6
Supervisory bodies
2
Financial regulators
9
Sectors covered
1
National FIU / EMLCU
02The regulatory landscape
02
One line splits Egyptian supervision
Egypt splits financial-crime oversight along a clear line. Licensed financial sectors sit under a prudential regulator. Designated non-financial businesses and professions carry full AML obligations with no dedicated financial regulator, AML-supervised under the national framework with the financial intelligence unit as the constant. What an examiner tests: that you built to the correct authority for your side of that line. We map every operator to the right body before a control is drafted.
- Licensed side: a bank or payments firm holds a live licence and a named prudential supervisor.
- DNFBP side: a gold dealer, real-estate agent or high-value-goods trader holds neither, yet carries the same customer-due-diligence, screening and reporting duties under AML Law 80/2002, enforced through the EMLCU.
- The error that trips operators is registration versus licence versus AML-only supervision. Building the wrong programme for the wrong side is common and costly.
VASP & crypto
CBEFRA The Central Bank of Egypt is in scope where virtual-asset activity touches banking or money movement. The Financial Regulatory Authority is in scope where it touches capital-market instruments or the non-bank financial sector. The same firm can answer to either, depending on the activity.
Payments & MSB
CBE The Central Bank of Egypt licenses payments, money services and foreign-exchange bureaux, and publishes the register of licensed foreign-exchange bureaux and their branches. A CBE file is a full licensing relationship, not a registration.
Banks & FIs
CBEFRA The Central Bank of Egypt supervises banks and financial institutions and publishes its licence lists. The Financial Regulatory Authority supervises the non-bank financial institutions, with its financing-sector listings on its site.
Funds & CSP
FRA The Financial Regulatory Authority supervises the non-bank financial sector: capital markets, funds and fund administration, financing and leasing, and corporate service provision. FRA supervision is a licensing or a registration relationship depending on the activity.
Gold & DPMS
EMLCU No dedicated financial regulator. Dealers in precious metals and stones carry DNFBP AML duties under AML Law 80/2002, supervised through the Egyptian Money Laundering and Terrorist Financing Combating Unit, the national financial intelligence unit. The absence of a bespoke supervisor does not reduce the duty.
Gaming
MoTA The Ministry of Tourism and Antiquities governs the tourism-linked activity relevant to gaming. Integrity and AML controls for gaming operations sit under the tourism and antiquities regime.
Real estate & DNFBP
FRAEMLCU Real-estate-linked financial activity sits with the Financial Regulatory Authority. The wider designated non-financial businesses and professions have no single dedicated regulator and are AML-supervised under AML Law 80/2002 through the EMLCU, which also receives suspicious transaction reports from every regulated operator and every DNFBP.
Defence & dual-use
GOEICMoD / MoMP The General Organization for Export and Import Control and the Ministry of Defence and Military Production, including the Ministry of Military Production, govern export, import and dual-use controls for defence-linked trade. This is export-control and integrity exposure, not classic AML supervision.
Art & high-value
SCA / MoTAEMLCU Antiquities and cultural property fall to the Supreme Council of Antiquities under the Ministry of Tourism and Antiquities. General high-value-goods dealers carry AML duties via the EMLCU under AML Law 80/2002: provenance, source-of-funds and AML controls.
Every regulator above is drawn from the verified Egypt regulator matrix. We state what the current framework requires. Where a recent CBE or FRA circular or an EMLCU guidance update would sharpen the plan, we verify it against the regulator's own published materials first. No date, threshold or penalty is asserted here.
03Who operates here, and what they build
Egypt is a large, cash-intensive market with heavy remittance and foreign-exchange flow, and it draws supervisory attention unevenly: the licensed operator faces a prudential supervisor with a visit schedule, the DNFBP faces an AML regime it often did not know applied. What an examiner tests: a working programme, not a binder. Whether you are CBE-licensed, FRA-supervised or EMLCU-obligated, you build and keep running:
01A documented enterprise AML/CFT risk assessment, tuned to Egyptian typologies (cash intensity, informal value transfer, foreign-exchange and remittance exposure), that a supervisor can test.
02Customer due diligence and beneficial-ownership checks that hold up under review, with enhanced measures for higher-risk relationships and politically exposed persons.
03Sanctions and watchlist screening calibrated to real exposure, not a switched-on default, covering United Nations and other applicable designations.
04Transaction monitoring that produces defensible alerts and a clean path to a suspicious transaction report filed with the EMLCU.
05A named, competent MLRO and a reporting function that actually functions, with a documented escalation line.
06Independent testing, board or senior-management reporting, and a training programme that leaves a record.
Most enforcement does not begin with a missing licence. It begins with a programme that reads well and works badly, or an obligation the operator never realised it carried. That is the gap we close.
04By sector here
How we serve every sector here
Nine sectors. Even weight. No flagship. Each card is the Egypt-specific build for that sector, mapped to the real supervisor and delivered with the same seniority and fixed-scope discipline. If a sector is not right for us, we say so before you engage.
VASP & cryptoCBE and FRA. Programme build and screening for virtual-asset activity where it touches banking, money movement or capital-market instruments, including the FATF Travel Rule.
Payments & MSBCBE. AML controls, agent oversight, and the obligations that sit on licensed money services and foreign-exchange bureaux.
Banks & FIsCBE. Full programme build, remediation and independent audit for banks and financial institutions under central-bank supervision.
Funds & CSPFRA. AML frameworks for funds, administrators and corporate service providers in the non-bank financial sector.
Gold & DPMSEMLCU under AML Law 80/2002. Dealer AML programmes, source-of-funds controls and reporting where no dedicated financial regulator supervises.
GamingMoTA. Integrity and AML controls for gaming and tourism-linked operations under the tourism and antiquities ministry.
Real estate & DNFBPFRA and EMLCU. Real-estate-linked financial activity with FRA; wider DNFBPs AML-supervised under AML Law 80/2002 through the EMLCU.
Defence & dual-useGOEIC and MoD / MoMP. Export-control, sanctions and integrity due diligence for defence-linked trade and dual-use goods.
Art & high-valueSCA / MoTA and EMLCU. Provenance, source-of-funds and AML controls for antiquities, cultural property and high-value goods.
05The five service lines, in this market
01
Licensing and new-regime programme build. The controls a CBE or FRA file needs behind it, or the full DNFBP AML programme where no financial regulator supervises you, built to scope.
02
Remediation. Post-finding or post-enforcement rebuild, with a plan a supervisor or the EMLCU will accept.
03
Outsourced and bridge MLRO, plus a managed financial-intelligence function. We hold the role, or bridge it, and run the reporting line into the EMLCU.
04
Independent AML audit. The independent test your framework requires, delivered by senior reviewers.
05
Sanctions, export-control and integrity due diligence. Screening, dual-use controls, and the FATF Travel Rule.
06The operator-side value
Conflict-free
Lawyers file. We build the compliance. Where the same advisers often sell the licence and the tooling, our independence is the point: no commission, no product, answerable to the operator alone. When we sign off on a control, nothing else is riding on it.
Senior-only
The person who scopes the work is the person who does it. No junior handover.
Fixed scope, fixed fee
No hourly billing. A costed plan within 48 hours of the first call. You know what you are buying before you commit.
Real proof, not invented proof. We do not publish client names or invent case studies. The proof below is the proof, and it is real.
Briefing seriesCurrent and datedA standing regulatory briefing series at blackseabriefings.substack.com, current and dated.Insights →
Local partnersLocal legal standingLicensed local law-firm and compliance partners in our markets.Partners →
CredentialsCAMS / ICAPractitioner credentials on the team. No client names, no invented cases.The firm →
Build the programme behind your Egyptian licence.
Confidential. Tell us the licence, the sector and where the programme stands. We return a scoped, costed plan within 48 hours. Fixed scope. No hourly billing.
operations@blackseaspv.com · Briefings: blackseabriefings.substack.com