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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:
The Analysis & Investigation Unit is the financial investigation arm of the Special Investigation Commission. When discharging its duties in connection with filed STRs, the Unit performs the needed operational analysis and financial investigation on the persons and related transactions. This process can be complemented with information gathered from reporting entities, law enforcement and government agencies, in addition to intelligence obtained from FIUs. In certain instances and when necessary, the Unit performs such work on ROAs received from local and foreign authorities. Decisions taken by the SIC based on this work include exchanging information with FIUs, sending spontaneous disclosures, freezing accounts/ transactions, keeping accounts traceable, placing an encumbrance on records and entries pertaining to movable or immovable assets, and forwarding cases to the General Prosecutor.
The Compliance Unit is the supervisory arm of the Special Investigation Commission that ensures banks and other reporting entities compliance with prevailing AML/CFT regulations. It conducts ongoing onsite and offsite examinations to assess the effectiveness of AML/CFT compliance programs, CDD measures and controls adopted to monitor, detect and report suspicious transactions. Onsite examinations are risk based and are complemented with annual offsite assessments. When necessary, the risk based approach for supervision of concerned sectors under Law no. 44 are updated to ascertain both adequate coverage and more focused assessments. In discharging its duties, the Unit highlights corrective measures that banks and other reporting entities need to implement to enhance their compliance programs and internal controls. The Unit also recommends updating or introducing new AML/CFT regulations following developments in international standards, and when the need arises due to either evolving risks, best practices or as a result of examinations findings.
The Database Administrative Unit is entrusted with managing the Special Investigation Commission’s database. The Unit logs all filed STRs and ROAs received from local/foreign sources in addition to spontaneous disclosures, as well as SIC decisions in this regard. Also, requests made by the SIC to counterparts, external parties along with any obtained intelligence are maintained. Reviews, classifications, updates and data cleansing are performed periodically to ensure both quality and accuracy of data. The Unit reviews MOUs the SIC intends to sign with its counterparts and issues statistics that is used in SIC annual reports, when undertaking strategic analysis and when identifying money laundering and terrorism financing trends. The Egmont Secure Web (ESW) is also housed within this Unit and is subject to strict security usage protocols.
The Information Technology & Security Unit at the Special Investigation Commission is in charge of managing and updating all hardware, software, applications and network communications infrastructure needed for both the day-to-day operations of staff and for the secure exchange of messages between the SIC and reporting entities. Among the Unit’s core responsibilities is also maintaining the SIC website, overseeing the disaster recovery plan and the security of equipment, data, documents and physical security of the premises.