Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Investigations: Case Studies from the Lebanese Financial Intelligence Unit (SIC)

The Lebanese Financial Intelligence Unit (SIC) has conducted several investigations into Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) cases, highlighting the importance of collaboration between law enforcement agencies in preventing financial crimes. This article provides a summary of four case studies related to suspicious transactions, including tax evasion.

Case 1: Suspicious Transaction Report (STR)

• Background: A bank filed an STR after discovering media reports about accusations against one of its employees.
• Investigation Findings:
  • The employee had engaged in suspicious activities, including unjustified cash deposits and check withdrawals.
  • The SIC froze the balances of identified accounts, placed encumbrances on properties, and forwarded findings to the General Prosecutor for further investigation.

Case 2: Request of Assistance (ROA)

• Background: The SIC received an ROA from the Lebanese General Prosecutor regarding allegations of corruption, bribery, and abuse of function.
• Investigation Findings:
  • Investigation revealed unjustified cash deposits followed by check withdrawals in bank accounts belonging to suspects.
  • The SIC decided to lift banking secrecy off identified bank accounts and forwarded findings to the General Prosecutor.

Case 3: STR

• Background: A bank filed an STR after reviewing a real estate sales contract that showed a deposited amount exceeding the figure mentioned in the contract.
• Investigation Findings:
  • Investigation revealed similar activity between the parties involved, and the SIC froze and lifted banking secrecy off related bank accounts.
  • The findings were forwarded to the General Prosecutor, who decided to prosecute on tax evasion charges.

Case 4: ROA

• Background: The SIC received an ROA from the Lebanese General Prosecutor regarding ongoing investigations into tax evasion.
• Investigation Findings:
  • Investigation revealed cash deposits later withdrawn with checks for real estate purchases in two bank accounts belonging to a suspect.
  • Further analysis and additional information requests were made, but no further details are provided.

Conclusion

These case studies demonstrate the role of the SIC in investigating suspicious transactions, collaborating with law enforcement agencies, and helping to prevent and combat financial crimes such as money laundering, tax evasion, and corruption.