Banque du Liban Circular 170 (2025)

Banque du Liban Basic Circular 170 attaches Basic Decision 13735 of 14 July 2025, which restricts dealings by specified Lebanese financial institutions with unlicensed entities subject to foreign sanctions. It is a Lebanese supervisory measure, not a foreign sanctions designation. Article 4 makes the decision effective upon issuance; Article 5 separately requires publication in the Official Gazette. Decision 13735, cover and Articles 4 and 5.

Addressees and prohibition

The circular is addressed to banks, finance companies, all other institutions regulated by Banque du Liban, financial-intermediation institutions and collective-investment schemes. Article 1 states the prohibition for banks, finance companies and other institutions licensed by the central bank, together with the latter two categories. The cover's addressee description should not substitute for the operative article. Decision 13735, cover and Article 1.

Article 1 prohibits direct or indirect financial, commercial or similar activity, wholly or partly, with the unlicensed money-exchange institutions, remittance companies, associations and organisations described in it. The published English text names Al-Qard Al-Hassan, Tashilat SARL, Yousser Company for Finance and Investment and Bayt al-Mal Lil Muslimeen, then refers to other entities designated on international sanctions lists. Those names and categories should be read within the article's wording, not as a prohibition on every unlicensed business or a new designation of every similarly named entity. Decision 13735, Article 1, English and Arabic versions.

The listed conduct includes providing or facilitating financial or cash services, transfers and intermediation; financing, rental or lending arrangements; and direct or indirect access to the Lebanese banking system in any currency, including through the entities' branches. Decision 13735, Article 1.

Legal consequences and limits

Article 2 identifies potential measures for non-compliance, including licence suspension or withdrawal, freezing of accounts and assets, and referral to the Special Investigation Commission. Article 3 states that Banque du Liban will take appropriate administrative and legal measures to implement the decision. These provisions establish available consequences and stated enforcement intent; they do not prove that a particular account was frozen, a licence withdrawn or a referral made. Decision 13735, Articles 2 and 3.

The decision does not itself adjudicate criminal guilt. A referral to an investigative body is not a final judicial finding. Any attribution linking an entity to Hezbollah requires separate evidence from the relevant authority; it should not be inferred from the circular alone. The separate events discussed in Israeli strikes and financial restrictions against Al-Qard Al-Hassan (2024-present) are not a Banque du Liban enforcement record.

Rationale and FATF context

The preamble cites Lebanese financial legislation, earlier central-bank decisions, Lebanon's FATF increased-monitoring status and risks arising from dealings with unlicensed financial entities. It also states concern for correspondent-bank relationships and the national interest. These are the central bank's recorded reasons, not independent proof of each underlying allegation or of the measure's effectiveness. Decision 13735, preamble.

FATF's 30 October 2026 statement continues to include Lebanon among jurisdictions under increased monitoring. It records progress and remaining tasks concerning the national anti-money-laundering and counter-terrorist-financing framework. The statement does not call for enhanced due diligence solely on that basis and favours risk-based assessment over cutting off entire classes of customers. It is jurisdiction-level context, not a finding that any named party breached Circular 170. FATF, 30 October 2026 statement, introductory explanation and Lebanon section.

Current assessment

On 10 November 2026, Banque du Liban's register displayed zero intermediate circulars amending Basic Circular 170. That observation establishes what the register showed on that date. It does not establish the absence of every other relevant legal instrument, unpublished supervisory direction or subsequent change. The decision's issuance date is verified; this review does not establish the separate date on which it appeared in the Official Gazette. Basic Circular 170 register; Decision 13735, Articles 4 and 5.

Application requires the operative category, entity identity, relationship and transaction to be checked. The English spellings reproduce the published English decision; they are not a complete list of aliases. This entry does not certify a current foreign designation or a specific institution's compliance.

For analysis, issuance, supervisory implementation, local-bank compliance, correspondent decisions and market response remain separate questions. The decision's aim of protecting correspondent relationships is not a guarantee that an overseas bank will maintain access. An observed financial outcome requires its own dated evidence and cannot be attributed to this circular from timing alone.

Sources

1. Banque du Liban, Basic Circular 170 register, *Preventive measures to protect the financial and economic sector in Lebanon from dealing with unlicensed entities subjected to sanctions issued by foreign authorities*, decision dated 14 July 2025, register accessed 10 November 2026. Addressees and intermediate-amendments fields.
2. Banque du Liban, Basic Circular 170 and Basic Decision 13735, English version, 14 July 2025, cover, preamble and Articles 1 to 5, three PDF pages, accessed 10 November 2026.
3. Banque du Liban, Basic Circular 170 and Basic Decision 13735, Arabic version, 14 July 2025, cover and Articles 1 to 5, three PDF pages, accessed 10 November 2026. Retained for comparison with the published English version; no certified translation is supplied here.
4. Financial Action Task Force, *Jurisdictions under Increased Monitoring*, 30 October 2026, introductory explanation and Lebanon section; Lebanon country page, accessed 10 November 2026.