Describe the product without relying on its label
For a proposed Egyptian blockchain service, trace money, tokens, data and decision rights from onboarding to redemption. Identify issuer, platform, wallet provider, payment intermediary and customer-facing entity. “On-chain” does not tell the customer who owes a service if a component fails. Draw one journey for each user type: what they pay, what they receive, who controls keys, and how they exit. Distinguish a record of a right from the right itself, and name the party responsible for custody, redemption, disputes and reversals.
Compare the promise with evidence
Put marketing, white paper, terms, interface and smart contract versions side by side. A claim about liquidity or immutability needs careful limits. Save test transactions and change logs. A customer should understand when a transfer is final and what recourse is available if the interface or a provider makes an error. Compare the test build to the launch build, and record which functions are upgradable, who has upgrade keys and whether a customer can inspect a change before it applies. If an off-chain provider decides an on-chain outcome, describe that dependency in plain language.
Ask legal questions by function
Issuing, trading, payment, custody and lending may need different analysis. Egyptian-qualified specialists should check current requirements for the actual function, customer group and cross-border flow before the business offers it. Do not import a conclusion from a different jurisdiction or product version. Prepare a jurisdiction-and-function matrix instead of calling everything “crypto.” For each function, identify the legal entity, users served, where funds or data move, service provider and proposed approval route. Validate the resulting legal assessment against the current service design.
Keep change and incident procedures
Set who can pause a service, communicate an incident, preserve logs and approve a release. Model provider failure and disputed redemption. If custody or token rights change, revisit code, disclosures and terms together; a static opinion cannot cover an evolving product indefinitely. Keep an incident decision tree with keyholders, freeze powers, an evidence-preservation step, customer contacts and a rollback test. Rehearse a lost-key event and a failed provider handoff; update terms and disclosures whenever operational control changes.
Launch review pack
- Document the product flow and the legal entity responsible at every step.
- Reconcile the customer promise with code, interface, custody and provider contracts.
- Map each product function and cross-border flow for current local advice.
- Test incident controls, recovery and customer communications before launch.
- Note that the Central Bank of Egypt, in its warning statement of 13 September 2022, recalled that Law No. 194 of 2020 prohibits issuing, trading or promoting cryptocurrencies; have Egyptian counsel confirm the current position for this product.
See our blockchain legal consultancy practice and data privacy practice for connected questions.