How is Egypt's AML legal framework built? Law 80 of 2002 and five amendments
On 11 March 2020, Law 17 of 2020 amended the penalty article of Law 80 of 2002 and added virtual assets to its definition of funds. On 21 September 2026, the EMLCU's board of trustees approved new CDD procedures. By 31 January 2027, firms supervised by the Financial Regulatory Authority (FRA) must send in updated KYC forms, policies and controls.
Law 80 of 2002, the Anti Money Laundering Law, was published in the Official Gazette on 22 May 2002. As with the AML rules of other jurisdictions, amendments followed, five so far (gazette dates in brackets): Law 78 of 2003 (8 June), Law 181 of 2008 (22 June), Decree Law 36 of 2014 (15 May), Law 17 of 2020 (11 March) and Law 154 of 2022 (28 July); the EMLCU's consolidated Arabic text footnotes each one. The Arabic text in the Official Gazette is the official one; Andersen Egypt's English translation of the law and the regulations, dated October 2025, is unofficial.
Article 2 defines money laundering, which requires knowledge that the funds come from a predicate offense. Article 1 makes any felony or misdemeanor under Egyptian law a predicate offense, whether committed in Egypt or abroad, provided it is punishable in both jurisdictions.
The executive regulations (Prime Minister's Decree 951 of 2003), Law 94 of 2015 on combating terrorism and Law 8 of 2015 on terrorist lists complete the stack. Egypt ratified the United Nations Convention against Corruption (UNCAC) in 2005, according to the 2021 mutual evaluation.
What did the 2020 amendment to Law 80 of 2002 change?
Footnotes in the consolidated text show what Law 17 of 2020 changed. It rewrote the definition of funds to cover virtual assets used for payment or investment, and amended both article 14, the laundering penalty, and article 16 bis on supervisory measures.
New articles brought confiscation (14 bis), the customs penalty (14 bis 1) and statistics (9 bis). Under the new article 17 bis, the Public Prosecutor or the Military Prosecutor may order freezing or seizure, where necessary or urgent, at the request of the EMLCU board chair. Articles 18 bis to 18 bis 3, also new, cover international cooperation.
The regulations were amended by Decisions 1463 of 2006, 2367 of 2008, 1569 of 2016, 2910 of 2019, 457 of 2020 and 3331 of 2023. Law 154 of 2022 then reshaped the EMLCU board (art. 3) and added the UN sanctions duty (art. 9 bis 1) with its own penalty (art. 15 bis).
What is the EMLCU, and which bodies regulate AML in Egypt?
| Supervisor | Who it supervises (executive regulations art. 1, as amended to Decision 3331 of 2023) | AML role (in force, November 2026) |
|---|---|---|
| EMLCU (Egyptian Money Laundering and Terrorist Financing Combating Unit, also called the MLCU) | Financial institutions and DNFBPs that no other supervisor covers | Financial intelligence unit: receives and examines reports (Law 80 arts. 4, 5), issues CDD procedures, verifies compliance of firms without another supervisor (art. 7) |
| Central Bank of Egypt (CBE) | Banks in Egypt, their branches abroad and branches of foreign banks; exchange companies; money transfer; payment system operators and payment service providers | AML supervisor; annual AML risk questionnaire for banks |
| Financial Regulatory Authority (FRA) | Insurance, reinsurance, private insurance funds and insurance brokerage; capital market, clearing, depository and central registration; real estate finance; receiving funds for investment; leasing, factoring and consumer finance; medium, small and micro enterprise finance | AML supervisor of the non bank financial sector; periodic letters |
| Ministry of Communications and Information Technology | Egypt Post's financial services (payment systems and services stay with the CBE) | AML supervisor |
| Ministry of Trade and Industry | Real estate brokers | AML supervisor |
| Ministry of Supply and Internal Trade | Dealers in precious metals and stones | AML supervisor |
| Ministry of Tourism | Casinos | AML supervisor |
| Egyptian Bar Association | Lawyers | AML supervisor |
| Syndicate of Commercial Professions | Accountants | AML supervisor |
| General Authority for Investment and Free Zones (GAFI) | Trust and company service providers | AML supervisor |
The EMLCU sits at the Central Bank as "an independent unit of a special nature" (Law 80 art. 3, in Andersen's translation). It receives suspicious transaction reports (art. 4), examines them and notifies the Public Prosecution where it finds indications of an offense (art. 5). A judicial expert with at least 15 years at the Court of Cassation or a Court of Appeal chairs its board of trustees, whose members include representatives of the Public Prosecution, the CBE, the FRA and the Federation of Egyptian Banks.
Each supervisor checks its firms off site and on site on a risk based approach and reports to the EMLCU at least once a year (regulations art. 23). For banks, the CBE's AML supervision page sets the cycle: a risk questionnaire goes out at the start of each year and comes back, with supporting documents, by the end of the first quarter.
Which firms and professions does Law 80 cover?
Law 80 article 1 and regulations article 1 name two groups. Financial institutions include banks, exchange companies, money transfer and payment firms, Egypt Post's financial services, insurers, capital market firms, real estate finance, leasing, factoring, consumer finance, medium, small and micro enterprise finance, and anyone who professionally carries out a licensed financial activity for a client.
DNFBPs are covered for named activities only: real estate brokers buying or selling for clients; dealers in precious metals and stones on cash transactions of USD 15,000 or more; lawyers and accountants for five listed services; casinos, online and on ships included, from USD 3,000; and trust and company service providers for four listed services.
Picture a Cairo consumer finance company licensed under Law 18 of 2020: regulations article 1 makes it a financial institution under FRA supervision, so FRA Periodic Letter 8 of 2026 binds it.
What are the key AML compliance requirements in Egypt, article by article?
Twelve duties follow, each with its article as in force in November 2026; the last column names the part of complead, formerly Sanction Scanner, that answers it. Sanction Scanner, the screening product, is part of complead.
Outside the rows, three rules apply. A firm that cannot complete CDD does not open the account, start or continue the relationship, or execute the transaction, and considers a report that states why (regulations art. 22 bis (C)). Where reasonable signs show that CDD would alert the customer to a suspicion, the firm skips CDD and reports instead (art. 22 bis). At least once a year the officer reports to the board on the program and on unusual and suspicious transactions; the report then goes to the EMLCU with the board's comments and decisions (art. 38).
| Obligation | Legal basis (in force, November 2026) | What the article requires | Where complead fits |
|---|---|---|---|
| Risk assessment | Regulations art. 29 bis | Assess money laundering, terrorist financing and proliferation financing risks by customer, country, product, transaction and delivery channel, scaled to the firm's size; document it, have the board approve it, update it at least yearly and whenever needed, and assess new products and technologies before use. | A rule can apply to one product, one segment or one jurisdiction, and each change keeps who made it, when and why. |
| Compliance officer | Regulations arts. 35 to 38 | Appoint an AML/CFT officer and a deputy from senior management, notify the EMLCU of both, and give them independence and access to every record they need. | Each agent output holds evidence, a narrative and a work log; the record names the reviewer who decided. |
| Customer due diligence | Law 80 art. 8; regulations arts. 22 bis, 22 bis (A) | Apply CDD at onboarding, on occasional transactions above USD 15,000 (linked ones counted together), on any occasional transfer, on suspicion and when earlier data is doubtful or insufficient; verify from independent, reliable sources. | Onboarding, screening and monitoring results sit on one engine, so the customer carries a single score. |
| Beneficial owner | Regulations art. 22 bis (B); EMLCU CDD procedures (September 2026) | Identify natural persons holding 25 percent or more of the capital; where that is in doubt or finds no one, those who control by other means; failing both, the senior manager. Verify with reasonable measures. | Owners are traced up the chain until natural persons are reached, and layers that cannot be resolved are reported as unresolved. |
| Politically exposed persons | Regulations art. 32 bis | Check the customer and any beneficial owner for PEP status; take reasonable measures to establish source of wealth and funds; get senior management approval to start the relationship, or to continue it when PEP status appears later; monitor with enhanced measures. Family members, close associates and companies a PEP controls are covered. | The PEP match is one input to that single score, and the senior manager's approval is recorded with a name. |
| Risk classification and enhanced due diligence | Regulations art. 32 | Classify customers by risk, set measures for each level and review the class periodically or when facts change. | Higher risk segments can run their own rules and thresholds. |
| Suspicious transaction report | Law 80 arts. 8, 11; regulations arts. 31, 34 bis (A) | Report to the EMLCU "immediately" once the officer forms a suspicion, whatever the value, attempts included, on the EMLCU's forms with detailed reasons (its site carries the goAML v5.2 documentation); tell no one outside the competent authorities, the customer included. | Regulatory compliance reporting support within case management. |
| UN and domestic sanctions | Law 80 art. 9 bis 1; regulations art. 22 bis (C) | Screen customers and beneficial owners before dealing and again on every list update; freeze and stop services for persons and entities listed by the UN Security Council or on the Law 8 of 2015 lists. | Fuzzy matching thresholds are set per list type and per individual list. |
| Updating CDD | Regulations art. 22 bis (C) | Keep CDD data current, especially for higher risk customers, and bring existing customers under CDD by risk and materiality. | Ongoing monitoring of a name starts or stops through an API call. |
| Wire transfers | EMLCU banks procedures (September 2026), wire transfer section | The ordering bank sends originator and beneficiary data and the purpose with every domestic or cross border transfer, and does not execute a transfer when it cannot meet those duties. | The API screens sender and receiver during processing of the transfer. |
| Record keeping | Law 80 art. 9; regulations arts. 34, 40 | Keep transaction, customer and beneficial owner records at least five years from account closure or, without an account, from completion of the transaction, longer if the EMLCU or investigators ask; keep STR files five years or until a final decision or judgment, whichever is longer. | Each screening search is stored with its searcher, search term, timestamp and outcome, searches with no match included. |
| Training | Regulations art. 41 | Run AML training plans in coordination with the EMLCU and keep each program's records at least five years from its completion. | A closed alert keeps its rule and its matched signals on file, so trainers can teach from the firm's own cases. |
Where do the USD 15,000, USD 3,000 and customs lines sit?
The USD 15,000 line works two ways. A bank applies CDD to an occasional transaction above USD 15,000, linked ones counted together (regulations art. 22 bis), so a single walk in payment of exactly USD 15,000 does not cross it by amount. Suspicion or a transfer of any value still triggers CDD, and below the line a bank records the occasional customer's details from an identity document before executing (EMLCU banks procedures, September 2026).
A gold dealer is covered from cash of USD 15,000 or more, linked payments included (art. 1). Picture a Cairo dealer taking three cash payments of USD 5,000 in one week from one buyer. If the payments appear linked, the total reaches the line and CDD applies.
| Line (in force, November 2026) | Amount | Basis |
|---|---|---|
| CDD on an occasional transaction | Above USD 15,000, linked transactions aggregated | Regulations art. 22 bis |
| CDD on an occasional transfer | Any value | Regulations art. 22 bis |
| Dealers in precious metals and stones covered | Cash of USD 15,000 or more, linked transactions included | Regulations art. 1 |
| Casinos, online and on ships included, covered | USD 3,000 or more, linked transactions included | Regulations art. 1 |
| Customs declaration on entry | Foreign currency and bearer instruments above USD 10,000 | Regulations art. 14 (Decision 457 of 2020) |
| Customs on exit | Declare above USD 5,000; take out no more than USD 10,000 (non Egyptians may take out the rest of an amount declared on arrival) | Regulations art. 14 (Decision 457 of 2020) |
| Suspicious transaction report | Immediately, whatever the value | Law 80 art. 8; regulations art. 31 |
What penalties apply under Law 80 for laundering and noncompliance?
| Offense or breach | Basis (Law 80) | Maximum (in force, November 2026) |
|---|---|---|
| Money laundering, or an attempt | Art. 14 (wording of Law 17 of 2020) | Imprisonment up to 7 years and a fine equal to twice the funds or assets involved |
| Confiscation | Art. 14 bis | The laundered funds and the proceeds; where proceeds are mixed with lawful property, property of equal value or of the value of the instruments used; an extra fine equal to their value if they cannot be seized or have passed to good faith third parties |
| Undeclared or falsely declared currency at customs (art. 12) | Art. 14 bis 1 | Up to 3 months and a fine of one to four times the amount, or either; the amount is confiscated, or an equal fine imposed if it is not seized |
| Breach of reporting, CDD systems, record keeping or the tipping off ban (arts. 8, 9, 11) | Art. 15 | Imprisonment and a fine of EGP 100,000 to EGP 500,000, or either |
| Breach of the UN sanctions duty (art. 9 bis 1) | Art. 15 bis | Up to 1 year, or a fine of EGP 100,000 to EGP 300,000 |
| Offense by a legal person | Art. 16 | Fine of EGP 100,000 to EGP 5 million where an employee acted in its name and for its benefit, with joint liability for fines and compensation; the court may ban the activity for a period or revoke the license; the judgment is published at the firm's cost in two daily newspapers |
| Manager of that legal person | Art. 16 | The same penalties as the offender, if the manager knew and a breach of the manager's duties caused the offense |
| Supervisory measures | Art. 16 bis | Warning, corrective order with a deadline, or a ban, suspension, restriction or halt of activity for up to 1 year; regulations art. 14 bis gives supervisors a warning with a corrective order, or a ban, suspension or restriction for a set period, or a halt of activity, for breaches of the law or of the UN sanctions mechanisms |
Heavier penalties in the Penal Code or another law still apply (art. 13). Supervisors take the measures in article 16 bis on their own initiative or at the EMLCU's request (regulations art. 23).
The EMLCU, the CBE and the FRA publish no AML enforcement register, so the table carries no fines. Picture instead a money transfer firm whose officer sits on a suspicion for a week. Article 15 reaches whoever breached article 8, and if that was an employee acting in the firm's name and for its benefit, article 16 adds a fine of EGP 100,000 to EGP 5 million on the firm.
How did MENAFATF rate Egypt, and which risks does the evaluation name?
In EMLCU case 3, a bank reported a customer whose incoming transfer of about USD 1 million, from a company in a high risk country, did not fit her activity. She converted it to pounds, bought savings instruments, borrowed against them, withdrew cash and sent part to a second suspect to buy land. That suspect had hacked a bank customer's email and redirected a European importer's payments to himself. The Public Prosecutor barred the suspects from disposing of their funds.
The 2021 mutual evaluation cites the 2019 national risk assessment: drug trafficking, fraud, arms trafficking, theft and corruption are the main predicate offenses, while tax evasion, human trafficking and antiquities smuggling generate less. Banking and real estate are among the sectors where proceeds are laundered most, and the evaluation ties terrorist financing risk to the 68 percent of cash transactions that happen outside the financial sector.
MENAFATF adopted the evaluation at its 32nd plenary, in June 2021. It rated 9 recommendations Compliant, 23 Largely Compliant and 8 Partially Compliant, and gave a low effectiveness rating for investigating and prosecuting laundering (IO.7). Upgrades in 2024 and 2025 left 11, 26 and 3, with R.24 (legal persons), R.28 (DNFBP supervision) and R.36 (international instruments) still Partially Compliant.
The FATF lists of 19 June 2026 did not name Egypt. After the October 2026 plenary, FinCEN's notice of 30 October reported four removals from the increased monitoring list and an unchanged call for action list.
Which international cooperation channels does the EMLCU use?
MENAFATF, the FATF style body for the region, assesses Egypt against the FATF Recommendations. Law 80 article 4 lets the EMLCU share information with foreign counterparts under conventions Egypt is party to or on reciprocity. The EMLCU joined the Egmont Group in 2004 (2021 evaluation, criterion 29.8) and exchanges information over the Egmont Secure Web.
What should AML solutions for Egypt record?
Regulations article 34 wants records that can rebuild a transaction as evidence, and a screening hit needs its matched list entry and the analyst's decision kept together.
Client screening and ongoing monitoring checks each name, and its data totals 3,500+ sanctions, PEP and watchlists from 220+ jurisdictions, refreshed every 15 minutes. Before relying on any of the AML solution providers, complead included, ask how fast the Law 8 of 2015 lists reach its data, because article 22 bis (C) requires a rescreen on every list update.
Picture an Egyptian payment firm onboarding merchants. KYB and UBO verification confirms each merchant against official registers and follows its owners up the chain until natural persons are reached; deciding who crosses the 25 percent line stays with the firm. Article 36 has the officer review unusual transactions raised by the firm's own systems; transaction monitoring writes those alert rules without code and replays them on real history (30, 60 or 90 days) before release.
complead's agents close the routine alerts with the evidence, a narrative and the work log attached; the officer decides every other case, and the record shows who. Filing with the EMLCU stays with the officer (regulations art. 31).
Which recent developments set Egypt's deadlines to 31 January 2027?
- May 2025. MENAFATF's fourth enhanced follow up report upgrades R.3 to Largely Compliant, though participation in an organized criminal group is still not criminalized by law; Decision 3331 of 2023 names it a predicate offense only in the executive regulations.
- May 2026. A fifth report was due at the 42nd plenary; none appears on MENAFATF's follow up list as of 4 November 2026.
- 21 September 2026. The EMLCU board approves CDD procedures for all financial institutions and DNFBPs, plus two PEP guidance papers.
- September 2026. FRA Periodic Letter 5 of 2026 binds capital market, insurance and non bank finance firms to the updated procedures.
- 3 November 2026. The FRA announces Periodic Letter 8 of 2026: updated KYC forms that suit older, illiterate and disabled customers, plus updated policy manuals and internal controls, sent with the 2026 annual AML report by 31 January 2027.
Two dates follow: the CBE questionnaire, due back by the end of the first quarter of 2027, and the fifth MENAFATF report. Before 31 January 2027, an FRA supervised firm has three tasks:
- Map each form and control to the September 2026 procedures.
- Rescreen customers against the Law 8 of 2015 lists and register the officer on the EMLCU site for list updates (regulations art. 36).
- Approve the updated forms, manuals and controls in time to send them with the 2026 annual report.
What the 2026 PDF adds. Nothing on this page depends on it. The 16 page PDF holds the working papers: a program checklist with 14 points, a risk factor template for Egyptian customers and a decision record for each suspicion, whether it was reported or not. Ask for it through the form at the side of this page.
