2025-01-01

Lending-2025- Circular No. 28 Results of the National Risk Assessment Process for Money Laundering and Terrorist Financing Crimes

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.

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Results of the National Risk Assessment Process for Money Laundering and Terrorist Financing Risks

Section One: Summary of Money Laundering Risk Assessment Results for National Sectors.

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:

SectorSector DetailsRelevant 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 relevanceHigh
All operations reflect (Operations related to Funds): Addressing, heat, and warmthHigh to High
Usually reflects other operations like interest and clearing transfers, and customer elevationHigh 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 probabilityHigh 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.

Section Two: Summary of Money Laundering Risk Assessment Results for Sectors.

The assessment relies on classification grades, risk elevation levels, and national capabilities:

Section Three: Summary of Money Laundering Risk Assessment Results for Banking Lending Sectors.

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.

Section Four: Summary of Terrorist Financing Risk Assessment Results for National Sectors.

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:

SectorRisk GradeElevation LevelProbability/Exposure Grade
National BanksHigh to HighHigh to HighHigh, acceptable for operations
Financial OperationsHigh, acceptable for operationsLow to HighLow to High
Banking LendingLow
Credit EndowmentLow to HighLow to HighLow to High
Securities (National coherence)High to HighHighHigh
PropertiesLow
Foreigners (National)Low
National AssetsHigh
Income Streams (National and Parties)High to HighHigh to HighHigh to High
Names (National)LowHighLow
Real Estate WorkersHigh, Real Estate
Property loyalty and administrationLowLow

The national sector's risk elevation is estimated as (High), based on national factors:

Section Five: Summary of Terrorist Financing Risk Assessment Results for Sectors.

Results range from "High" to "Low" according to the following protocol:

SectorRisk GradeElevation LevelProbability/Exposure Grade
NationalLow to HighLow to HighLow to High
NationalLow to HighLow to HighLow to High
Banking LendingLow
Credit EndowmentLow
Securities (National coherence)Low
PropertiesLow
Foreigners (National)Low
Income Streams (National and Parties)Low to HighLowLow to High
Names (National)Low to HighLowLow
Real Estate SectorLow to HighLowLow to High
Names (National)Low

Criteria for Estimating Terrorist Financing Classifications in the Banking Lending Sector:

The following details criteria for estimating terrorist financing classifications in the banking lending sector:

SectorFactors 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 FactorsHigh
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):

  • Classification of terrorist financing National to (High)
  • Classification of terrorist financing Capable on the National to (High)
  • Classification of terrorist financing Incoming on the National to (High)
  • Classification of terrorist financing Transversal on the National is not renewed

National Sector Risk Elevation Estimation:

The national sector's risk elevation is estimated as (High), based on national factors:

SectorNational Factors
General/ Base turnover rateLow
National Capable WorkersNot renewed /
Factors/ National Capable to Reality Rich More experiencedNot renewed
National Incoming WorkersNot renewed /
Factors/ National Incoming from Reality Rich More experiencedNot renewed
Circular file base NationalLow
National Fulfillment AcceptanceLow
Usage of Census, Clients, and Other TransactionsNot renewed
Suitability/ Effectiveness for Terrorist FinancingLow