NNA - On December 21st 2023, MENAFATF published Lebanon’s Mutual Evaluation Report (MER) on AML/CFT measures, after having discussed and adopted the MER in its May 2023 plenary meeting, and subsequently endorsing in its December plenary meeting amendments to the MER as requested by the FATF.
The MER indicates that Lebanon scored acceptable results on technical compliance in thirty four recommendations out of the FATF forty recommendations whereby “Compliant” or “Largely Compliant” ratings were achieved. In the six other recommendations where improvements are needed, Lebanon received “Partially-Compliant” ratings, thus necessitating some legislative amendments.
As for the eleven immediate outcomes that measure effectiveness, the MER indicated in nine immediate outcomes in which Lebanon received “moderate” level of effectiveness ratings that the country’s AML/CFT regime delivered some positive results that require further strengthening in areas covering; risk identification, international cooperation, supervision and other measures primarily for the non-financial sector, legal persons & arrangements along with beneficial ownership, parallel financial investigations and targeted financial sanctions with respect to UNSCRs. The remaining two immediate outcomes in which Lebanon received “low” level of effectiveness ratings are mainly associated with insufficient confiscation of criminal proceeds and assets, in addition to shortcomings related to money laundering prosecutions and convictions that need to be more commensurate with the country risks, and for which proportionate and dissuasive sanctions are needed.
Lebanon was evaluated based on the FATF assessment methodology that is applied across all jurisdictions, whereby the evaluation process was carried out under known exceptional circumstances that continue to prevail. Nevertheless, as in all jurisdictions, the necessary corrective measures need a whole-of-government approach to be implemented by the concerned domestic competent authorities. As the national coordinator for the assessment process, the Special Investigation Commission (SIC) shall apprise the Speaker of the Parliament and the Prime Minister of the MER outcome so as to communicate to each concerned domestic competent authority the corrective measures needed to improve the effectiveness of Lebanon’s AML/CFT regime. Henceforth; Lebanon will be required to submit to MENAFATF progress reports during 2024 that will be discussed and decided upon in its plenary meetings.
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