The Encyclopedia of Economic Statecraft

Current entry

Banque du Liban Circular 170 (2025): version history

Entry-text changes are distinguished from website design and metadata changes. The publication change log explains editorial reasons; the dated entry review record explains scope.

Publication change log ยท Current review record

Text changes from 2.0.38 to 2.0.39

Reason for this change. Complete the whole-entry review against the published decision and current register. Distinguish issuance from Gazette publication, operative addressees from the cover, available measures from actual enforcement, and FATF context from party-level findings. Preserve the limits of the register and bilingual checking.

Before: edition 2.0.38

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. The official circular remained listed with zero amendments as at 27 July 2026.

After: edition 2.0.39

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.

Before: edition 2.0.38

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 applies to institutions licensed by the central bank and the two latter categories.

It prohibits direct or indirect financial, commercial or similar activity with specified unlicensed money-exchange institutions, remittance companies, associations and organisations. The decision names Al-Qard Al-Hassan, Tashilat SARL, Yousser Company for Finance and Investment and Bayt al-Mal Lil Muslimeen as examples, then reaches other entities designated on international sanctions lists within its terms.

The listed conduct includes services, transfers, intermediation, financing, rental, lending and facilitating access to the Lebanese banking system. Article 2 identifies possible measures including licence suspension or withdrawal, account and asset freezing, and referral to the Special Investigation Commission.

Legal boundaries

The decision is a Lebanese supervisory measure. It does not itself make a foreign designation, determine criminal guilt or convert every foreign listing into a central-bank finding. Hezbollah attribution should be tied to the relevant foreign authority or evidence, not inferred from the circular's existence.

The preamble cites Lebanon's FATF increased-monitoring status and unlicensed financial-sector risks. That context records the central bank's stated rationale. It does not prove why every institution was listed or that Circular 170 caused a later financial outcome.

Israeli strikes and financial restrictions against Al-Qard Al-Hassan (2024-present) concerns separate military and foreign-sanctions actions. Those events should not be merged into Banque du Liban's competence or enforcement record.

After: edition 2.0.39

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.

Before: edition 2.0.38

As at 30 July 2026, the official register controlled amendment status, while the decision controlled scope. Editors should distinguish issuance, supervision, enforcement action and observed compliance. Any claim of account closure, asset freeze or market effect requires a dated decision or attributed evidence from the responsible body.

Implementation and evidence

Covered institutions need procedures to identify the named and analogous unlicensed entities, direct and indirect relationships, and access to the banking system. The circular's reference to foreign sanctions does not remove the need to determine the relevant list, identity and transaction. Name matching alone can create false positives.

The enforcement measures in Article 2 are possible consequences, not proof that any specific institution received them. A licence suspension, frozen account and SIC referral should be documented separately. Referral also does not establish a final finding by the commission or a court.

Correspondent banks can make independent risk decisions under their own laws and policies. The circular's stated objective of protecting correspondent relationships does not compel an overseas bank to retain access. Assessment should distinguish central-bank supervision, local-bank compliance, correspondent withdrawal and market response.

Current FATF monitoring is jurisdiction-level context. It should not be used to infer that a named party breached the circular or that all Lebanese financial activity presents the same risk.

After: edition 2.0.39

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.

Before: edition 2.0.38

  1. Banque du Liban, Basic Circular 170 register (accessed 30 July 2026).
  2. Banque du Liban, Basic Decision 13735, 14 July 2025.
  3. Financial Action Task Force, Lebanon country page (accessed 30 July 2026).
  4. US Treasury, OFAC Lebanon-related sanctions programme (accessed 30 July 2026).

After: edition 2.0.39

  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.