The Special Investigation Commission (SIC) is a multi-function financial intelligence unit (FIU) with judicial status. It is the center piece of Lebanon’s AML/CFT regime, a platform for international cooperation and plays a vital role in safeguarding concerned sectors from illicit proceeds. 

The SIC’s tasks include receiving and analyzing suspicious transaction reports (STRs), conducting financial investigations, lifting banking secrecy, freezing accounts and/or transactions and forwarding them to concerned judicial authorities. 

With respect to terrorism and the financing of terrorism, the SIC is also empowered to prevent the use of movable or immovable assets. In addition to sharing ML/TF intelligence with counterparts and coordinating with foreign/local competent authorities on requests of assistance (ROAs), the SIC also proposes AML/CFT regulations and issues regulations and recommendations to concerned parties. 
AML/CFT supervision via risk based compliance examinations that cover banks and other reporting entities to ensure proper implementation of prevailing regulations is also among its tasks.

The Secretary General tasks include the following:

  • Supervise directly the SIC Units.
  • Receive all suspicious transaction reports, requests of assistance, and other reports, and process them through the concerned SIC Units, and notify relevant parties of SIC decisions.
  • Provide an analytical opinion on SIC Units’ reports on executed tasks.
  • Implement when allocating tasks the principle of avoiding conflict of interest.
  • Monitor domestic / foreign laws and regulations as well as international standards, and recommend amendments to Lebanese legislations and regulations.
  • Foster cooperation between the SIC and its foreign counterparts.
  • Engage and follow up on the work of AML/CFT regional and international bodies.
  • Engage and follow up on the work of the AML and CFT National Committees.
  • Oversee staff related administrative matters, prepare the budget, and oversee expenditures and the audit thereof.

The Analysis & Investigation Unit is the financial investigation and analysis arm of the Special Investigation Commission. The Unit analyzes STRs filed on money laundering, associated predicate offences, terrorism and terrorism financing, and investigates related persons and transactions. This work is supported when needed with additional information requested from reporting entities, law enforcement authorities, government agencies, and counterpart FIUs. The Unit also handles spontaneous disclosures and ROAs received from local and foreign authorities. Decisions taken by the SIC based on this work include disseminating cases to the General Prosecutor, exchanging information with counterpart FIUs, sending spontaneous disclosures as well as freezing accounts/transactions. SIC decisions also include keeping accounts traceable, and placing an encumbrance on records and entries pertaining to movable or immovable assets.

The Compliance Unit is the supervisory arm of the Special Investigation Commission tasked with ensuring compliance of banks, financial institutions and other reporting entities, including at the financial group level, with prevailing AML/CFT obligations. It conducts onsite and offsite supervision to assess the implementation and effectiveness of compliance programs, CDD measures and internal controls adopted to monitor, detect and report suspicious transactions. Onsite supervision is risk based and is complemented with ongoing offsite work, and a tailored risk based approach for supervision of concerned sectors under Law no. 44/2015 is adopted and updated continuously to ascertain effective and precise supervision, as well as adequate coverage. The Unit also highlights corrective measures that banks, financial institutions and other reporting entities need to implement to enhance their compliance programs and internal controls. Moreover, it recommends updating AML/CFT obligations or introducing new ones in accordance with developments in international standards / best practices, and with the evolving risks, or as a result of supervisory findings.

The Database Administrative Unit is entrusted with managing the Special Investigation Commission’s database. It logs and maintains all filed STRs and ROAs received from local/foreign sources and through the Egmont Secure Web, as well as spontaneous disclosures, and ROAs sent to foreign authorities including FIUs. Its tasks include retaining existing and gathered information, along with the results of conducted analysis & investigations, and SIC decisions taken in this regard. Reviews, updates and classifications are periodically performed to ensure data accuracy. The Unit also issues statistics that is used in SIC annual reports, in strategic analysis and when identifying ML/TF trends and patterns.

The Information Technology & Security Unit manages, updates and makes available for SIC staff all technical tools and equipment, as well as the servers, internal network, programs and applications needed for their work. It is also tasked with the technical development and security measures of the SIC database, as well as with establishing the network and programs needed for the secure exchange of messages and information with reporting entities and concerned authorities. Among the Unit’s responsibilities is also the safety and security of the premises, data and archived documents, in addition to developing and updating the SIC website and the disaster recovery plan.