Report (STR): A Lebanese national approached a local bank to open a personal account and an account for his company. The customer claimed working in fuel trade and distribution, and wanted to obtain bank facilities. The two accounts were opened after CDD measures were carried out and the necessary supporting/ identification documents were obtained. Due to the nature of the expected account activity that involved cash transactions, the accounts were classified as high risk and were subjected to enhanced monitoring. After coming across a media article that posted names and pictures of individuals arrested for forging identification documents, and after noticing that one of the pictures was the same one used on the customer’s ID card, the bank became suspicious and filed an STR accordingly.
Analysis and Investigation: The SIC obtained from the reporting bank the identification document used to open the accounts, along with account statements which reflected frequent cash deposits and check withdrawals totaling hundreds of thousands of dollars. The obtained ID was then circulated to all banks, financial institutions, and money remittance companies operating in Lebanon in order to identify transactions and other accounts opened with the said ID. Several other banks reported having accounts for the suspect and the analysis performed on the accounts’ statements reflected a similar pattern of cash deposits followed by check withdrawals. The information obtained from law enforcement authorities confirmed that the customer’s ID was forged.
Subsequent Measures: With the findings at hand, the SIC decided to lift banking secrecy, freeze the identified bank accounts and forward the investigation findings to the General Prosecutor for further investigation.
|2018||Embezzlement of Private Funds||
Report (STR): A local bank filed an STR with the SIC concerning unauthorized transactions carried out by a bank employee on customers’ accounts. The said employee works in customer service, and had arranged for debit cards to be issued in the names of several customers and used them for ATM withdrawals.
Analysis and Investigation: The bank statements of several customers that were reviewed by the SIC revealed ATM withdrawals worth thousands of dollars. With the information at hand indicating towards acts of embezzlement, the SIC circulated the name of the suspect to all banks, financial institutions and money remittance companies operating in Lebanon to identify bank accounts and transactions. Two bank accounts were identified. The analysis of the accounts revealed that they had small balances, and that their activity consisted mainly of salary domiciliation and of small cash deposits and withdrawals.
Subsequent Measures: The SIC decided to freeze the balances of the two identified bank accounts, and provided the General Prosecutor with the findings for further investigations. While under interrogation the suspect confessed to committing forgery and embezzling funds from customers’ accounts.
Report (STR): A local bank filed a suspicious transaction report with the SIC after receiving complaints from a customer concerning a wire transfer in the amount of $ 600K that did not reach the intended beneficiary abroad. Later on, the SIC received from another bank a suspicious transaction report concerning two wire transfers totaling 1 Million Euros that also did not reach the intended beneficiaries and involved the same customer. The two banks had contacted the concerned correspondent banks, and were unsuccessful in returning the transferred funds. Preliminary findings pointed towards possible hacking/cybercrime offences.
Analysis and investigation: The SIC initiated its investigation by reviewing all related bank records, documents and invoices obtained from the two reporting banks. The review of the documents revealed that the customer’s e-mail was hacked and that he was provided with false billing information and bank account details relating to the purchase of merchandise he had negotiated and intended to import. The customer acted on those details by submitting them to the two banks with instructions to execute the transfers. The SIC also contacted two counterpart FIUs seeking information on the bank accounts that received the transfers abroad. The information gathered from the first FIU indicated that the account holder was not the intended supplier and that the account had received inward transfers that were followed by 17 outward transfers to different parties in other jurisdictions. The Second FIU indicated that the account did not belong to the intended supplier and that the transfers received were followed by cash withdrawals.
Subsequent measures: The SIC forwarded the findings to the General Prosecutor suggesting that the judicial police-cybercrime office investigate the matter further, and asked the reporting banks for updates on the law suit filed abroad by the customer.
Report (ROA): The SIC received a request of assistance from the Lebanese General Prosecutor concerning allegations of corruption and abuse of position brought against a local PEP, who for personal gain colluded with a suspect in settling violations that facilitated tax evasion. Banking information among other things were needed to complement the ongoing investigation.
Analysis & Investigation: In order to identify transactions and accounts, the SIC circulated the names of the PEP and the suspect to all banks and financial institutions operating in Lebanon. Several bank accounts belonging to the PEP, a relative and the suspect were identified. The analysis performed on the obtained accounts statements revealed no transactions between the aforementioned individuals. The analysis however depicted unjustified frequent cash transactions that were deposited in the PEP and a relative’s accounts, the source of which were unknown. A search of the SIC database also revealed that the suspect was subject to previous investigations concerning unusual cash deposits.
Subsequent Measures: The SIC decided to lift banking secrecy off the identified bank accounts, and forwarded the findings to the General Prosecutor for further investigations.
Report (STR): A local bank filed several STRs on a number of customers for depositing cash and claiming that they were proceeds generated from the sale of real estate. The customers presented several power of attorney documents used in the transactions, and promised to provide further supporting documents afterwards.
Analysis and Investigation: The SIC initiated its investigation by analyzing the suspects’ account statements and also circulated their names to all banks, financial institutions and money remittance companies in order to identify related transactions and bank accounts. The SIC also contacted several national agencies, including law enforcement and the real estate registrar for information on the suspects’ real estate ownership. During the investigations, the SIC received a request of assistance from the General Prosecutor concerning suspects accused of drug trafficking. The names of those suspects were also forwarded to all banks, financial institution and money remittance companies. The SIC was able to identify further bank accounts and transactions, and the analysis revealed that the suspects mentioned in the STRs had sold their real estate to the accused drug traffickers for cash. Furthermore, the SIC contacted public notaries to identify real estate transactions executed through proxies for the aforementioned suspects.
Subsequent measures: The SIC decided to freeze the balances of the identified bank accounts, placed an encumbrance on the suspects’ real estate, and forwarded the findings to the General Prosecutor.