Self-custodial wallet / non-custodial software in Egypt
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is conditionally permitted in Egypt without local incorporation, subject to AML obligations and none licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- No AML obligations attach — the publisher never holds, controls, or has access to user funds, and therefore does not qualify as a financial institution or VASP under Egyptian law.
- The AML obligations described under Law No. 80 of 2002 (CDD, EDD, STR filing, record-keeping) apply only to licensed financial institutions and VASPs, which a non-custodial software publisher does not fall within.
Key Restrictions
- The publisher must not engage in any activity that would fall under Article 206 of Law No. 194 of 2020 — i.e., it must not issue, trade, promote, or operate a platform for trading cryptocurrencies, or carry out 'related activities' without a CBE license (which the CBE has not issued).
- Purely publishing non-custodial wallet software (where the publisher never holds private keys or funds) likely falls outside the scope of Article 206, but the broad language 'or carry out activities related to them' creates legal ambiguity.
Key Risks
- Regulatory ambiguity: Article 206's prohibition on 'carrying out activities related to' cryptocurrencies is broad and untested — a regulator or prosecutor could assert that wallet software distribution is a 'related activity' even without custody.
- No CBE licenses have ever been issued, so there is no compliant path to market if the activity were deemed to require a license — the model would shift from conditional to effectively prohibited.
- Consumer-protection and disclosure rules for non-custodial software are not addressed in the provided facts; operators lack guidance on what disclaimers, warnings, or terms-of-service are legally required or recommended.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Article 206 of Law No. 194 of 2020 prohibits the issuance or trading of cryptocurrencies, or the establishment or operation of platforms for their trading, or conducting any related activities, without a license from the Board of Directors of the Central Bank.
Given that the CBE has not issued any such licenses, and has reiterated its warnings, this effectively means that the activities typically performed by VASPs (exchanges, custodians, etc.) are prohibited in Egypt.
Law No. 80 of 2002 (Anti-Money Laundering Law), as amended: This is the primary AML/CFT legislation in Egypt.
Law No. 194 of 2020 (The Banking and Central Bank Law): As mentioned above, this law governs banking and financial activities and explicitly addresses virtual assets.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- low
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a self-custodial wallet software publisher does not trigger VASP classification or AML obligations (no custody, no access to funds), but Article 206 of Law No. 194 of 2020's broad prohibition on any cryptocurrency "related activities" creates material legal ambiguity, and no CBE licenses exist to resolve it.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?