Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) in Lebanon: Case Studies

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The Lebanese Financial Intelligence Unit (SIC) has been investigating various cases related to suspicious transactions, tax evasion, and other financial crimes. Here are some notable case studies that demonstrate the importance of AML/CFT measures.

Case 1: Suspicious Transactions

• Background: A government agency employee was accused of corruption and bribery.
• Investigation:
  • The SIC analyzed bank accounts and transactions related to the suspect, including cash deposits followed by check withdrawals.
  • The SIC lifted banking secrecy off the identified bank accounts and forwarded the findings to the General Prosecutor for further investigation.

Case 2: Suspicious Transactions

• Background: A bank filed a suspicious transaction report on a customer after media reports accused an employee of corruption and bribery.
• Investigation:
  • The SIC analyzed the customer’s account activity, including cash deposits below thresholds.
  • The SIC circulated the name of the suspect to all banks and financial institutions operating in Lebanon and contacted real estate and vehicle registers for additional information.
  • The SIC froze the balances of the identified accounts, placed an encumbrance on properties, and forwarded the findings to the General Prosecutor for further investigation.

Case 3: Tax Evasion

• Background: A bank’s AML/CFT compliance officer noticed a discrepancy between cash deposits and real estate sales contracts.
• Investigation:
  • The SIC initiated an investigation by analyzing the customer’s account activity and circulating the names of both parties involved in the real estate transaction to all banks, financial institutions, and money remittance companies operating in Lebanon.
  • The SIC froze and lifted banking secrecy off related bank accounts and forwarded the findings to the General Prosecutor for prosecution on tax evasion charges.

Case 4: Tax Evasion

• Background: The SIC received a request of assistance from the Lebanese General Prosecutor concerning ongoing investigations regarding acts of tax evasion committed by a Lebanese national.
• Investigation:
  • The SIC circulated the name of the suspect to banks, financial institutions, and money remittance companies operating in Lebanon.
  • Findings revealed the existence of accounts at two banks with cash deposits later withdrawn for real estate purchases.
  • The SIC requested additional information from the real estate register, commercial register, and vehicle register.

Conclusion

These cases demonstrate the importance of AML/CFT measures in detecting and preventing financial crimes, such as tax evasion and money laundering.