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Report (ROA): The Special Investigation Commission received a request of assistance from the Lebanese General Prosecutor concerning a non-Lebanese national residing in Lebanon charged with being affiliated with several terrorist groups and for being linked to a number of terrorist attacks that took place on Lebanese soil against military outposts.
Analysis & Investigation: The SIC initiated its investigation by circulating the name of the suspect and close family members to all banks and financial institutions operating in Lebanon to identify whether or not they maintain any accounts. Obtained documents and bank records revealed the existence of several accounts. The review and analysis of transactions executed on the said accounts showed a pattern of cash deposits mainly below the USD ten thousand threshold and internal transfers to different parties including family members.
Subsequent Measures: The SIC decided to lift banking secrecy off related bank accounts, freeze them, and forward the findings to the General Prosecutor.
|2014||Embezzlement of Private Funds||
Report (STR): A bank filed an STR with the SIC concerning one of its customers who has been maintaining a bank account for several years. The bank became suspicious of his customer after a number of transactions seemed inconsistent with previous account activity and customer profile.
Analysis & Investigation: Obtained bank records and account statements from the reporting bank reflected unusual transactions. Endorsed checks were deposited in multiple accounts and had reached a total of approximately half a million US dollars. Several withdrawals, including outgoing transfers to overseas bank accounts totaling around three hundred thousand US dollars, followed. At a later stage, the SIC circulated the suspect’s name to all banks and financial institutions operating in Lebanon in an attempt to trace the movement of funds, and was able to identify several bank accounts, some of which were held jointly with the suspect’s family members. Information gathered by the SIC also revealed that the suspect was an employee of a syndicate, and had defrauded a notary public assigned by the said syndicate to collect fees on its behalf. The suspect had presented himself as being authorized to collect checks on behalf of the syndicate, but chose to deposit them in his personal accounts.
Subsequent Measures: The SIC had reasons to believe that the suspect was engaged in fraudulent check activity and embezzlement of funds. Banking secrecy was lifted, bank accounts were frozen and investigation findings were forwarded to the General Prosecutor.
Report (STR): A financial institution (FI) operating in Lebanon received a wire transfer and credited the funds to a customer’s account. A while later, a correspondent bank requested that the FI return the funds after being alerted that internet fraud had resulted in a series of fraudulent transfers being sent to several jurisdictions. Consequently, a suspicious transaction report was filed with the SIC.
Analysis & Investigation: The review of the account opening form and KYC documents revealed that an introducing broker had introduced a foreign company to the FI and handled the account opening procedures on its behalf, including submitting a form assigning an authorized signatory to handle the said account. The review of transactions showed that a number of checks were issued shortly after the transfer was received. This led the SIC at a later stage, after tracing where the checks were deposited, to broaden its investigation to cover accounts at a number of banks. A review of the bank records and accounts' statements revealed that most of the funds were withdrawn at a later stage in cash, and that the authorized signatory and introducing broker were connected to the bank accounts.
Subsequent Measures: Banking Secrecy was lifted, account balances were frozen and investigation findings were forwarded to the General Prosecutor.
Report (ROA): A request of assistance was received from the Lebanese General Prosecutor concerning a mutual legal assistance request (MLA) sent from a judicial authority in a European country on acts of corruption and bribery that took place years ago in which funds were suspected to be deposited in Lebanese bank accounts. The judicial authority was seeking specific information including financial information and bank records.
Analysis & Investigation: A review of the MLA revealed that a foreign PEP had colluded with associates and several others to award large contracts in exchange for kickbacks and bribes. The investigation had led to the arrest of the PEP and also revealed that offshore companies were used to hide bribery related funds, some of which were deposited in bank accounts in Lebanon maintained by offshore companies.
The SIC initiated its investigation by obtaining from concerned banks all relevant records including account statements and KYC forms pertaining to the said offshore companies. The records revealed that they were incorporated in a tax haven jurisdiction, some had the same beneficial owners and authorized signatories. The analysis performed on the account statements depicted transfers and a number of banker’s checks issued by foreign banks and made to the order of one of the PEP’s associates.
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.
Report (ROA): The SIC received a request of assistance from the Lebanese Internal Security Forces concerning individuals arrested while attempting to smuggle drugs into Lebanon. The drugs were creatively hidden inside equipment intended to be shipped overseas. Preliminary investigations done by law enforcement authorities revealed that the drugs originated from a neighboring Arab country and were in transit to another destination.
Analysis & Investigation: The SIC initiated its investigation by circulating the names of the suspects to all banks and financial institutions operating in Lebanon. Findings revealed the existence of bank accounts and transactions made through a money remittance company. The obtained bank records showed that one of the suspects owned a cash-generating business, and that his account activity consisted mainly of recurrent cash deposits below the USD 10,000 threshold which were considered to be in line with the suspect’s business profile. The analysis done on a consolidated basis revealed that two suspects had made multiple cash deposits across a number of bank accounts totaling USD tens of thousands of dollars. The review of money remittance records showed also that one of the suspects had received several remittances.
Subsequent Measures: Banking secrecy was lifted, bank accounts were frozen and investigation findings were forwarded to the General Prosecutor.