Generally, any entity seeking to carry out any type of banking or non-banking financial services in Egypt must obtain the relevant license from either the CBE or the FRA, as applicable. Different requirements would need to be satisfied by such entity in order to obtain the license in question depending on the financial activity it seeks to carry out in Egypt.
By way of example, the following activities require a license from the CBE: offering banking activities, acting as a payment aggregator or a payment facilitator, acting as an instant payment network (IPN) service provider or a technical service provider, providing e-wallet services, and acting as a card scheme.
Similarly, offering any of the following services requires the relevant entity to obtain the applicable license from the FRA: consumer finance, microfinance, SME finance, insurance, brokerage, mortgage financing, and financial leasing. If any such services are to be offered using financial technology such as digital platforms, an additional fintech approval must be obtained from the FRA.
Relatedly, Article 206 of the Banking Law prohibits the issuance, trading and advertising of cryptocurrency and electronic money as well as the construction or operation of platforms for trading in cryptocurrency and e-money or the execution of related activities without obtaining a license from the CBE's board of directors. In a letter addressed to banks, the CBE emphasized the importance of blocking transactions aimed at buying cryptocurrency and declared the creation of a list in collaboration with the Money Laundering and Terrorist Financing Combatting Unit, including the names of 55 cryptocurrency platforms and websites where any transfers or transactions made through them or to them are prohibited. Additionally, the FRA clearly stated that it did not license any cryptocurrency activity in Egypt or create any framework for such, that it strictly opposes trading and use of cryptocurrencies, and that it considers any promotion of or incentivization towards cryptocurrencies a form of misrepresentation which leads to legal liability. In practice, to the best of our knowledge, neither the CBE nor the FRA have approved or licensed any activity in cryptocurrency in Egypt to date, including the issuance and advertisement of and trading in cryptocurrencies. Moreover, no licensing regime has been set up or published.