2025-01-01
The Central Bank of Lebanon issued Circular No. 28 detailing the National Risk Assessment results for money laundering and terrorist financing across national and banking lending sectors. The circular updates risk classifications from Low to High, reflecting increased electronic fraud since 2017, sectoral capacities, and specific operational criteria. It mandates revised risk elevation levels, probability assessments, and compliance protocols for financial institutions to align with updated national standards.
Money laundering classifications in the State of Lebanon range from (High) to (Low), noting that these classifications reflect familiar categories assessing the following relevant sectors:
| Sector | Sector Details | Relevant Original Sectors |
|---|---|---|
| Financial Funds (from Most Classified): Broad transfers, embezzlement, public corruption, scarcity, misuse of authority, credit mismanagement, financial stability. | High | |
| National Banks with Financial and Banking relevance | High | |
| All operations reflect (Operations related to Funds): Addressing, heat, and warmth | High to High | |
| Usually reflects other operations like interest and clearing transfers, and customer elevation | High to High on transfers | |
| Reflects on related contracts collecting all relevant rates, technical and directional handling. | High to High | |
| Reflects basic work in assurance (distributed factor, and less probable probability | High to High credit). | |
| Credit mismanagement Credit mismanagement in the base adds duplication. | High |
The assessment considers two main factors: the first relates to the national sector's risk elevation, and the second, which differs in assessing 11 sectors as detailed below. It also considers the state's capacity to manage national sector risks.
Recently (2024), and consequently, this was not reflected in the National Risk Assessment which highlighted an important observation: electronic fraud has increased, especially since the beginning of 2017-2023.
The assessment relies on classification grades, risk elevation levels, and national capabilities:
The money laundering risk in the banking lending sector (national) is assessed as (High), based on classification results ranging from (Low) to (High), and the national sector's risk elevation level.
The terrorist financing risk grade on national sectors ranges from (High) to (Low), with classifications in Lebanon ranging from (Low) to (High). The following are the relevant terrorist financing sectors:
| Sector | Risk Grade | Elevation Level | Probability/Exposure Grade |
|---|---|---|---|
| National Banks | High to High | High to High | High, acceptable for operations |
| Financial Operations | High, acceptable for operations | Low to High | Low to High |
| Banking Lending | Low | ||
| Credit Endowment | Low to High | Low to High | Low to High |
| Securities (National coherence) | High to High | High | High |
| Properties | Low | ||
| Foreigners (National) | Low | ||
| National Assets | High | ||
| Income Streams (National and Parties) | High to High | High to High | High to High |
| Names (National) | Low | High | Low |
| Real Estate Workers | High, Real Estate | ||
| Property loyalty and administration | Low | Low |
The national sector's risk elevation is estimated as (High), based on national factors:
Results range from "High" to "Low" according to the following protocol:
| Sector | Risk Grade | Elevation Level | Probability/Exposure Grade |
|---|---|---|---|
| National | Low to High | Low to High | Low to High |
| National | Low to High | Low to High | Low to High |
| Banking Lending | Low | ||
| Credit Endowment | Low | ||
| Securities (National coherence) | Low | ||
| Properties | Low | ||
| Foreigners (National) | Low | ||
| Income Streams (National and Parties) | Low to High | Low | Low to High |
| Names (National) | Low to High | Low | Low |
| Real Estate Sector | Low to High | Low | Low to High |
| Names (National) | Low |
The following details criteria for estimating terrorist financing classifications in the banking lending sector:
| Sector | Factors Related to Types of Terrorist Financing (High) |
|---|---|
| Found that types/cases in the State (related to misuse of base) are not renewed | |
| Found that types/cases on the National (related to misuse of base) are not renewed | |
| National Rich and Coherent Factors | High |
| National Factor (especially Base) | Not renewed |
| National Rich Factor (especially Base) | Not renewed |
The base gives identities of terrorist financing on the National (High) to (Low):
The national sector's risk elevation is estimated as (High), based on national factors:
| Sector | National Factors |
|---|---|
| General/ Base turnover rate | Low |
| National Capable Workers | Not renewed / |
| Factors/ National Capable to Reality Rich More experienced | Not renewed |
| National Incoming Workers | Not renewed / |
| Factors/ National Incoming from Reality Rich More experienced | Not renewed |
| Circular file base National | Low |
| National Fulfillment Acceptance | Low |
| Usage of Census, Clients, and Other Transactions | Not renewed |
| Suitability/ Effectiveness for Terrorist Financing | Low |