Egypt – CM PB – Update 2022

Jan 28, 2022

Country Manuals Private Banking

We would like to inform you that BRP has updated its COUNTRY MANUAL PRIVATE BANKING for the following jurisdiction:

EGYPT OUT OF BANK’S COUNTRY OF ESTABLISHMENT (Def, RS, BT & RT)

Regulatory Template

Material changes
Following consultations with our local counsel, we have reviewed and updated the documents to take into account recent regulatory developments as well as an evolving interpretation of the regulatory framework.

The most significant changes are as follows:
– The previous “Banking Sector and Money Law” N° 88 of 2003 was replaced by the “Central Bank and Banking System Law” N° 194 of 2020. From a cross-border perspective, this new text only brings minor changes:
• The current Law adopted a new structure. Consequently, we adapted all legal references;
• Some new chapters were added, for example on payment system and consumer protection;
• The sanctions and the amount of the fines were modified in accordance to the new Law.
– A new “Consumer Protection Law” N° 181 of 2018 replaced the previous one, providing more specific provisions (e.g. conditions on language).
– The Central Bank of Egypt (CBE) updated the threshold for the definition of Professional High-Net Investors (Qualified Clients) : the amount of required assets was raised from EGP 2,000,000 to EGP 5,000,000 (approx. USD 320,000).
– Concerning the remuneration of third-party relationships, we have adopted a more prudent approach changing our answers from “Grey zone/YES” to “Grey zone/NO”.

Non-material changes
The document has been reformatted onto the latest template. Many answers in the RS have been re-worded, with an additional reference to applicable law/regulation, to provide more clarity and more detailed explanations.

Regulatory Summary
This document has now a more user-friendly layout and reflects the changes contained in the RT.

Behaviour Template
The answers in the BT have been aligned to those contained in the RT.

BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline.com) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “EGYPT” in the Target Country Field.

The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.


Best regards,