Publications | Special Investigation Comission

Year	Subject	Description
2020	Cybercrime	Report (STR): A bank filed a suspicious transaction report concerning two customers who ordered the execution of cross-border transfers to the account of a European based supplier at a foreign bank. Following the execution of the transfers, the customers realized that the supplier’s email was compromised and that they had acted on wrongful payment instructions. The reporting bank had also requested from the correspondent bank the cancellation of the transfers and return of funds. Analysis and Investigation: The SIC initiated its investigation by reviewing all bank records, documents and invoices submitted by the reporting bank, and also contacted a European FIU in order to freeze the funds abroad and seek further information on the account that received the transfers. The information obtained from the counterpart FIU indicated that the account was for an individual being investigated abroad for ML charges, after having received several fraudulent transfers. The counterpart FIU also stated that part of the funds were frozen, and some had been withdrawn. Contact details were also provided for the foreign law enforcement authority handling the case after the suspect was arrested while attempting to leave the country. Subsequent Measures: The SIC forwarded the information obtained to the Lebanese General Prosecutor, who in turn also shared with the SIC the related Mutual Legal Assistance request received from the European country.
2020	Tax Evasion	Report (ROA): The SIC received a request of assistance from the Lebanese General Prosecutor concerning a Mutual Legal Assistance (MLA) that he received from a foreign judicial authority. The MLA was related to acts of tax evasion committed by a suspect who owned shares in a company he managed. The suspect made significant profits after the company became publicly traded, did not report or pay taxes due and had transferred funds to a bank account in Lebanon. Analysis and Investigation: The SIC initiated its investigation by obtaining all related documents, including bank statements as well as available CDD information from the local bank that received the transferred funds from abroad. Furthermore, the SIC circulated the name of the suspect and companies mentioned in the MLA to all banks and financial institutions operating in Lebanon in an effort to identify accounts and transactions. Two additional bank accounts were identified and the analysis performed showed the same pattern of incoming transfers in millions of dollars that were later transferred abroad including for the purchase of real estate. Subsequent Measures: Banking secrecy was lifted and SIC findings were forwarded to the Lebanese General Prosecutor to take appropriate measures including providing information to the foreign judicial authority.
2020	Drug Trafficking	Report (ROA): The SIC received a request of assistance from the Lebanese General Prosecutor regarding four Lebanese nationals accused of drug trafficking. Analysis and Investigation: A search of the SIC database revealed that two of the four suspects were subject to previous investigations relating to drug trafficking. At the time, the SIC identified and froze related bank accounts and forwarded the matter to the General Prosecutor for further investigation. With the new ROA at hand, the SIC circulated the names of the other two suspects to all banks, financial institutions and money remittance companies operating in Lebanon. The SIC also requested information from several national agencies including the real estate register and the vehicle register. Findings revealed the non-existence of bank accounts, while one money remittance company reported a few incoming and outgoing remittances executed by the two suspects. The information from the real estate register and vehicle register on the two suspects revealed ownership of one real estate and one vehicle. Subsequent Measures: The SIC decided to place an encumbrance on the real estate and vehicle, and also requested from all money remittance companies not to perform future transactions for the suspects. The findings were forwarded to the General Prosecutor for further investigation.
2020	Embezzlement of private funds	Report (STR): A local bank filed a STR with the SIC concerning unauthorized transactions carried out by a bank employee on customers’ accounts. The said employee executed withdrawals from the accounts of several customers using forged instructions, and uncollected newly issued checkbooks. Analysis and Investigation: The SIC review of bank statements pertaining to several embezzled customers revealed withdrawals worth hundreds of thousands of dollars. With the information at hand, the SIC circulated the name of the suspected bank employee 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 said accounts revealed that the embezzled funds were not placed in the identified accounts as they had small balances, and activity consisted mainly of salary domiciliation and small cash deposits followed by cash and ATM withdrawals. The SIC later requested information from a local law enforcement authority concerning the entry and exit of the suspect to/from the country, which revealed departure from Lebanon. Subsequent Measures: The SIC sought assistance from a counterpart FIU on the suspect and related bank accounts abroad and froze the balances of identified accounts in Lebanon. It also requested from all money remittance companies not to perform any future transaction for the suspect. The findings were forwarded to the General Prosecutor for further investigation.
2020	Corruption	Report (ROA): The SIC received a request of assistance from the Lebanese General Prosecutor concerning allegations of corruption, bribery, and abuse of function brought against suspects working for a government agency. Banking information among other things were needed to complement the ongoing investigation, and accordingly the SIC assistance was sought. Analysis and Investigation: In order to identify transactions and accounts, the SIC circulated the names of the suspects to all banks, financial institutions and money remittance companies operating in Lebanon. Accounts belonging to one of the suspects was identified in four banks along with accounts for close family members. The analysis performed on the obtained accounts revealed unjustified cash and check deposits followed by checks withdrawals. Accounts belonging to another suspect and close family members were also depicted at other banks, and the analysis performed on those accounts reflected many transactions between them. In addition, two money remittance companies reported a number of outgoing remittances in prior years. Subsequent Measures: The SIC decided to lift banking secrecy off the identified bank accounts and forwarded the investigation findings to the General Prosecutor.

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