - [FinCEN Alert, FIN-2023-Alert006, October 20, 2023](https://www.fincen.gov/sites/default/files/2023-10/FinCEN_Alert_Terrorist_Financing_FINAL508.pdf) - [Counter Terrorism Designations; Counter Narcotics Designation Removal | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20240327) - [FinCEN Alert Hizballah Alert](https://www.fincen.gov/sites/default/files/shared/FinCEN-Alert-Hizballah-Alert-508C.pdf) - [WEST BANK AND GAZA REPORT ON MACROECONOMIC DEVELOPMENTS AND OUTLOOK1](https://unispal.un.org/pdfs/IMF_MacroRpt.pdf) - [OFAC Sanctions Gaza-based MSB Buy Cash with Crypto Ties to Hamas Following Terror Attack Against Israel - Chainalysis](https://www.chainalysis.com/blog/ofac-sanctions-buy-cash-with-hamas-ties-following-terror-attack-israel/) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [Anti-money laundering: the Commission updates its list of high-risk third-country jurisdictions to strengthen the international fight against financial crime - Finance](https://finance.ec.europa.eu/news/anti-money-laundering-commission-updates-its-list-high-risk-third-country-jurisdictions-strengthen-2022-12-20_en) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [Commission adds Russia to list of high-risk jurisdictions to strengthen international fight against financial crime](https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2910) - [In Egypt, More High-ranking Arrests in Antiquities Trafficking Ring | OCCRP](https://www.occrp.org/en/news/in-egypt-more-high-ranking-arrests-in-antiquities-trafficking-ring) - [Protection from Illicit Trading in Cultural Property](https://www.unodc.org/documents/treaties/organized_crime/Egypt.pdf) - [Egypt: Follow the Money and Find the Trafficker: Financial Investigation workshop to address Trafficking in Persons and Smuggling of Migrants](https://www.unodc.org/romena/en/Stories/2019/October/egypt_-follow-the-money-and-find-the-trafficker_-financial-investigation-workshop-to-address-trafficking-in-persons-and-smuggling-of-migrants.html) - [About the Pandora Papers - ICIJ](https://www.icij.org/investigations/pandora-papers/about-pandora-papers-investigation/) - [In terms of land area, Egypt is the second biggest of the ...](https://www.unodc.org/pdf/egypt/egypt_country_profile.pdf) - [Countering Russian sanctions evasion - guidance for businesses - GOV.UK](https://www.gov.uk/government/publications/countering-russian-sanctions-evasion-and-circumvention/countering-russian-sanctions-evasion-guidance-for-exporters) - [EU's 20th Russia Sanctions Package](https://www.chainalysis.com/blog/eu-russia-sactions-package-april-2026/) - [1 EXPORT-RELATED RESTRICTIONS FOR DUAL-USE GOODS AND ADVANCED TECHNOLOGIES](https://finance.ec.europa.eu/document/download/586f9b62-50c3-46e3-9940-de73ae96a24b_en?filename=faqs-sanctions-russia-export-related-restrictions-russia_en.pdf) - [Sanctions on dual-use goods - European Commission](https://eu-solidarity-ukraine.ec.europa.eu/eu-sanctions-against-russia-following-invasion-ukraine/sanctions-dual-use-goods_en) - [Sanctions and Evasion Updates: Insights from OCCRP](https://gacc.occrp.org/post/sanctions-and-evasion-updates) - [EU sanctions against Russia: questions and answers - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia-explained/) - [1 Preventing Russian Export Control and Sanctions Evasion:](https://finance.ec.europa.eu/document/download/ae2e63e2-4c4d-4f77-9757-c408ddbcede1_en?filename=240924-preventing-russian-export-control-sanctions-evasion+.pdf) - [Exporting dual-use items - Trade and Economic Security](https://policy.trade.ec.europa.eu/help-exporters-and-importers/exporting-dual-use-items_en) - [Sanctions adopted following Russia’s military aggression against Ukraine - Finance](https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/sanctions-adopted-following-russias-military-aggression-against-ukraine_en) - [Counter Terrorism Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20240130) - [Counter Terrorism Designations; Administrative List Updates: Addition of Secondary Sanctions Information | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250328) - [Counter Terrorism Designations and Designations Updates | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20210114) - [Revocation of Syria Sanctions; Publication of Syria Frequently Asked Questions; Syria and Syria-related Designation Updates and Removals | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250630) - [[Withdrawn] Financial sanctions, Egypt - GOV.UK](https://www.gov.uk/government/publications/financial-sanctions-egypt) - [EGYPTIAN ISLAMIC JIHAD | Security Council](https://main.un.org/securitycouncil/en/sanctions/1267/aq_sanctions_list/summaries/entity/egyptian-islamic-jihad) - [Egypt Central Bank Eases Currency Rules to Clear Import Backlog - Bloomberg](https://www.bloomberg.com/news/articles/2022-09-20/egypt-central-bank-eases-currency-rules-to-clear-import-backlog) - [Major Egypt Banks Suspend Debit-Card Use in Foreign Currency - Bloomberg](https://www.bloomberg.com/news/articles/2023-10-09/major-egypt-banks-suspend-debit-card-use-in-foreign-currency) - [Egypt to Introduce Currency Hedging, Central Bank Governor Says - Bloomberg](https://www.bloomberg.com/news/articles/2022-10-23/egypt-to-introduce-currency-hedging-central-bank-governor-says) - [Regulating the no man’s coin – the rapid rise of cryptocurrencies has regulators scratching their heads | UN DESA | United Nations Department of Economic and Social Affairs](https://www.un.org/development/desa/en/news/policy/cryptocurrencies.html) - [Egypt: EU revokes sanctions framework and delists 9 people - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2021/03/12/egypt-eu-revokes-sanctions-framework-and-delists-9-people/) - [The Egypt (Asset-Freezing) Regulations 2011](https://www.legislation.gov.uk/uksi/2011/887/contents/made) - [Council Regulation (EU) No 270/2011 of 21 March 2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Egypt](https://www.legislation.gov.uk/eur/2011/270/adopted) - [The Misappropriation (Sanctions) (EU Exit) Regulations 2020](https://www.legislation.gov.uk/uksi/2020/1468/part/8/made) - [The Egypt (Asset-Freezing) Regulations 2011 (revoked)](https://www.legislation.gov.uk/uksi/2011/887/contents) - [EU restrictive measures](https://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/en/foraff/135804.pdf) - [Overview of sanctions and related resources - Finance - European Commission](https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/overview-sanctions-and-related-resources_en) - [ASSET FREEZE AND PROHIBITION TO MAKE FUNDS AND ECONOMIC RESOURCES AVAILABLE](https://finance.ec.europa.eu/document/download/c7265161-3d9c-42e2-a928-e5b38c02bb92_en?filename=faqs-sanctions-russia-assets-freezes_en.pdf) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Egypt.html) - [MENAFATF / FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-egypt-2021.html) - [MENAFATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/MENAFATF-MER-Egypt-2021-English.pdf) - [MENAFATF / FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-egypt-2025.html) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [MENAFATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Egypt-MENAFATF-FUR-2025.pdf.coredownload.inline.pdf) - [MENAFATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Egypt-FUR-MENAFATF-May-2024.pdf) - [European Commission](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [HM Treasury](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [US Treasury OFAC](https://ofac.treasury.gov/recent-actions/20251218) - [US Treasury OFAC](https://ofac.treasury.gov/recent-actions/20250328) - [FinCEN](https://www.fincen.gov/resources/advisories/fincen-advisory-issue-30) - [UN Security Council](https://main.un.org/securitycouncil/en/sanctions/1267/aq_sanctions_list/summaries/entity/egyptian-islamic-jihad) - [Council of the EU](https://www.consilium.europa.eu/en/press/press-releases/2021/03/12/egypt-eu-revokes-sanctions-framework-and-delists-9-people/) - [OCCRP](https://www.occrp.org/en/news/in-egypt-more-high-ranking-arrests-in-antiquities-trafficking-ring) - [ICIJ](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) Coverage gaps fim-int-2026-07-07-G001: The ratified typology library (sent… fim-int-2026-07-07-G001: The ratified typology library (sentinel-typology-library-v1.0.json) was not provided as context this cycle, preventing Task 11C typology matching against Egypt's developments. [resolved] fim-int-2026-07-07-G002: No dedicated recent (18-month windo… fim-int-2026-07-07-G002: No dedicated recent (18-month window) investigative or regulatory reporting quantifies current Sinai/Gaza-adjacent hawala or informal-value-transfer flows tied to CTF risk; available sourcing is largely pre-2020. [resolved] fim-int-2026-07-07-G003: Egypt's 5th MENAFATF Enhanced Follo… fim-int-2026-07-07-G003: Egypt's 5th MENAFATF Enhanced Follow-up Report outcome, due at the 42nd Plenary (May 2026), is not yet reflected in public FATF documents. [resolved] fim-int-2026-07-07-G004: No quantitative data establishes th… fim-int-2026-07-07-G004: No quantitative data establishes the scale of informal cryptocurrency adoption relative to Egypt's formal economy, limiting confidence beyond directional (worsening) trend assessment. [resolved] fim-int-2026-07-07-G005: No confirmed evidence links Egyptia… fim-int-2026-07-07-G005: No confirmed evidence links Egyptian free-zone (GAFI) re-export activity to specific shadow-fleet vessels or Russia-sanctions-evasion transactions, leaving the T1 tracker's Egypt exposure assessment as latent/structural rather than confirmed. [resolved] fim-int-2026-08-05-G001: No Egypt-specific conflict-finance … fim-int-2026-08-05-G001: No Egypt-specific conflict-finance development was located this cycle; only the Suez Canal trade-chokepoint structural factor was identified. [resolved] fim-int-2026-08-05-G002: Tier D mandatory sweep (KH/LA/MX/CO… fim-int-2026-08-05-G002: Tier D mandatory sweep (KH/LA/MX/CO) was not independently conducted this cycle. [resolved] fim-int-2026-08-05-G003: The Rec.24/28/3 partial-compliance … fim-int-2026-08-05-G003: The Rec.24/28/3 partial-compliance breakdown is sourced from a Tier-4 secondary summary; the primary FATF FUR recommendation-level table has not been independently verified this cycle. [resolved] fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No sourced material was found this cycle for D1 (sanctions), D3 (enabler jurisdictions), D4 (conflict finance), or D6 (compliance technology) specific to Egypt; this pooled single-JID pass allocated search budget to EG-specific queries. [resolved] fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): Egypt's beneficial-ownership register lacks a T1 gazette source confirming the current status of Ministerial Decree No. 41/2020; only T4 secondary commentary was available this cycle. [resolved] fim-int-2026-08-21-G003: Tier-D watch jurisdictions KH/LA/MX… fim-int-2026-08-21-G003: Tier-D watch jurisdictions KH/LA/MX/CO were not actively searched this cycle given the pooled single-JID (EG) search-budget allocation. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D4'}): No dedicated Egypt-specific conflict-finance (D4) query was run this cycle; the D4 search budget was directed at the mandatory Tier-D watch sweep, leaving Egypt's D4 exposure genuinely unassessed rather than confirmed absent. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No primary MENAFATF Mutual Evaluation Report or enhanced follow-up report text was retrieved this cycle for the R.3/R.24/R.28 partial-compliance characterisations; these rest on T2/T4 secondary sources. [resolved] fim-int-2026-10-04-G001: Tier D watch jurisdictions (Cambodi… fim-int-2026-10-04-G001: Tier D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) were not actively re-swept this cycle, as the pooled research budget was concentrated on the bound jurisdiction (EG) and its Banque Misr nexus. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2 (beneficial ownership), D4 (conflict finance), and D6 (compliance technology) had thin or no coverage for Egypt this cycle. [resolved] fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): The primary FinCEN/Federal Register instrument (91 FR 56085) for the Banque Misr Section 311 proposal was not directly retrieved this cycle, capping confidence at Probable rather than Confirmed. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Tier-1 Egyptian corporate-registry source confirming current beneficial-ownership register mechanics was reached this cycle. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No Egypt-specific enabler-jurisdiction finding located this cycle; relevant professional-facilitator sources not reached. [resolved] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D4'}): No Egypt-specific conflict-finance finding located this cycle. [resolved] fim-int-2026-10-11-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G004 ({'scheme': 'financial_integrity', 'value': 'D7'}): No Tier-1 instrument text for the exact CDD reporting threshold figure (~USD 15,000) was retrieved this cycle; only T3 compliance-vendor support exists. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No official primary CBE circular text was obtained for the October 2026 AML/CDD update; reliance is on T3 press reporting. [open] fim-int-2026-10-18-G002: Tier D jurisdiction collection (Cam… fim-int-2026-10-18-G002: Tier D jurisdiction collection (Cambodia, Laos, Mexico, Colombia) was not separately actioned this cycle; pooled search budget was directed to EG-bound queries. [open] fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): Beneficial-ownership register status and enabler-jurisdiction/professional-facilitator findings specific to Egypt were not surfaced this cycle, reflecting thin coverage rather than confirmed absence. [open] fim-int-2026-10-25-G001: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-10-25-G001: Tier D jurisdictions (KH, LA, MX, CO) were not actively re-swept this cycle given the single-jurisdiction dispatch scope of this run. [open] fim-int-2026-10-25-G002: Primary MENAFATF follow-up report t… fim-int-2026-10-25-G002: Primary MENAFATF follow-up report text was not directly opened this cycle; the 36/40 FATF-Recommendation compliance figure rests on secondary T3/T4 commentary rather than the primary document. [open] FIM-GAP-001 (D2): Egypt's legal framework requires a predica… FIM-GAP-001 (D2): Egypt's legal framework requires a predicate-offense conviction before money laundering can be prosecuted, and MENAFATF's assessment found ML investigation patterns limited largely to domestic self-laundering, with the legal system unable to detect stand-alone ML patterns. FIM-GAP-002 (D2): TCSPs are not covered by Egyptian AML/CFT … FIM-GAP-002 (D2): TCSPs are not covered by Egyptian AML/CFT legislation, and there is no legal prohibition on non-lawyer/non-accountant persons providing corporate services, rated Partially Compliant under R.22. FIM-GAP-003 (D1): Egypt's targeted financial sanctions imple… FIM-GAP-003 (D1): Egypt's targeted financial sanctions implementation (R.35) remains rated Partially Compliant, indicating technical shortfalls in the framework Egypt uses to implement UN Security Council sanctions designations domestically. FIM-GAP-004 (D3): Mutual legal assistance (R.37) and extradi… FIM-GAP-004 (D3): Mutual legal assistance (R.37) and extradition (R.39) frameworks remain Partially Compliant, with MENAFATF noting some concerns over quality and expediency of responses and volume of outgoing MLA requests relative to Egypt's risk profile. FIM-GAP-005 (D4): No dedicated recent (18-month window) inve… FIM-GAP-005 (D4): No dedicated recent (18-month window) investigative or regulatory reporting was identified quantifying current Sinai/Gaza-adjacent hawala or informal-value-transfer flows tied to CTF risk; available sourcing on the tunnel economy and cross-border informal finance is largely pre-2020. ## Evidence #### Confidence-tiered claims CBE's AML unit issued updated customer due diligence guidelines for banks and their foreign branches, formally incorporating eKYC practices into the post-2020 AML Act framework. [[Source 1]](#sec-sources) Probable · 1 source Recommendation 3 re-rated from Partially Compliant to Largely Compliant, bringing standing to 11 Compliant, 26 Largely Compliant, 3 Partially Compliant of the FATF 40. [[Source 1]](#sec-sources) Probable · 1 source 35000000 USD pre-Series C, co-led by Mubadala Investment Company and EBRD, announced 2026-09-21 [[Source 1]](#sec-sources) Probable · 1 source 1400000000 USD valuation investment round plus planned EGX IPO of 20pct shares, October 2026 [[Source 1]](#sec-sources) Probable · 1 source FinCEN proposed a Section 311 special measure against Banque Misr's five UAE branches, citing approximately USD 1.8 billion moved through 103 suspected Iranian shadow-banking front companies between January 2024 and June 2026. [[Source 1]](#sec-sources) Probable · 1 source The UAE Central Bank ordered a special and urgent examination into Banque Misr's UAE branches following the US FinCEN warning, a domestic response distinct from and not contingent on the US finding. [[Source 1]](#sec-sources) Probable · 1 source Egypt does not appear among jurisdictions added to or removed from the FATF grey list at the 19 June 2026 plenary (Bosnia and Herzegovina, Iraq added; Algeria, Namibia removed); no later plenary action located this cycle. [[Source 1]](#sec-sources) Probable · 1 source Egypt's blanket cryptoasset prohibition under CBE Law 194/2020 Art. 206 remains unchanged this cycle; no CBE licence has been issued to any crypto platform. [[Source 1]](#sec-sources) Probable · 1 source The EU AML Package (AMLR/6AMLD/AMLA) trackers remain not applicable to Egypt as a non-EEA jurisdiction. Probable Recommendations 14, 15, 22 and 23 re-rated to Compliant/Largely Compliant per May 2024 MENAFATF enhanced follow-up report [[Source 1]](#sec-sources) Probable · 1 source Egyptian Money Laundering and Terrorist Financing Combating Unit (EMLCU) as FIU and AML supervisory structure [[Source 1]](#sec-sources) Probable · 1 source CDD required on transactions at approximately USD 15,000, EDD for higher-risk customers, five-year minimum record retention [[Source 1]](#sec-sources) Probable · 1 source not_on_grey_or_black_list_as_of_19_june_2026_plenary [[Source 1]](#sec-sources) Probable · 1 source Not currently subject to active EU, US or UK country-level sanctions regime; EU's 2011 Arab-Spring-era asset-freeze regime against Egypt was revoked in 2021. [[Source 1]](#sec-sources) Probable · 1 source cryptocurrency_prohibited_under_law_194_2020_art_206_unchanged [[Source 1]](#sec-sources) Probable · 1 source AML/CFT regime supervised by CBE (banks) and Financial Regulatory Authority (non-bank entities); EMLCU is the FIU, analysing STRs via GoAML. [[Source 1]](#sec-sources) Probable · 1 source Crypto-asset issuance, trading, promotion, or platform operation without prior CBE approval is unlawful; no approvals granted since enactment. [[Source 1]](#sec-sources) Probable · 1 source Not on FATF's Jurisdictions under Increased Monitoring list as of 24 October 2025; remains in MENAFATF enhanced follow-up (a separate, lower-visibility process). [[Source 1]](#sec-sources) Probable · 1 source Six companies approved 18 October 2026 for fintech-based non-banking financial activities including securities custody/trading, SME lending and outsourcing technology provision. [[Source 1]](#sec-sources) Probable · 1 source Seven further companies and entities approved 20 October 2026, including a bond-dealing licence extension for Golden Way Securities and Bonds Brokerage. [[Source 1]](#sec-sources) Probable · 1 source Unchanged; EMLCU is FIU, CBE/FRA are sectoral supervisors, MENAFATF assesses compliance; 36 of 40 FATF Recommendations reported fully/largely compliant per May 2024 enhanced follow-up, with partial compliance on R.3, R.24, R.28. [[Source 1]](#sec-sources) Probable · 1 source UBO register remains non-public, accessible only via GAFI/ITDA and to judicial officers; implemented via ITDA from December 2022; CBE issued a Guiding Manual on UBO identification for banks on 8 January 2025. [[Source 1]](#sec-sources) Probable · 1 source Blanket criminal prohibition on issuance, trading, promotion or operation of a cryptoasset platform without prior CBE approval remains in force; no approval has been granted. [[Source 1]](#sec-sources) Probable · 1 source Law No. 80 of 2002 remains the governing AML/CFT instrument; EMLCU functions as FIU via GoAML; Egypt remains in MENAFATF enhanced follow-up with R.3 upgraded in 2025 and R.24/R.28 partially compliant. [[Source 1]](#sec-sources) Probable · 1 source CBE issued updated customer due diligence guidelines for banks operating in Egypt and their foreign branches, dated 4 October 2026. [[Source 1]](#sec-sources) Probable · 1 source Professional-body analysis continues to link licensed and unlicensed casino infrastructure in Cambodia to scam-compound and money-laundering networks, alongside Cambodia's own August 2026 licence-revocation action. [[Source 1]](#sec-sources) Probable · 1 source FATF's October 2026 increased-monitoring statement records continued technical-compliance progress on Laos's targeted financial sanctions regime for terrorist financing. [[Source 1]](#sec-sources) Probable · 1 source October 2026 Plenary removed Bulgaria, Côte d'Ivoire, DRC and Monaco from the increased-monitoring list; list narrows from 22 to 18 jurisdictions with no additions. [[Source 1]](#sec-sources) Probable · 1 source Law No. 80 of 2002, EMLCU as FIU; MENAFATF ratings show non-compliance on R.7, R.22, R.26; no amendment located this cycle [[Source 1]](#sec-sources) Probable · 1 source No EG-specific RegTech/AI-ML supervisory development located this cycle; placeholder watch row [[Source 1]](#sec-sources) Uncertain · 1 source Unlicensed crypto issuance, trading, promotion remains a criminal offence; no licence granted to date [[Source 1]](#sec-sources) Probable · 1 source