Saturday, September 22nd 2018

The role of the Special Investigation Commission on fighting money laundering and terrorism financing is to apply the laws and regulations in force. This is done by fostering interagency and global cooperation for fighting domestic and international money-laundering and terrorism financing crimes.  

The SIC investigates reported suspicious transactions, with a proactive approach in applying the provisions of Law 44. Cases considered by the SIC as money laundering and terrorism financing are deferred to the judicial authorities and to other concerned parties, as specified in the said law. Consequently, banking secrecy is lifted on the accounts involved.

Law No. 44 criminalizes illicit proceeds that are derived from the following offences:

1. The growing, manufacturing, or illicit trafficking of narcotic drugs and/or psychotropic substances according to the Lebanese laws.
2. The participation in illegal associations with the intention of committing crimes and misdemeanors.
3. Terrorism, according to the provisions of Lebanese laws.
4. The financing of terrorism or terrorist acts and any other related activities (travel, organizing, training, recruiting…) or the financing of individuals or terrorist organizations, according to the provisions of Lebanese laws.
5. Illicit arms trafficking.
6. Kidnapping, using weapons or any other means.
7. Insider trading, breach of confidentiality, hindering of auctions, and illegal speculation.
8. Incitation to debauchery and offence against ethics and public decency by way of organized gangs.
9. Corruption, including bribery, trading in influence, embezzlement, abuse of functions, abuse of power, and illicit enrichment.
10. Theft, breach of trust, and embezzlement.
11. Fraud, including fraudulent bankruptcy.
12. The counterfeiting of public and private documents and instruments, including checks and credit cards of all types and the counterfeiting of money, stamps and stamped papers.
13. Smuggling, according to the provisions of the Customs Law.
14. The counterfeiting of goods and fraudulent trading in counterfeit goods.
15. Air and maritime piracy.
16. Trafficking in human beings and smuggling of migrants.
17. Sexual exploitation, including sexual exploitation of children.
18. Environmental crimes.
19. Extortion.
20. Murder.
21. Tax evasion, in accordance with the Lebanese laws

Money-laundering operations may occur in any business especially: 

· Banks 
· Other financial institutions (insurance, mutual funds, etc.) 
· Money exchange firms 
· Antique dealers 
· Real estate concerns 
· Jewelry dealers 

  1. Consecutive transactions with total exceeding the threshold limit.
  2. Unjustifiable account activity concerning the size and frequency of transactions.
  3. Frequent deposits followed by frequent withdrawals.
  4. Exchanging large amounts of small denomination bills for large denominations bills (same or different Currency)
  5. Requests for wire transfers or bankers checks in exchange for currency.
  6. High volume of bankers' or travelers' checks deposited into an account with no justifiable reasons.
  7. Maintaining large number of accounts not commensurate with the type of business.
  8. Cashing checks earned from gambling.

Money laundering is an illegal act intended to conceal the source or use of illicit funds, by converting cash into untraceable bank transactions. The process goes through three main stages:  

· Placement: the launderer introduces the illegal proceeds into the financial system.  

· Layering: the launderer engages in a series of operations on the illicit funds movements, in order to distance them from their source. This involves using different channels that make reverse tracing impossible.  

· Integration: the funds re-enter the formal financial system, and the launderer can invest the funds in any business of high-value assets