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Year Subject Description
2020 Terrorism Financing

Report (ROA): The SIC received a request of assistance from a local law enforcement authority via the Lebanese General Prosecutor regarding two individuals who were apprehended and interrogated for smuggling suspected terrorists across the borders. The LEA was seeking any information the SIC might have in its database and to assist in identifying any related bank accounts and transactions.

Analysis and Investigation: In an effort to identify whether or not the suspects had transactions or maintained bank accounts, the SIC circulated their names to all banks, financial institutions, and money remittance companies operating in Lebanon, and simultaneously requested a freeze on accounts and transactions if found. The SIC also requested from the real estate register and the vehicle register to attach an encumbrance on any assets related to them. Findings revealed the
presence of two accounts at two financial institutions consisting of small value loans, including a car loan and an outstanding debt which was classified as uncollectable. One money remittance company also provided information on incoming and outgoing transactions in small amounts.

Subsequent Measures: The SIC decided to lift banking secrecy off the identified accounts and placed an encumbrance on the vehicle identified. Findings were forwarded to the Lebanese General Prosecutor for further investigation.
 

2020 Terrorism Financing

Report (ROA): The Lebanese General Prosecutor sought the SIC assistance in order to identify and freeze bank accounts, transactions and any movable or immovable assets pertaining to individuals involved in acts of terrorism and terrorism financing. The suspects had carried out an attack that resulted in the killing of municipality guards, and investigations that followed this act uncovered a terrorist cell associated with ISIL that underwent military training and collected arms and ammunitions. Law Enforcement investigations also revealed that the cell was preparing to execute terrorist attacks on Lebanese soil, namely through simple and easy to perpetrate terrorist attacks, such as mass shootings in public places.

Analysis and Investigation: The SIC initiated its investigation by circulating the names of the suspects to all banks, financial institutions, and money remittance companies. Enquiries were also made to the vehicle register and to the real estate register. Findings revealed the presence of money remittance transactions in small amounts occurring within the country, in addition to a number of transactions with several jurisdictions. No bank accounts were identified, and a few vehicles and properties were depicted. Additional findings from parallel investigations carried
out by law enforcement and made available to the SIC revealed that the terrorist cell had also conducted several robberies to finance their activities.

Subsequent Measures: Spontaneous disclosures and requests of assistance were sent to concerned FIUs. The SIC also attached an encumbrance on the identified vehicles and properties and requested from all money remittance companies to refrain from executing any future transactions for the involved individuals. All findings were forwarded to the Lebanese General Prosecutor.

2019 Embezzlement of Public Funds

Report (ROA): In 2019, three individuals working for a government agency were detained for embezzling public funds. The suspects were accused of abusing their positions and colluding with one another to embezzle municipal funds. The Lebanese General Prosecutor requested SIC assistance to obtain banking and other information to complement his investigations.

Analysis and Investigation: The SIC contacted the real estate register to enquire about any real estate ownership pertaining to the suspects within the municipality area and elsewhere, and was able to identify several properties owned by them. The SIC also circulated the names of the suspects to all banks, financial institutions and money remittance companies operating in Lebanon and was able to identify bank accounts and transactions. Several bank accounts reflected mainly small cash deposits and withdrawals.

Subsequent Measures: An encumbrance was placed on identified properties and the SIC decided to freeze and lift banking secrecy off bank accounts and forward the findings to the General Prosecutor. Furthermore, money remittance companies were requested not to perform any transactions for the suspects.

2019 Tax Evasion

Report (STR): The AML/CFT compliance officer at a local bank, while reviewing cash transactions deposited in a customer’s account requested supporting documents from the said customer. The officer was provided with a real estate sales contract, from which he noticed that the deposited amount exceeded the figure mentioned in the sales contract. An STR was consequently filed with the SIC, for possible tax evasion.

Analysis and Investigation: The SIC initiated its investigation by analyzing the customer’s account activity and also circulated the names of both parties involved in the real estate transaction to all banks, financial institutions and money remittance companies operating in Lebanon in an attempt to identify if similar activity existed.

Subsequent Measures: The SIC decided to freeze and lift banking secrecy off related bank accounts and forward the findings to the General Prosecutor, who in turn decided to prosecute on tax evasion charges.

2019 Drug Trafficking

Report (STR): A Lebanese national approached a local bank to open an account. The customer claimed that he owns a small manufacturing business and informed the bank that he will be depositing cash into the account from sales proceeds. The account was opened after CDD measures were carried out. After coming across a news article that posted names of individuals involved in a drug smuggling network arrested for trafficking and smuggling large amounts of drugs, the bank filed an STR with the SIC.

Analysis and Investigation: The SIC initiated its investigation by analyzing the customer’s account statements and also circulated his name to all banks, financial institutions and money remittance companies operating in Lebanon. Findings revealed the existence of two other bank accounts with similar patterns of cash and check deposits, followed by check withdrawals. One money remittance company reported the existence of incoming and outgoing remittances related to the suspect.

Subsequent Measures: The SIC decided to freeze the balances of the identified accounts, placed an encumbrance on all properties owned by the suspect, requested from all money remittance companies not to perform any transaction for the suspect and forwarded the findings to the Lebanese General prosecutor.

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2021 TBML Risk-Indicators
The FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems - 2013
2020 TBML Trends & Developments
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FATF: High risk and other monitored Jurisdictions
Central Bank of Lebanon
Banking Control Commission of Lebanon
The Organization for Economic Co-operation and Development (OECD)
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