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Anti-Money Laundering (AML) and Combating Financing of Terrorism (CFT) Regulations in Lebanon
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AML/CFT Framework
The Central Bank of Lebanon (CBL) is responsible for regulating banks and financial institutions in Lebanon. The CBL has issued Basic Circular no. 83, which outlines the requirements for AML/CFT compliance.
Key Requirements
- Conduct Customer Due Diligence (CDD) on all customers
- Identify beneficial owners of customers
- Verify customer identity through original copies or certified copies by public notaries
Customer Due Diligence (CDD)
Banks are required to conduct CDD on all customers, including identification of beneficial owners. Identification documents include national ID cards and passports.
Additional Requirements for Clients Operating with a Bank
- Provide a procuration document if transactions are done via an agent
Reporting Requirements
Suspicious Activity Reports (SARs) must be submitted to the Governor of the Central Bank and the Special Investigation Committee (SIC).
Submission Methods
- SARs can be submitted electronically or in writing
- All suspicious transactions, regardless of materiality, need to be reported
Automated Transaction Monitoring
Banks are required to use specialized software to monitor accounts and transactions for risk indicators.
Risk-Based Approach
The CBL has a risk-based approach to AML/CFT compliance.
Penalties for Non-Compliance
Failure to comply with reporting requirements can result in imprisonment and fines as stipulated by Law no. 318.
Data Protection Laws
Banking Secrecy Law provides data protection for corporate clients, while additional protections are in place for customers who have facilities with banks.
Sensitive Data Protection
Data protection for sensitive data is also required.
External Audit Requirements
External auditors are required to assess the Bank’s AML function and issue a “gap analysis” report on an yearly basis.
FATF Mutual Evaluation
Lebanon was subject to a FATF mutual evaluation in 2009.