Updated regulatory controls for exchange companies on combating money laundering, terrorist financing and financing the spread of arms

On August 27, 2025, the following decision:

1- Canceling the regulatory controls for exchange companies regarding combating money laundering and financing terrorism issued

Pursuant to the decision of the Board of Directors of the Central Bank issued on July 29, 2008.

2 - Issuing the attached regulatory controls for exchange companies regarding combating money laundering and financing terrorism

And financing the proliferation of arms.

• Granting exchange companies a period of 6 months from the date of issuance of the controls to reconcile their situations.

The aforementioned instructions have been published on the Central Bank's website and you can view them through

Periodic letters link:

https://www.cbe.org.eg/ar/laws-regulations/regulations/circulars

Accept our sincere appreciation,

Hassan Abdullah

In the Arab Republic of Egypt
The Central Bank of Egypt
CENTRAL BANK OF EGYPT
CENTRAL BANK OF EGYPT

Regulatory controls for exchange companies regarding Combating money laundering, financing terrorism, and financing the proliferation of arms.

The Central Bank of Egypt
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CENTRAL BANK OF EGYPT

Table of Contents
Introduction
Definitions.
Scope of the controls.
1 - Governance.

• The manager responsible for combating money laundering and financing terrorism.
  1-2 Appointing the Responsible Manager and his Deputy.
  2-2 Criteria for determining the Responsible Manager and his Deputy.
  3-2 Independence and powers of the Responsible Manager or his Deputy.
  2-4 Responsibilities of the Responsible Manager.
• Assessing the risks of money laundering, financing terrorism, and financing the proliferation of arms.
• Policies, procedures and internal controls.
  5 - Customer Due Diligence.
  5-1 Customer Due Diligence Procedures.
  5-2 Continuous Monitoring of Operations.
  6- Requirements for notifying suspicious transactions.
  6-1 General Requirements .....
  6-2 Internal Notification Requirements.
  6-3 Unit Notification Requirements.
• Training in the field of combating money laundering, financing terrorism, and financing the proliferation of arms.
• Internal Audit.
• Keeping Records and Documents.
  9-1 Records and documents that the company must keep as a minimum ................
  9-2 Conditions to be followed when keeping records and documents.
  3-9- Duration of record and document retention.

10 - Guiding indicators to identify operations suspected of involving money laundering or terrorist financing .. 15 1-10 Indicators to identify operations suspected of involving money laundering... 2-10 Indicators to identify operations suspected of involving terrorist financing.

.......... Annex

The Central Bank of Egypt
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CENTRAL BANK OF EGYPT
Introduction
These controls represent the minimum that exchange companies must adhere to, in addition to due diligence procedures

With customers of exchange companies and other parties licensed to deal in foreign currency issued by the Anti-Money Laundering Unit

And financing terrorism in February 2020, as exchange companies should put in place appropriate additional measures in proportion

With the results of the risk assessment for combating money laundering and financing terrorism approved by it.

These controls have been prepared in line with developments in the legislative and regulatory environment and in line with amendments

To the Anti-Money Laundering Law issued by Law No. 80 of 2002 and its amendments, and its executive regulations issued by a decision

Of the Prime Minister No. 951 of 2003 and its amendments, in addition to the Central Bank Law and the banking apparatus

Issued by Law No. 194 of 2020 and other related laws, in addition to the amendments made to the procedures

Due diligence mentioned above and referred to later as due diligence procedures, these controls also come within the framework of the endeavor

The Central Bank to keep pace with developments in international standards in the field of combating money laundering, financing terrorism and financing the proliferation

Of armaments and following the best international practices in this field, as well as consolidating what already exists in practical practices.

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Definitions
The following words and phrases in the application of the provisions of these rules mean the meaning indicated next to each:

Unit:

Client:

Beneficial owner:

Senior officials

Inherent Risk
Inherent Risk
Residual Risk
Residual Risk
The Anti-Money Laundering and Terrorism Financing Unit established at the Central Bank of Egypt pursuant to

Anti-Money Laundering Law and its amendments.

Every natural or legal person or legal arrangement that receives a service from an exchange company.

The natural person who actually owns or controls the client or the natural person

Who is carrying out an operation on his behalf, including persons who actually exercise effective control

On the client, whether the client is a legal person or a legal arrangement.

Heads and members of boards of directors of exchange companies and executive directors responsible for

Main and regulatory activities.

The level of risk without taking into account any of the regulatory controls or treatment measures

Implemented by the exchange company and consists of two elements: impact and probability of occurrence.

The risks that the exchange company may be exposed to after the implementation of regulatory controls or measures

Reducing inherent risks.

Financing the proliferation of armaments
It is intended to finance the proliferation of weapons of mass destruction.

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Scope of the controls
These controls apply to all exchange companies operating in the Arab Republic of Egypt.
1- Governance
1-1 The company should have a clear governance framework to combat money laundering, financing terrorism, and financing proliferation

Of armaments based on the risk-based approach, and include defining the powers and responsibilities related to this,

And ensuring that it is well understood and properly implemented by all employees of the company, including all levels

Administrative, and setting standards that ensure its implementation, based on item (6) of the fourth of the instructions issued

By the Central Bank regarding the rules of licensing, control and supervision of exchange companies.

1-2 The company's board of directors is responsible for ensuring compliance with the requirements of combating money laundering and financing

Terrorism and financing the proliferation of arms in addition to documenting its role and responsibilities in this regard, as follows:

The following:

1-2-1 Adopting special policies to combat money laundering, financing terrorism, and financing the proliferation of arms, which

Include, for example, automated work procedures to verify the internal control systems and their ability to

Detect suspicious transactions and unusual transactions, and a mechanism for examining unusual transactions.

2-2-1 Adopting the periodic regulatory reports prepared regarding combating money laundering, financing terrorism and financing

The proliferation of arms and presented by the Internal Audit and Risk Committee.

1-2-3 Ensuring that the risks of money laundering, financing terrorism and financing the proliferation of arms are assessed accurately and comprehensively

With the aim of developing appropriate policies to manage those risks.

1-2-4 Adopting the acceptable level of risks of money laundering, financing terrorism, and financing the proliferation of arms at the level

Of the company as a whole and follow up on compliance with it, provided that it is reviewed in accordance with the periodicity determined by the Board of Directors.

1-2-5 Verify the continued support of the Compliance Officer / Department, and the company must provide electronic systems

And appropriate tools, in addition to ensuring the enjoyment of the necessary independence and ensuring the preservation of confidentiality

Private information on unusual transaction reports and suspicious transaction reports, and in the event that an independent department is established

It must be provided with sufficient human resources and qualified and trained cadres.

1-2-6 Ensuring the existence of appropriate internal review mechanisms, in order to verify the effectiveness of the policies and procedures

And internal controls approved to combat money laundering, financing terrorism, and financing the proliferation of arms, and that

After being presented to the Internal Audit and Risk Committee.

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• The manager responsible for combating money laundering and financing terrorism
  1-2 Appointing the Responsible Manager and his Deputy 2-1-1 The manager responsible for the company's commitment is the manager responsible for combating money laundering and financing

Terrorism, and the approval of the Central Bank of Egypt is obtained upon his appointment.

2-1-2 Determining who will act on behalf of the manager responsible for combating money laundering and financing terrorism during his absence.

2 - 1 - 3 Notifying the Central Bank and the Unit of the contact information of the Responsible Manager and his Deputy, within

Three days and this includes updating this data in the event of a change, termination of service, resignation, or transfer of any

Of them.

2-2 Criteria for determining the Responsible Manager and his Deputy 2-2-1 They must be of a high functional level. 2-2-2 The availability of appropriate academic qualifications and sufficient practical experience to perform tasks well and effectively. 2-2-3 Sufficient knowledge of international standards, legislation and related local instructions. 2-2-4- Enjoying integrity and a good reputation. 2 - 2 - 5 Approval of the Internal Audit and Risk Committee and the Company's Board of Directors on the Manager responsible for combating

Money laundering, financing terrorism and his Deputy before applying for the approval of the Central Bank

Egyptian.

2- Independence and powers of the Responsible Manager or his Deputy The company must provide the manager responsible for combating money laundering and financing terrorism or his deputy with what

Enables him to exercise his powers independently, in accordance with the provisions of Article (37) of the Executive Regulations of the Anti-Money

Laundering Law, in addition to having the right to obtain all information and access to all records

Or documents that he deems necessary without any restrictions and in a timely manner to perform his duties, provided that the performance of the manager is evaluated

Responsible by the Internal Audit and Risk Committee.

2 - 4 Responsibilities of the Responsible Manager The responsibilities of the manager responsible for combating money laundering and financing terrorism must include what is stipulated in the article

(36) of the executive regulations of the Anti-Money Laundering Law, in addition to the following as a minimum:

2-4-1 Preparing and developing the company's policy in the field of combating money laundering, financing terrorism and financing proliferation

Of armaments, and the systems and procedures followed, while working to review and update this policy at least once

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Every two years and whenever the matter calls for it, according to the results of the risk assessment process, in order to increase its effectiveness and efficiency,

And keeping pace with local and global developments.

2-4-2 Examining unusual transactions that the company's internal systems allow him, including verifying the source of

Funds and the purpose of the transaction, in addition to keeping proof of the examination and review process and all

Data and information related to it.

2-4-3 Examining suspicious transactions that are received by him from employees accompanied by the reasons justifying them, or that are received

To him from any other party.

2 - 4 - 4 Examining all transactions relating to the company's employees.

2 - 4 - 5 Notifying the Central Bank and the Unit immediately of the available data on the transactions that are being attempted from

By the persons and entities listed on the Security Council lists or the two lists of terrorist entities and terrorists

Local, as well as any other measures taken, in accordance with the binding texts in this regard.

2-4-6 Providing the Central Bank with the required periodic reports on combating money laundering and financing terrorism

And financing the proliferation of armaments, as well as responding to requests received from him regarding data, information,

Statistics and documents during the specified time period.

2-4-7 Following up on the implementation of instructions and applying them in accordance with the company's internal policies regarding combating money laundering and financing

Terrorism and financing the proliferation of armaments.

2-4-8 Submitting reports on efforts to combat money laundering, financing terrorism and financing the proliferation of arms on a quarterly basis

At a minimum or as soon as the company is exposed to any significant risks to the Internal Audit and Risk Committee,

Provided that it includes the risks faced by the company, their degrees and the measures necessary to reduce them, including as a minimum:

The following:

2-4-8-1- Results of the risk assessment, implementation of the training plan, results of field and desk supervision work,

Exceptions to policies and work procedures related to any new developments ... etc).

2 - 4 - 8 - 2 Statistics on warnings of negative lists, including the lists of the Security Council and the two lists of entities

Local terrorists and terrorists, ensuring that it is updated periodically, and reports of unusual transactions are

Ordinary, suspicious cases, and reports that have been saved, and the number and categories of customers classified within

High-risk category.

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2 - 4 - 8 - 3 Corrective actions to address the shortcomings resulting from the audit operations, and the observations

Contained in the inspection or evaluation report of the Central Bank in the field of combating money laundering and financing

Terrorism and financing the proliferation of arms specified with the target dates for implementing those procedures.

2-4-8-4 Developments and updates in the requirements of combating money laundering, financing terrorism and financing the proliferation

Of armaments.

2-4-8-5 Definitions and patterns of unusual transactions and their updates.

2-4-9 Ensuring that the manager responsible for the company's branch performs the tasks and responsibilities assigned to him with regard to

Combating money laundering, financing terrorism and financing the proliferation of arms in accordance with the policies approved by the Board

Of directors, taking into account the following:

2 - 4 - 9 - 1 Assigning these tasks and responsibilities should not conflict with his current position, with his competence

And the appropriate qualifications that enable him to do so.

2 - 4 - 9 - 2 Participation of the manager responsible for combating money laundering and financing terrorism in the company in the evaluation

Annual for his performance in terms of his performance of tasks and responsibilities in the field of combating money laundering

Funds and financing terrorism.

2 - 4 - 10 Developing an annual plan for general oversight, office and field, of all branches in accordance with the provisions of the executive regulations

To the Anti-Money Laundering Law, supervising its implementation and presenting its results periodically to the committee

Internal Audit and Risk Management and Board of Directors.

2 - 4 - 11 Ensuring the effectiveness of the company's systems to do the following:

2 - 4 - 11-1 Identifying unusual transactions or extracting reports to monitor transactions.

2 - 4 - 11-2- Disclosing the names of all clients and beneficial owners and any other parties on the lists

Security Council and the two lists of terrorist entities and terrorists, as well as updating those lists in a manner

Continues whether this update is in addition to deletion or modification.