Lebanon SIC Annual Report 2024

Lebanon’s SIC Annual Report 2024: Navigating Grey Listing and Reinforcing the Fight Against Financial Crime

The Special Investigation Commission (SIC), Lebanon’s Financial Intelligence Unit, released its 2024 Annual Report at a time when the country is grappling with severe political, economic, and security crises. The report sheds light on the difficult realities Lebanon faced as the Financial Action Task Force (FATF) placed the country under increased monitoring, also known as the grey list. Despite the challenges, the SIC highlights its extensive supervisory actions, its case-handling record, and its continued efforts to strengthen Lebanon’s financial integrity and restore international trust.

FATF Grey Listing and Political Commitment

In 2024, the observation period given to Lebanon to implement anti-money laundering and counter-terrorism financing (AML/CFT) corrective measures came to an end. FATF concluded that the country had not made sufficient progress on the shortcomings identified in its Mutual Evaluation Report and consequently added Lebanon to the grey list. This decision represents a significant setback, especially for a nation already under financial and political strain.

Nonetheless, the Lebanese authorities have pledged to work closely with FATF and committed to a formal action plan aimed at addressing the identified gaps. A ministerial committee was formed by the Council of Ministers to oversee the implementation of these corrective measures. The action plan includes reforms that span across multiple sectors such as supervision, prosecutions, beneficial ownership transparency, and controls against terrorism financing. The SIC stressed that while many of these measures fall outside its direct mandate, it would continue to coordinate with domestic authorities to ensure effective implementation.

SIC’s Role and Mandate

The report reiterates the SIC’s central role in Lebanon’s AML/CFT regime. Established as a financial intelligence unit with judicial powers, the Commission is tasked with receiving and analyzing suspicious transaction reports, investigating money laundering and terrorism financing cases, lifting banking secrecy, and freezing assets when necessary. It also acts as the official channel for international cooperation, sharing intelligence with counterpart financial intelligence units through platforms such as the Egmont Secure Web. The SIC’s mandate positions it not only as a domestic watchdog but also as an essential partner in cross-border financial crime investigations.

2024 Operational Highlights

During 2024, the SIC processed 620 cases of money laundering and terrorism financing. These were comprised of 211 suspicious transaction reports, 430 requests of assistance from both local and foreign authorities, and 23 spontaneous disclosures. The outcomes included the dissemination of intelligence to the General Prosecutor, account freezes, restrictions on transactions, and encumbrances placed on assets.

Supervision remained another cornerstone of SIC’s activities. The Compliance Unit conducted risk-based on-site examinations across a wide spectrum of financial institutions. This included visits to 19 banks, 100 money dealers, 7 money remittance companies, 12 financial institutions, 14 specialized lending entities, 13 brokerage firms, and 29 insurance companies. Additionally, a number of designated non-financial businesses and professions were examined to ensure adherence to AML/CFT requirements. In cases where weaknesses were detected, corrective measures were mandated, and penalties were recommended to enforce compliance.

The SIC also continued to engage actively at the international level. It maintained its involvement in the work of the FATF, MENAFATF, and the Egmont Group. Notably, the Director of the Compliance Unit had his mandate as Vice-Chair of the Egmont Membership Support and Compliance Working Group renewed for another two years, underscoring Lebanon’s continued relevance in global AML/CFT cooperation despite its grey listing.

Legal and Regulatory Developments

The year also witnessed important regulatory advancements. Banque du Liban issued several circulars, including Basic Circular No. 168 and Intermediate Circulars No. 692 and 705. The SIC itself issued guidance on politically exposed persons to improve monitoring and due diligence. Banks were required to establish anti-bribery and corruption units, while actions were taken against unlicensed financial activities. Although these developments demonstrated progress, FATF considered them insufficient in scope and effectiveness, highlighting the need for further comprehensive reforms.

Training and Capacity Building

The SIC emphasized that building expertise among its staff remains a long-term investment. In 2024, it organized local and international training in cooperation with global partners such as the International Monetary Fund, Interpol, FATF, and Banque de France. Training sessions covered a wide range of issues from parallel financial investigations to corruption risks and terrorism financing frameworks. The Commission also extended training support to other domestic agencies and reporting entities, ensuring that Lebanon’s wider AML/CFT network remained updated with international best practices.

Strategic Analysis and Trends

The report presented insights from five years of strategic analysis covering the period from 2020 to 2024. Key trends included increases in forgery, corruption, and cybercrime-related cases. These findings shaped supervisory priorities and were shared with stakeholders to raise awareness about emerging risks. Typologies published by the SIC included cases involving corruption among public officials, drug trafficking operations, and terrorist financing through small-scale transactions. Such case studies provided practical examples of how financial crime manifests and how targeted interventions could disrupt these networks.

Outlook: Exiting the Grey List

Looking ahead, the SIC stressed that exiting the grey list is Lebanon’s foremost AML/CFT priority. The Commission noted that success in this effort will depend on the collective work of judicial authorities, law enforcement bodies, customs, and the commercial registry, in addition to its own role. Areas requiring urgent attention include improving investigations, prosecutions, and convictions in money laundering and terrorism financing cases, demonstrating effective confiscation of illicit assets, and enhancing supervision of non-financial businesses. Strengthening international cooperation and ensuring transparency in beneficial ownership are also central to the action plan.

Both SIC Chairman Wassim Manssouri and Secretary General Abdul Hafiz Mansour acknowledged that while progress had been made in certain areas, Lebanon still faces a resource-intensive and multi-year effort to meet international expectations. Their messages underscored the resilience of the SIC’s staff and the necessity of persevering in the face of political, economic, and social difficulties.

The SIC Annual Report 2024 reflects a year of heavy challenges and difficult decisions. On one hand, Lebanon’s inclusion on FATF’s grey list highlighted gaps in its financial oversight framework. On the other, the report documented significant achievements in supervision, case handling, and international cooperation. The road to exiting the grey list will be long and demanding, but Lebanon’s commitment to implementing the FATF action plan signals a determined effort to restore credibility in its financial sector. Ultimately, the country’s ability to strengthen its AML/CFT regime will play a decisive role in regaining international trust and ensuring the stability of its banking system.