Implementation Rules of the Law Regulating the Money Changer Profession

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Circular No. 3 for Money Changer Institutions

We hereby enclose a copy of Decision No. 7933 dated 2001/9/27, attached with the Implementation Rules of Law No. 347 dated 2001/8/6 concerning the regulation of the money changer profession.

Beirut, 27 September 2001 Governor of Bank Al-Maghrib Riad T. Salamé

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Decision No. 7933

Implementation Rules of the Law Regulating the Money Changer Profession

The Governor of Bank Al-Maghrib, Pursuant to Law No. 347 dated 2001/8/6 concerning the regulation of the money changer profession in Lebanon, particularly Articles 3, 4, and 10 thereof, And pursuant to the decision taken by the Central Council of Bank Al-Maghrib in its meeting held on 2001/9/26, Decides as follows:

Article 1: The attached Implementation Rules concerning:

• Determining the required documents to obtain a license to practice the money changer profession.
• Determining the ceiling for traveler's checks that Category (B) money changer institutions may purchase and sell.
• Determining the banking facilities that money changer institutions may obtain from banks.
• The transfer of individual money changer institutions and of shares/portions in the capital of money changer companies.

Article 2: The provisions of Decision No. 6053 dated 1995/11/4, subject to Circular No. 8 for Money Changer Institutions dated 1995/11/4, are hereby repealed.

Article 3: This Decision and its attached Rules shall take effect immediately upon issuance.

Article 4: This Decision and its attached Rules shall be published in the Official Gazette.

Beirut, 27 September 2001 Governor of Bank Al-Maghrib Riad T. Salamé

This number corresponds to the old numbering system.

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Text/Section/2 CBL/R/3 T-30/2025-6 Implementation Rules of the Law Regulating the Money Changer Profession

Article 1: These Rules are issued to implement the provisions of Law No. 347 dated 2001/8/6 concerning the regulation of the money changer profession in Lebanon, particularly Articles 3, 4, and 10 thereof.

Part One: Required Documents to Obtain a License to Practice the Money Changer Profession:

Article 2: Applicants wishing to obtain a license to practice the money changer profession shall submit to Bank Al-Maghrib a request signed by the founders, partners, or owner of the individual institution, accompanied by the following documents: A. For all companies:

1. Document proving the identity of each founder, beneficial owner, and each person who will participate in the subscription and capital release, or each partner (ID card, passport, or family record statement, or a copy of the commercial registration file if any founder, shareholder, or partner is a legal entity).

2. Extract from the criminal record for each of the aforementioned natural persons, not older than three months.

3. Statement containing material and moral information and an accurate assessment of the financial standing of each of the aforementioned persons.

4. Articles of Association or company contract signed by all founders or partners.

5. Statement of participation percentage, for closed companies, specified for each prospective subscriber in the company's capital, including the share class and distribution method.

1 - This paragraph was amended pursuant to Article 42 of Interim Decision No. 13440 dated 2022/5/27 (Interim Circular No. 625).

6. Lease agreement registered in the company's name and duly authenticated, or a copy of the title deed currently owned by the company and designated as its headquarters, or a commitment from the owner to draft a lease or sale agreement in the company's name immediately upon obtaining a license from Bank Al-Maghrib.

7. Declaration letter from partners or founders stating that the company's headquarters is an independent and dedicated location for money changer activities without any other business.

8. 1 - For money changer institutions established after 2011/5/18, proof that partners in a general partnership, authorized partners in a limited partnership, or the president, board members, and general managers in a joint stock company, or managers in a limited liability company, and anyone who actually manages the concerned money changer institutions directly or indirectly, have successfully completed the qualification courses organized, prepared, or approved by Bank Al-Maghrib, particularly in the field of combating money laundering and terrorist financing. The requirement mentioned in this paragraph applies upon any change to any of the aforementioned persons in any money changer institution, regardless of its establishment date.

B. For individual institutions: The owner shall attach the following documents to his request in three copies, one original:

1. Document proving the owner's identity (ID card, passport, or family record statement).

2. Extract from the criminal record for the owner, not older than three months.

3. Statement containing material and moral information and an accurate assessment of the owner's financial standing.

4. Lease agreement in the owner's name duly authenticated, or a copy of the title deed currently owned by the owner and designated as the headquarters.

1 - This paragraph was added pursuant to Article 1 of Interim Decision No. 10727 dated 2011/5/21 (Interim Circular No. 264), then amended pursuant to Article 1 of Interim Decision No. 10787 dated 2011/8/22 (Interim Circular No. 272).

5. Declaration letter from the owner stating that the institution's headquarters is an independent and dedicated location for money changer activities without any other business.

6. 1 - For money changer institutions established after 2011/5/18, proof that the owner and anyone who actually manages the institution directly or indirectly have successfully completed the qualification courses organized, prepared, or approved by Bank Al-Maghrib, particularly in the field of combating money laundering and terrorist financing. The requirement mentioned in this paragraph applies upon any change to any of the aforementioned persons in any money changer institution, regardless of its establishment date. The Central Council of Bank Al-Maghrib shall grant the license to establish a money changer institution to the extent it deems it serves the public interest, after verifying the material and moral competence of the founders, beneficial owners, subscribers to the institution's capital, and persons intended to be assigned to senior administrative roles, particularly regarding the absence of any criminal or civil judgments against any of them or their partners, in Lebanon or abroad, for committing any ordinary felony, theft, breach of trust, fraud, money laundering, terrorist financing, or bankruptcy declaration, or regarding their inclusion on local or international sanctions lists.

1 - This paragraph was added pursuant to Article 2 of Interim Decision No. 10727 dated 2011/5/21 (Interim Circular No. 264), then amended pursuant to Article 2 of Interim Decision No. 10787 dated 2011/8/22 (Interim Circular No. 272). 2 - This clause was added pursuant to Article 43 of Interim Decision No. 13440 dated 2022/5/27 (Interim Circular No. 625).

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Part Two: Determining the Ceiling for Traveler's Checks:

Article 3: Pursuant to the provisions of Article 3 of Law No. 347 dated 2001/8/6 concerning the regulation of the money changer profession in Lebanon, at no time shall the amount of traveler's checks that Category (B) money changer institutions may purchase and sell, which remain in collection, exceed a value of ten thousand US dollars or its equivalent in other currencies.

Part Three: Banking Facilities for Money Changer Institutions:

Article 4: Pursuant to the provisions of Article 10 of the aforementioned Law No. 347, money changer institutions are prohibited from obtaining any facilities for money changer activities from banks in Lebanese Lira; however, these institutions may obtain facilities for money changer activities from banks in foreign currency, provided that these facilities do not exceed at any time an amount equivalent to 50% of their capital.

Part Four: Transfer of Individual Money Changer Institutions and Transfer of Shares/Portions in Money Changer Companies' Capital:

Article 5: Any transfer of an individual money changer institution is subject to the prior approval of Bank Al-Maghrib. Similarly, any transfer of shares or portions in the capital of money changer companies, regardless of their legal form, that results in any person directly or indirectly acquiring a percentage exceeding 10% (ten percent) of the total shares or portions of these companies is subject to the prior approval of Bank Al-Maghrib.

Article 6: In cases that do not require obtaining Bank Al-Maghrib's approval, the concerned company shall, on its own full responsibility, verify that all legal and regulatory conditions (shareholders' or partners' right of first refusal, board of directors' or partners' approval...) for the transfer of shares or portions in money changer companies are met, after the concerned parties provide it with the following documents, which must be retained:

• A copy of the transfer deed for shares or portions, dated and signed by the transferor and transferee, including their full addresses (P.O. Box, phone, fax/telex, email) and all transfer conditions, particularly the price.
• A copy of the ID (or passport) of the transferee if a natural person.
• Extract from the criminal record of the transferee if a natural person.
• A copy of the commercial registration certificate of the competent authority for the transferee if a company, along with a list of its shareholders or portions and their participation percentages.
• If applicable, a certified true copy of the inheritance inventory judgment or the will deed.
• Proof of compliance with the requirement stipulated in paragraph (8) of item (A) and paragraph (6) of item (B) of Article 2 of these Rules.
• For capital companies as transferees, a duly authenticated copy of the Articles of Association containing a clause stating that all shares of these companies are registered and fully owned, directly or indirectly, at all times by Lebanese natural persons or Lebanese companies whose shares are registered.

1 - This paragraph was added pursuant to Article 3 of Interim Decision No. 10787 dated 2011/8/22 (Interim Circular No. 272). 2 - This paragraph was added pursuant to Article 4 of Interim Decision No. 12194 dated 2016/2/29 (Interim Circular No. 411).

Article 7: In cases requiring prior approval from Bank Al-Maghrib, the request shall be submitted to the Governor's Secretariat by the concerned institution or company in three copies, one original, accompanied by: First: The transfer deed for the individual money changer institution or for shares/portions in money changer companies' capital, dated and signed by the transferor and transferee, including all transfer conditions, particularly the price, and an explicit clause suspending its enforcement pending Bank Al-Maghrib's approval, authenticated regarding the validity of signatures and signatories' capacity by a notary public for individual institutions, and by a notary public or the concerned company for shares/portions.

Second: If the transferor is a company:

1. A duly authenticated copy of the founding contract, Articles of Association, or any other document determining the authority competent to sign the transfer deed for shares/portions.

2. If applicable, a copy of the resolution by the competent body in the company approving the transfer and the authorization granted to sign the transfer deed.

1 - This paragraph was amended pursuant to Article 5 of Interim Decision No. 12194 dated 2016/2/29 (Interim Circular No. 411).

Third: If the subscriber or transferee is a natural person:

1. Extract from their criminal record, not older than 3 months.

2. Copy of their ID, family record statement, or passport.

3. Information statement, not older than three months, dated and signed by them, containing information about their social and financial status and details of their financial standing (assets and liabilities) and the estimated value of their participations, shares, and real estate properties, organized according to Form (1) attached.

Fourth: If the subscriber or transferee is a company:

1. For all companies: a. Company registration certificate with the competent audit authority. b. Financial statements for the last three years or for the period since establishment if established less than three years ago, organized and signed duly. c. If applicable, a copy of the resolution by the competent body in the company approving the subscription or transfer, and the authorization granted to sign the transfer deed. d. Extract from the criminal record, not older than three months, for the board president or general manager in a capital company, and for the manager or authorized partner in a personal company. e. Information statement, not older than three months, dated and signed by the competent authority, detailing the estimated value of their real estate investments, shares, and participations, organized according to Form (2) attached.

2. For capital companies, in addition to item (1) above: a. A duly authenticated copy of the Articles of Association containing a clause stating that all its shares are registered and fully owned, directly or indirectly, at all times by Lebanese natural persons or Lebanese companies whose shares are registered.

b. A duly authenticated copy of the minutes containing the election of the current board members and president. c. A list of shareholders indicating the number of shares in the company.

3. For limited liability companies and personal companies, in addition to item (1) above: a. A duly authenticated copy of the company's founding contract. b. If applicable, a duly authenticated copy of the partners' meeting minutes appointing the manager. c. A list of partners indicating their portions in the company.

Fifth: Proof of compliance with the requirement stipulated in paragraph (8) of item (A) and paragraph (6) of item (B) of Article 2 of these Rules.

1 - This paragraph was added pursuant to Article 4 of Interim Decision No. 10787 dated 2011/8/22 (Interim Circular No. 272).

Article 8: 1. Money changer institutions established as capital companies shall, within a maximum period of one month: a. Record in their registers every transfer of shares approved by the Central Council of Bank Al-Maghrib. b. Send a letter to the Legal Affairs Directorate at Bank Al-Maghrib informing it of the date of recording the aforementioned transfer.

2. Money changer institutions established as individual institutions, personal companies, or limited liability companies shall provide the Legal Affairs Directorate at Bank Al-Maghrib with a certified true copy of the transfer deed approved by the Central Council of Bank Al-Maghrib and registered at the Commercial Registry Secretariat, within a period of fifteen days from the date of recording the transfer in the said registry.

1 - This paragraph was added pursuant to Article 4 of Interim Decision No. 10787 dated 2011/8/22 (Interim Circular No. 272).

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Part Five: Miscellaneous Provisions:

Article 9: Every money changer institution shall immediately provide the concerned bank with:

1. A notice containing information about any check issued by or through it on behalf of its clients, particularly indicating whether it is in exchange for the money changer institution receiving cash amounts, the source and destination of these amounts, the beneficiary's identity, and the beneficial owner, in case the check or transaction value exceeds 10,000 US dollars or its equivalent.
2. A notice containing the information mentioned in item (1) of this Article regarding any transfer made to third parties in Lebanon resulting from a money changer transaction or the shipment of banknotes and/or "precious metals", regardless of the transferred amount.

1 - This section was added pursuant to Article 1 of Interim Decision No. 9233 dated 2006/1/9 (Interim Circular No. 101). 2 - The last amendment to this article was introduced pursuant to Article 5 of Interim Decision No. 10787 dated 2011/8/22 (Interim Circular No. 272). 3 - Refer to Decision No. 8024 dated 2002/1/11 (Circular No. 89 for Banks) concerning the shipment of banknotes and "precious metals". 4 - This article was added pursuant to Article 3 of Interim Decision No. 10727 dated 2011/5/21 (Interim Circular No. 264).

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Article 12: All money changer institutions shall, upon receiving cash amounts and/or metal bars and coins (hereinafter "precious metals") from one of their clients for the purpose of exchanging them for other currencies and/or "precious metals", or when conducting transactions involving the shipment of banknotes and/or "precious metals", do so exclusively through one of the following methods:

• Handing over to the client cash amounts and/or "precious metals", as applicable.
• Issuing a check in the client's name payable only to the first beneficiary.
• A transfer order to the account of the concerned client at a working bank in Lebanon or abroad without requesting any transfer to third parties except within Lebanon and subject to compliance with the requirement stipulated in item (2) of Article 9 of these Rules, regardless of the transferred amount.

1 - This article was added pursuant to Article 3 of Interim Decision No. 10727 dated 2011/5/21 (Interim Circular No. 264), then amended pursuant to Article 6 of Interim Decision No. 10787 dated 2011/8/22 (Interim Circular No. 272). 2 - Refer to Decision No. 8024 dated 2002/1/11 (Circular No. 89 for Banks) concerning the shipment of banknotes and "precious metals".

Article 13: 1. All money changer institutions are prohibited from:

• Directly depositing cash amounts into their clients' bank accounts.
• Accepting any type of agency on behalf of their clients.

2. Category "A" money changer institutions are prohibited from conducting any transfer transaction exceeding 1,500 US dollars not resulting from a money changer transaction or shipment of banknotes by receiving cash amounts from their clients and transferring them through their bank accounts to third parties, whether in Lebanon or abroad.

3. Money changer institutions are prohibited from conducting any operations of any kind (money changer or non-money changer), recorded inside or outside their balance sheets, with joint investment companies or funds whose shares or portions are, wholly or partially, bearer shares or owned, directly or indirectly, by companies or joint investment funds whose shares or portions are, wholly or partially, bearer shares.

4. Money changer institutions are prohibited from conducting financial and banking operations through electronic means subject to Decision No. 7548 dated 2000/3/30 and its amendments, and Decision No. 13790 dated 2026/1/9 concerning electronic payment service providers. All previous approvals granted to money changer institutions in this regard are repealed, and the concerned institutions shall be granted a period of six months to regularize their status.

1 - This clause was added pursuant to Interim Decision No. 13792 dated 2026/1/9 (Interim Circular No. 751). 2 - This article was added pursuant to Article 3 of Interim Decision No. 10727 dated 2011/5/21 (Interim Circular No. 264). 3 - This article was added pursuant to Interim Decision No. 10727 dated 2011/5/21 (Interim Circular No. 264) then amended pursuant to Interim Decision No. 13385 dated 2021/12/23 (Interim Circular No. 602).

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Article 14: Any money changer institution, in the course of its operations:

• Shall not open any type of deposit accounts with it, whether temporary or transitional, upon receiving cash funds.
• Shall execute operations, which fall within the tasks legally permitted to it, exclusively through its bank accounts without any use of personal accounts belonging to any of the persons listed in Article 10 above.

1 - This clause was added pursuant to Interim Decision No. 13792 dated 2026/1/9 (Interim Circular No. 751). 2 - This article was added pursuant to Article 3 of Interim Decision No. 10727 dated 2011/5/21 (Interim Circular No. 264).

Article 15: First: The following terms are intended:

• "Client": Any natural or legal person, whether a company or institution regardless of its type or any legal structure (Legal Arrangement) such as a Trust, or a body, organization, or non-profit association (mutual funds, cooperatives, social care homes, charities, clubs, etc.).
• "Beneficial Owner": Any natural person who ultimately owns or controls, directly or indirectly, the "Client" and/or the natural person on whose behalf the transactions are conducted. Cases of indirect ownership/control include situations where ownership/control is through a chain of ownership or through indirect control means.

1 - This clause was added pursuant to Interim Decision No. 13792 dated 2026/1/9 (Interim Circular No. 751). 2 - This article was added pursuant to Article 3 of Interim Decision No. 10727 dated 2011/5/21 (Interim Circular No. 264). 3 - This article was added pursuant to Interim Decision No. 10727 dated 2011/5/21 (Interim Circular No. 264) then amended pursuant to Interim Decision No. 13385 dated 2021/12/23 (Interim Circular No. 602).

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Second: Money changer institutions shall, each concerning itself:

1. Apply due diligence procedures regarding clients and beneficial owners regardless of the transaction value, which include verifying the identity of all their permanent and occasional clients, residents and non-residents, determining their profession's nature, understanding how the legal entity's ownership is structured and/or how it is controlled, understanding and determining the purpose and type of the transaction, and if necessary, obtaining information related to this purpose, identifying the "beneficial owner", source of funds, and continuously monitoring transactions, particularly in the following cases: a. Before or upon conducting the transaction or establishing a business relationship. b. When executing a single or multiple related transactions whose total reaches or exceeds 10,000 US dollars or its equivalent. c. If there is suspicion that a client is attempting money laundering or terrorist financing.

2. Apply due diligence procedures on their current clients based on relative importance and risk, and take due diligence measures regarding current business relationships at appropriate times, taking into account whether due diligence procedures were previously taken, when they were taken, and the adequacy of the data obtained.

3. Request, for the purpose of verifying the identity of the "Client" and "Beneficial Owner", the following official documents or data: a. If a natural person, presentation of a passport, ID card, family record statement, or residence permit. b. If a legal person, whether a company, institution, or legal structure, a duly authenticated copy of the Articles of Association, registration certificate, ownership structure, a list indicating how shares or portions are distributed (directly or indirectly), a list of authorized signatories, along with a copy of the ID of each legal representative, managers, and natural persons who own, directly or indirectly, a percentage entitling them to actual control over the company's management.

1 - This clause was amended pursuant to Article 1 of Interim Decision No. 13460 dated 2022/7/19 (Interim Circular No. 632). 2 - This paragraph was amended pursuant to Article 21 of Interim Decision No. 13440 dated 2022/5/27 (Interim Circular No. 625).

c. If the transaction is conducted through an agent or a person acting on behalf of the client, presentation of the original or a certified true copy of the power of attorney or proof that this person is authorized to do so, along with presentation of documents related to the agent's and principal's identity and those acting on behalf of the client, and verifying them. Due diligence procedures stipulated in item (1) of the "Second" section shall also apply to non-professional agents.

4. If satisfactory due diligence procedures on clients and beneficial owners cannot be performed, refrain from starting the transaction or conducting the transaction or terminating the business relationship, and consider reporting to the "Special Investigation Commission".

5. Maintain special registers for transactions exceeding each of them 10,000 US dollars or its equivalent.

6. Retain all records obtained through due diligence procedures regarding the "Client" and "Beneficial Owner", particularly their full name, profession, residential address, and registered business address for legal clients, and if different, the main business address, financial status, and account files for at least five years after account closure or termination of the business relationship, and all documents related to all transactions, including commercial correspondence and results of any analysis conducted, for at least five years after the transaction is completed, provided that transaction records are sufficient to allow reconstruction of individual transactions so that these records may serve as evidence for litigation and prosecution in case of any criminal activity.

7. Establish and adopt an effective internal control system (Internal Control System) for combating money laundering and terrorist financing, including at a minimum: a. Establishing a sufficient and effective AML/CFT procedures manual approved and adopted by senior management, including at a minimum the due diligence procedures required for clients whose transactions exceed a certain amount. b. Imposing high standards of integrity, honesty, and competence when hiring personnel.

c. Appointing a Compliance Officer at the management level, who must possess sufficient expertise in combating money laundering and terrorist financing and undergo continuous training courses in this field, or hold specialized certificates in this field such as the CAMS-Certified Anti-money Laundering Specialist certificate specified in Decision No. 9286 dated 2006/3/9 attached to Circular No. 103, and whose duties shall be as follows:

• Continuously train employees and involve concerned officials and employees in workshops, seminars, and lectures related to this subject to stay updated on money laundering and terrorist financing prevention methods.
• Prepare periodic reports on transaction monitoring based on a risk-based approach and compliance with required procedures.
• Audit transactions conducted throughout the client relationship period to ensure consistency between conducted transactions and what the institution knows about clients, their activity patterns, and the risks they pose, and if necessary, the source of funds.
• Ensure that documents, data, or information obtained through due diligence procedures are continuously updated and appropriate by reviewing existing records, particularly for high-risk client categories.
• Apply enhanced due diligence procedures proportionate to the risk level on business relationships and transactions conducted with natural and legal persons (including financial institutions) from countries to which the Financial Action Task Force (FATF) recommends taking such measures. For this purpose, the group's website shall be reviewed periodically, especially after each of its general meetings.
• Organize a centralized information system regarding money laundering and terrorist financing operations, including at least names disseminated by the "Special Investigation Commission" and names reported by the concerned institution to the "Commission", and continuously update them.

1 - This clause was repealed pursuant to Article 3 of Interim Decision No. 13460 dated 2022/7/19 (Interim Circular No. 632).

8. Take appropriate steps to identify money laundering and terrorist financing risks.