Publications | Special Investigation Comission

Date Subject Description

2012

Foreign PEP

Date	Subject	Description
2012	Foreign PEP	Report (ROA): The SIC received a request of assistance from a counterpart FIU seeking information on one of its nationals (a prominent PEP) and several of his associates. The said PEP was being prosecuted for money laundering in his home country and was accused of illegally obtaining funds and transferring them overseas to several banks in different countries including Lebanon. Analysis & Investigation: The SIC forwarded the suspects’ names to banks operating in Lebanon in an effort to identify bank accounts if any. Several accounts were identified at two banks, and analysis of the said accounts’ movement revealed that several transfers totaling around USD 150,000 originating from the PEP’s overseas bank accounts were wired to Lebanon. Further action by the SIC was manifested by contacting several other national agencies, including the real estate registrar and the ISF, seeking information on the suspects’ possible real estates ownership and police records. Subsequent Measures: Results of the SIC findings were forwarded to the requesting FIU and the PEP was recently convicted in his home country of money laundering offenses.
2012	Layering	Report (STR): A foreign national not residing in Lebanon walked into a local bank (X) and opened for three offshore companies registered in offshore Asian and Latin American centers three accounts (A, B & C). At the time, bank (X) obtained the necessary documentation and identified the purpose behind maintaining bank accounts in Lebanon as being the high interest rates offered. Transfers from two foreign banks, whereby the ordering customer was one of the companies, were sent to accounts A, B & C, only to be transferred out again from the said accounts to a third bank. The bank’s compliance officer flagged the transactions and an STR was filed. Analysis & investigations: Analysis of the obtained bank records from bank (X), including account statements revealed that several million dollars in incoming transfers were received by accounts A, B & C and were transferred out to local bank (Y). The SIC broadened its investigation to include reviewing bank records and transaction records from bank (Y). The information obtained and CDD documents showed that the receiving account belongs to an offshore company D, and that three non-resident customers from three different nationalities were authorized signatories of the account. Additional analysis of the account movement showed that funds were further transferred out of Lebanon to several countries. Subsequent Measures: The SIC contacted several counterpart FIUs for information. Since the funds were not placed in a time deposit bearing high interest as originally claimed, and since no economic justification existed for the transfers, the SIC suspected the possibility of layering and consequently decided to freeze the accounts, lift banking secrecy and forward the case to the General Prosecutor.
2012	Embezzlement	Report (STR): A local bank opened for two high net worth customers trading accounts and a corporate account for a company registered in Lebanon, owned by one of the customers. The bank obtained the necessary documentation and filled out KYC forms. An employee/trader was assigned to handle the said accounts. Routine internal audit work depicted unusual transactions executed by the trader. An STR was filed with the SIC as internal investigations continued at the bank. Analysis & Investigation: The SIC preliminary analysis of bank records revealed that unlawful trade operations were executed at the bank, resulting in losses on one hand and profits for a number of customers. Further analysis of the trader’s bank account revealed internal account to account transactions with a number of customers who benefited from the proceeds. Cash withdrawals and checks to the order of related parties were then issued, some of which were then endorsed to third parties and deposited in the same bank and at other banks. The SIC circulated the names of the suspects to banks operating in Lebanon, and identified several accounts. It was evident that the trader has colluded with several customers to split the illicit proceeds. Subsequent Measures: Bank secrecy was lifted, all related account balances were frozen and investigation findings were forwarded to the General Prosecutor in accordance with the AML Law. 123

Report (ROA): The SIC received a request of assistance from a counterpart FIU seeking information on one of its nationals (a prominent PEP) and several of his associates. The said PEP was being prosecuted for money laundering in his home country and was accused of illegally obtaining funds and transferring them overseas to several banks in different countries including Lebanon.

Analysis & Investigation: The SIC forwarded the suspects’ names to banks operating in Lebanon in an effort to identify bank accounts if any. Several accounts were identified at two banks, and analysis of the said accounts’ movement revealed that several transfers totaling around USD 150,000 originating from the PEP’s overseas bank accounts were wired to Lebanon. Further action by the SIC was manifested by contacting several other national agencies, including the real estate registrar and the ISF, seeking information on the suspects’ possible real estates ownership and police records.

Subsequent Measures: Results of the SIC findings were forwarded to the requesting FIU and the PEP was recently convicted in his home country of money laundering offenses.

2012

Layering

Report (STR): A foreign national not residing in Lebanon walked into a local bank (X) and opened for three offshore companies registered in offshore Asian and Latin American centers three accounts (A, B & C). At the time, bank (X) obtained the necessary documentation and identified the purpose behind maintaining bank accounts in Lebanon as being the high interest rates offered. Transfers from two foreign banks, whereby the ordering customer was one of the companies, were sent to accounts A, B & C, only to be transferred out again from the said accounts to a third bank. The bank’s compliance officer flagged the transactions and an STR was filed.

Analysis & investigations: Analysis of the obtained bank records from bank (X), including account statements revealed that several million dollars in incoming transfers were received by accounts A, B & C and were transferred out to local bank (Y). The SIC broadened its investigation to include reviewing bank records and transaction records from bank (Y). The information obtained and CDD documents showed that the receiving account belongs to an offshore company D, and that three non-resident customers from three different nationalities were authorized signatories of the account. Additional analysis of the account movement showed that funds were further transferred out of Lebanon to several countries.

Subsequent Measures: The SIC contacted several counterpart FIUs for information. Since the funds were not placed in a time deposit bearing high interest as originally claimed, and since no economic justification existed for the transfers, the SIC suspected the possibility of layering and consequently decided to freeze the accounts, lift banking secrecy and forward the case to the General Prosecutor.

2012

Embezzlement

Report (STR): A local bank opened for two high net worth customers trading accounts and a corporate account for a company registered in Lebanon, owned by one of the customers. The bank obtained the necessary documentation and filled out KYC forms. An employee/trader was assigned to handle the said accounts. Routine internal audit work depicted unusual transactions executed by the trader. An STR was filed with the SIC as internal investigations continued at the bank.

Analysis & Investigation: The SIC preliminary analysis of bank records revealed that unlawful trade operations were executed at the bank, resulting in losses on one hand and profits for a number of customers. Further analysis of the trader’s bank account revealed internal account to account transactions with a number of customers who benefited from the proceeds. Cash withdrawals and checks to the order of related parties were then issued, some of which were then endorsed to third parties and deposited in the same bank and at other banks. The SIC circulated the names of the suspects to banks operating in Lebanon, and identified several accounts. It was evident that the trader has colluded with several customers to split the illicit proceeds.

Subsequent Measures: Bank secrecy was lifted, all related account balances were frozen and investigation findings were forwarded to the General Prosecutor in accordance with the AML Law.

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