October 11, 2026
Lebanon faces a critical test to go beyond mere compliance with the requirements of the Financial Action Task Force (FATF), by introducing fundamental amendments to the Anti-Money Laundering and Countering the Financing of Terrorism Law No. 44. This step aims to increase the efficiency of control over the movement of funds, and prevent the exploitation of commercial activities and real estate and financial investments to give legal covers to illicit funds.
These amendments come as a continuation of Lebanon’s commitment, which was announced in October 2024 based on a report issued by the “FATF” last June, in cooperation with the group and the Middle East and North Africa Financial Action Task Force (MENAFATF). The joint action plan includes addressing deficiencies in risk assessment, strengthening international judicial cooperation to recover assets, tightening oversight of non-financial professions and high-risk associations, and updating data on the “true beneficiaries” who actually own or control companies, in addition to intensifying judicial investigations and applying targeted financial penalties.
International assessments revealed structural gaps related to identifying the actual beneficiary and pursuing funds channeled through multiple intermediaries and commercial entities before they stabilized in the local economy. Although the applicable law already criminalizes the transfer or investment of illicit funds and separates the crime of laundering from the original crime, the biggest challenge lies in the insufficiency of previous investigations in tracking the money’s paths and focusing only on the crimes that produce them, in addition to the limited final rulings.
In the legislative process, the Finance and Budget Committee completed the proposed amendments to Law No. 44 prepared by the Bank of Lebanon, without introducing fundamental changes to them. The committee postponed the final approval until the Ministry of Justice submitted its observations in writing, after Minister Adel Nassar was absent from the session. It is planned that these amendments will be devoted through the plenary session to expand the scope of prosecution, so that it includes beneficiaries of apparently legitimate investments, not just money carriers.
The “beneficiary” file is a basic pillar of this treatment. A reading by political economy professor Muhammad Musa indicates that companies officially registered in the name of a person may be subject to complete control by other parties that do not appear in the founding documents. Here the seriousness of the loopholes related to indirect control and the use of agents to establish commercial entities outside of anti-laundering controls is highlighted.
Moussa believes that the actual value of the amendments is measured by their ability to bridge the gap between registered ownership and actual control, and prevent escape from prosecution by distributing funds to multiple entities and names. He explains that treatment requires expanding risk-based supervision to include real estate, precious metals, and commercial sectors, while linking commercial, real estate, tax, and financial records to ensure accurate and up-to-date money tracking data and international cooperation to recover assets.
Moussa concludes that the actual success of the amendments will be measured by clear quantitative and qualitative indicators, including the number of investigations, prosecutions, and judicial rulings, the value of frozen and recovered assets, and the accuracy of the data on the true beneficiaries, with the need to publish periodic indicators for evaluation and accountability, and to avoid any selective use of the law that harms legitimate economic activities.
