Publications | Special Investigation Comission

Year	Subject	Description
2015	Forgery	Report (STR): A suspicious transaction report was filed by a bank after being informed from its correspondent that a check placed for collection turned out to be forged. The customer depositing the check claimed that it was against a real estate transaction, and that he was the victim, and also presented the bank with the supporting real estate sales contract. Analysis & Investigation: The SIC initiated its investigation by obtaining from the reporting bank all relevant records including a copy of the forged check. The review of the documents revealed that the amount of the forged check exceeded the actual real estate price stated in the contract. A search of the SIC database revealed that the suspect was subject to previous investigations related also to forged checks being deposited in his account. At the time, the SIC decided to freeze the account of the forged checks issuer and forwarded the matter to the General Prosecutor for further investigation. Since the suspect’s name appeared again in a case involving forged checks, the SIC decided to broaden its investigation. It forwarded the suspect’s name to all banks and financial institutions operating in Lebanon in an effort to identify whether or not the suspect had transactions or maintained accounts that witnessed check forgeries. Two banks reported having bank accounts, and a money remittance company provided information on several transactions. The SIC also contacted the ISF seeking police records, which also revealed that the suspect was accused of theft, forgery of checks and counterfeiting of currency. Subsequent Measures: With the findings at hand, the SIC decided to lift banking secrecy, freeze relevant bank accounts and forward the investigation findings to the General Prosecutor.
2015	Corruption	Report (ROA): In 2015, the Lebanese General Prosecutor received a Mutual Legal Assistance (MLA) request from a foreign judicial authority. The request was related to acts of corruption, bribery and embezzlement of public funds. Banking information among other things was needed to complement the ongoing investigation abroad, and accordingly the SIC assistance was sought. Analysis & Investigation: The preliminary information made available to the SIC revealed that a European company that had participated a few years back in a public tender to build an industrial site in the Gulf area was under investigation. The said company was suspected of colluding with another company, in the sense that the latter billed the European company for un-rendered services, and received payments via wire transfers into a bank account that was used for bribing officials. The bribes were made to obtain insider information concerning tender specifications and offers made by competitors. The SIC obtained from the concerned bank the relevant bank records, account statements and all CDD information on the company. The analysis performed on the account statement identified the transfers received from the European company, and also the internal transfers that followed to the individual suspected of making the bribery payments mentioned above. Subsequent Measures: SIC findings were forwarded to the Lebanese General Prosecutor to take appropriate measures, including forwarding the findings to the requesting foreign judicial authority.
2015	Cybercrime	Report (STR): A suspicious transaction report was filed by a bank after receiving complaints from his customer concerning an ordered wire transfer that did not reach the intended beneficiary abroad. The bank was unable to return the funds, and preliminary findings pointed towards possible hacking/cybercrime offenses. Analysis & Investigation: The SIC initiated its investigation by obtaining from the reporting bank all relevant records related to the transfer, including correspondence between the bank and the beneficiary bank abroad and also correspondence with the customer. The review of the documents revealed that the customer’s e-mail was hacked and that he was provided, for a business transaction he intended to engage in, with false billing information and bank account details. Those details were submitted to the bank to execute the transfer. Simultaneously, a counterpart FIU contacted the SIC informing it that a bank had filed an STR on a disputed blocked wire transfer after receiving information from a Lebanese bank that it was fraudulent. The counterpart FIU also revealed that this report was being handled along with similar cases on the same beneficiary. The information gathered locally and from a counterpart, FIU indicated the occurrence of a cybercrime offense. Subsequent Measures: The SIC requested from the counterpart FIU to freeze the funds, and also forwarded the investigation findings to the General Prosecutor, suggesting that the judicial police-cybercrime office investigate the matter and that a mutual legal assistance request was needed to recover the funds.
2015	Foreign PEP	Report (STR): A local bank opened three accounts for a foreign PEP, his wife and their company after carrying out the required enhanced due diligence measures. The accounts were classified as high risk, and accordingly were subjected to ongoing monitoring. The bank’s compliance officer filed an STR mentioning the three accounts, after becoming suspicious of the wife’s account movement which reflected transactions inconsistent with her profile, and after not being provided with the requested supporting documents. Analysis & Investigation: The SIC initiated its investigation by obtaining bank records and statements of accounts from the reporting bank. The wife’s account movement depicted multiple cash deposits followed by withdrawals for which she claimed that the funds were obtained pursuant to a real estate transaction and also from advertising fees collected by her company. The SIC decided to broaden its investigation and forwarded both the suspects’ names to all banks operating in Lebanon in an effort to identify other bank accounts belonging to the suspects. Several additional accounts were identified, and the obtained bank records revealed that the PEP had used different identity documents to open those accounts. The analysis conducted on the said accounts also revealed the same pattern of multiple cash deposits followed by withdrawals. The unjustified cash deposits followed by withdrawals, and the fact that the PEP used different identity documents to open bank accounts added to the level of suspicion. Subsequent Measures: Banking secrecy was lifted, account balances were frozen and investigation findings were forwarded to the General Prosecutor.
2015	Drug Trafficking	Report (ROA): The SIC received a request of assistance, via the Egmont Secure Web (ESW), from a counterpart FIU on behalf of its national police. The requesting FIU was seeking information on a suspected national with dual citizenship, and his companies charged for being involved in importing, manufacturing and distributing large quantities of prohibited drugs. The suspect was accused by the police for also dealing in proceeds of crime and was sentenced to a term of imprisonment of three years. The counterpart FIU mentioned that in order to restrain all the suspect’s interests in property was issued. Analysis & Investigation: The SIC initiated its investigation by circulating the name of the suspect and his companies to all banks and financial institutions operating in Lebanon. Findings revealed that the suspect maintained a bank account that received a wire transfer from abroad that seemed to be connected to the case. The analysis on the obtained bank statements also reflected cash deposits in small amounts. Subsequent Measures: The SIC decided to temporarily freeze the account balance of the suspect, to provide the requesting FIU with the information at hand, and also requested from the FIU to provide the issued sentence before the temporary freeze order expires.

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