2025-11-14 | 13769

KYC Form for Cash Transactions

Bank of Lebanon issued Basic Decision No. 13769, mandating non-banking financial institutions to implement a standardized Know Your Customer (KYC) framework for cash transactions. The decision establishes a USD 1,000 per-transaction threshold, requires the completion and retention of Forms A1-RF (client profile) and B1-RF (transaction record), and mandates identity verification, source-of-funds determination, and daily electronic reporting. Non-compliance triggers administrative penalties, daily delay fines in US dollars, and potential criminal prosecution under the Penal Code.

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Basic Circular No. 3 for Financial Institutions Also directed to Credit Counters, Exchange Houses, and Electronic Payment Service Providers

We submit herewith a copy of the Basic Decision No. 13769 dated 2025/11/14 regarding the Know Your Customer (KYC) Form for Cash Transactions.

Beirut, 14 November 2025 Governor of Bank of Lebanon: Karim Saeed

  1. Amended this title by Article 1 of Interim Decision No. 13815 dated 2026/5/4 (Interim Circular No. 761), effective as of 2026/6/30.

Basic Decision No. 13769 Know Your Customer (KYC) Form for Cash Transactions

The Governor of Bank of Lebanon, pursuant to the Monetary and Banking Law, specifically Articles 70 and 174 thereof, pursuant to the Anti-Money Laundering and Counter-Terrorist Financing Law No. 44 dated 2015/11/24, specifically Article 4 thereof, pursuant to Law No. 347 dated 2001/8/6 regarding the regulation of the exchange profession in Lebanon, specifically Article 13 thereof, pursuant to Basic Decision No. 7818 dated 2001/5/18 and its amendments regarding the financial and banking operations monitoring system to combat money laundering and terrorist financing, pursuant to Basic Decision No. 7933 dated 2001/9/27 regarding the executive system for the exchange profession law, pursuant to Basic Decision No. 7548 dated 2000/3/30 and its amendments regarding financial and banking operations via electronic means, pursuant to the decision of the Central Council of Bank of Lebanon taken in its meeting held on 2025/11/12,

decides the following:

Article 1: Definitions: For the purpose of applying this circular, the following terms mean:

  • "Non-Banking Financial Institutions": Financial institutions, credit counters, exchange houses, and electronic payment service providers subject to Bank of Lebanon's supervision.
  • "Cash Transactions": Any deposit, withdrawal, payment, or receipt of a cash amount equal to or exceeding USD 1,000 by a natural or legal person (such as electronic money services, electronic fund transfers, financing, currency exchange, and cash collection).
  1. Amended this title by Article 1 of Interim Decision No. 13815 dated 2026/5/4 (Interim Circular No. 761), effective as of 2026/6/30.
  2. Amended this article by Article 2 of Interim Decision No. 13815 dated 2026/5/4 (Interim Circular No. 761), effective as of 2026/6/30.

Article 2: Scope of Application: In application of the applicable regulations and instructions issued by Bank of Lebanon, and in line with international standards for combating money laundering and terrorist financing, and to prevent misuse of the licensed financial system in suspicious or high-risk operations (High Risk Operations), "Non-Banking Financial Institutions" must:

  1. Collect information and data related to their clients and operations, verify their accuracy, record them systematically, and retain them.
  2. Establish and apply effective policies and procedures to detect unusual or suspicious operations, particularly repeated operations suspected of aiming to avoid the "Cash Transactions" threshold.

Article 3: Operations Monitoring: "Non-Banking Financial Institutions" must comply with the following:

  1. Adopt a threshold of USD 1,000 or its equivalent on a per "cash transaction" basis (transactional basis).
  2. Pay attention to repeated operations that may aim to avoid the specified threshold and take necessary measures to detect and handle them.
  3. Comply with their adopted anti-money laundering and counter-terrorist financing policies and procedures, and comply with the obligation to report suspicious operations according to applicable regulations.

Article 4: The Forms and Their Completion Mechanism: "Non-Banking Financial Institutions", upon adopting the two forms specific to "Cash Transactions", must comply with the following:

  1. Complete Form A1-RF when executing any "cash transaction" equal to or exceeding USD 1,000 or its equivalent. This form is completed by the concerned client once and updated periodically according to the risk rating associated with the client, not exceeding 5 years for any client.
  2. Amended this article by Article 2 of Interim Decision No. 13815 dated 2026/5/4 (Interim Circular No. 761), effective as of 2026/6/30.
  3. Complete Form B1-RF when executing any "cash transaction" equal to or exceeding USD 1,000 or its equivalent, on a per-transaction basis, excluding cash withdrawals, and retain these forms for no less than 5 years.
  4. Both Forms A1-RF and B1-RF are manually signed by both the client and the institution.
  5. Forms A1-RF and B1-RF may be signed electronically by a natural person client, according to the electronic signature conditions stipulated in Basic Decision No. 13790 dated 2026/1/9 and Basic Decision No. 7548 dated 2000/3/30, provided that the value of the "cash transaction" or the sum of repeated operations for a single client in the concerned institution within one month does not exceed USD 10,000.

Article 5: Identity Verification and Source of Funds Determination: "Non-Banking Financial Institutions" must comply with the following:

  1. Verify the client's identity in each "cash transaction" and retain a copy of a valid identification document bearing their photograph.
  2. Update the document upon its expiration.
  3. Determine the source of funds without requiring the client to provide supporting documents for the forms, unless:
    • The value of the "cash transaction" or the sum of repeated operations at the concerned institution for a single client equals or exceeds USD 10,000 monthly.
    • Suspicion arises regarding the "cash transaction" or if the nature of the operation does not align with the information in Form A1-RF.

Article 6: Information Retention and Reporting: "Non-Banking Financial Institutions" must comply with the following:

  1. Securely retain all information and documents related to "Cash Transactions" for no less than 5 years.
  2. Send daily reports (a separate report for each day) to Bank of Lebanon via email (lb.gov.bdl@1rf-curr-fx) within a period not exceeding two working days, according to the "Daily Operations Report" form prepared in Excel format and attached herewith, available at the following link: Click to download.
  3. Amended this article by Article 2 of Interim Decision No. 13815 dated 2026/5/4 (Interim Circular No. 761), effective as of 2026/6/30.

Article 7: Penalties: Any person violating the provisions of this decision is subject to administrative penalties stipulated in Article 208 of the Monetary and Banking Law, and the concerned institution is subject to daily delay fines calculated in US dollars, as determined by the Central Council. Furthermore, violation of this Basic Decision constitutes an offense under Article 770 of the Penal Code, and Bank of Lebanon is authorized to prosecute any violating institution before the competent judicial authority.

Article 8: This decision takes effect upon its issuance.

Article 9: This decision is published in the Official Gazette.

Beirut, 14 November 2025 Governor of Bank of Lebanon: Karim Saeed

  1. Amended this article by Article 2 of Interim Decision No. 13815 dated 2026/5/4 (Interim Circular No. 761), effective as of 2026/6/30.

Form A1-RF (Form 1)

Part 1: Information about the Non-Banking Financial Institution

  • Name:
  • Address:
  • Phone No.:
  • Contact Person Name:
  • Registration/License Decision No.:
  • Tax ID:

Part 2: Information about the Client (if a natural person)

  • Full Name:
  • Mother's Name and Maiden Name:
  • Gender:
  • Date of Birth:
  • Place of Birth:
  • Record No./Place:
  • Nationality:
  • Other Nationality:
  • Marital Status (Single/Married/Divorced/Widowed):
  • Spouse/Partner Name and Maiden Name:
  • Country of Residence:
  • Full Residential Address (City/District/Street/Building Name/Floor) and Phone:
  • Occupation/Profession:
  • Rank:
  • Workplace (Company Name):
  • Full Work Address and Phone:
  • Annual Salary or Income:
  • Other Income Sources:
  • Confirmations:
    • Not convicted in the last 10 years for ordinary crimes, theft, breach of trust, fraud, issuing worthless checks due to bad faith, misappropriation of funds/values, or concealing proceeds from these offenses.
    • Not having ties (residence, work, or any activity) with high-risk countries per FATF classification (Iran, North Korea, Myanmar).
  1. Amended this form by Interim Decision No. 13815 dated 2026/5/4 (Interim Circular No. 761), effective as of 2026/6/30.

Part 3: Information about the Client (if a legal person)

  • Company Name:
  • Registration Date:
  • Place of Registration:
  • Commercial Address:
    • Building:
    • Street:
    • Landmark:
    • Town/City:
    • Postal Code:
    • Country:
  • Tax Residence:
  • Tax ID No.:
  • Commercial Register No.:
  • Phone:
  • Email:
  • Company Website (optional):
  • Legal Form of the Legal Entity (e.g., joint stock company, limited liability company, sole proprietorship, partnership):
  • Nature of Commercial Activity / Sector Classification:
  • Expected Annual Cash Flows: < USD 20,000; between USD 20,000 and 100,000; between USD 100,000 and 500,000; between USD 500,000 and 1,000,000; between USD 1,000,000 and 5,000,000; between USD 5,000,000 and 25,000,000; > USD 25,000,000.
  • Frequency of Expected Cash Transactions (once/daily/weekly/monthly/other):
  • Average Expected Amount per Transaction:
  • Expected Annual Cash Activity (estimated):

Information about the Ultimate Beneficial Owner / Economic Rights Holder

  • Name:
  • Maiden Name:
  • Father's Name:
  • Mother's Name and Maiden Name:
  • Gender:
  • Date of Birth:
  • Place of Birth:
  • Nationality:
  • Record No.:
  • Record Place:
  • ID/Passport No.:
  • Resident in Lebanon (Yes/No):
  • Residential Address:
  • Ownership Percentage:

Signature:

Form B1-RF (Form 1)

Information about the Cash Transaction

  • Amount:
  • Currency:
  • Source: Salary, Business Revenues, Sale of Properties/Assets, Loan, Other Source (specified);
  • Purpose of Transaction:
  • How Funds are Brought: By the Individual, Other Means (specified);
  • Are Funds Imported? If yes, from which country?

Signature:

  1. Amended this form by Interim Decision No. 13815 dated 2026/5/4 (Interim Circular No. 761), effective as of 2026/6/30.