Lebanon
1. Does Lebanon have a sanctions regime in place?
Lebanon has a boycott system in place targeting Israeli related entities and individuals (the law relating to the Boycott of Israel was enacted on 23/6/1955), and a boycott office that oversees the enforcement of boycott regulations and acts as a liaison office for the Central Office of Boycott that oversees the work of all Arab boycott offices. Pursuant to Law no. 318 dated 20/4/2001, a Special Investigation Commission (“SIC”) was established and is fighting money laundering and terrorism financing. The SIC has the exclusive right to freeze and lift banking secrecy for use by competent judicial authorities and the Higher Banking Commission by application of the United Nations convention relating to anticorruption. These powers were granted to the SIC by virtue of Law no. 318 and aim at combating money-laundering pursuant to the UN Convention Against Corruption (“UNCAC”) which Lebanon joined on 22/4/2009. The SIC investigates suspicious transaction reports and ensures the compliance of banks, financial institutions and other reporting entities with pertinent anti-money laundering and counterterrorism financing regulations, both domestically and internationally.
2. Does Lebanon implement UN sanctions?
As a member of the UN, Lebanon does implement UN sanctions. It is to be noted however that international sanctions, whether UN, EU, UK or US sanctions targeting Lebanese political groups are not always effective in Lebanon due to internal political considerations.
3. Does Lebanon implement an autonomous sanctions regime?
Lebanon does not have an autonomous sanctions’ program per se comparing to the programs in force in the US, EU or UK; but it is worth noting that Lebanese banks and financial institutions abide by aforementioned international sanctions (e.g. Lebanese Banks swiftly abide by the US sanctions because the Lebanese economy is dollarized and Lebanese banks cannot function without their U.S. correspondent banks in order to clear their transactions in U.S. dollars). Also, as member of the United Nations, Lebanon implements UN Sanctions.
Lebanon strictly enforces the boycott of Israel.
4. What is the nature of the sanctions regime in Lebanon?
The boycott of Israel was enacted by the law relating to the Boycott of Israel dated 23/6/1955 which prohibits any person or legal entity, directly or indirectly from engaging in any deal or transaction of any nature whatsoever (commercial, financial etc.) with individuals or entities domiciled in Israel, or of Israeli nationality or working for or in the interest of Israel. This law also bans import and trade in any products whatsoever (including financial instruments) of Israeli origin. Breaches of these prohibitions would result in various sanctions inter alia, criminal sanctions such as imprisonment and imposition of fines, prohibition from exercising certain commercial activities, seizure of the goods which are the subject of the breach and blacklisting of infringing individuals and entities. The Military Court is the competent authority to settle disputes related to the breach of the laws of boycott of Israel.
5. Does Lebanon maintain a list of sanctioned individuals and entities?
The Lebanese boycott office maintains a list of blacklisted entities and vessels (a check for blacklisted entities can be conducted through the boycott office). The Lebanese security forces hold a list of sanctioned individuals or entities that are subject to international criminal prosecution (such as individuals and entities featuring on the INTERPOL wanted people list).
6. Are there any other lists related to sanctions?
No.
7. Does Lebanon have a licensing or authorization system in place?
There is no licensing nor authorization system in place. Individuals and entities that are blacklisted in connection with the above-mentioned boycott regulations can apply for de-blacklisting subject to specific requirements.
8. What are the consequences for a breach of sanctions in Lebanon?
The consequences are considered on a case-by-case basis. If sanctions result in an international criminal prosecution, sanctioned individuals/entities may be subject to prosecution/sanctions in Lebanon. A breach of the boycott of Israel regulations results in criminal sanctions varying from imprisonment with hard labour to the imposition of fines, prohibition of exercising certain activity and the seizure of breaching goods.
9. Who are the relevant regulators in Lebanon and what are their contact details?
There is no special regulator in Lebanon. As mentioned above, the Lebanese boycott office oversees the implementation of the Israel boycott regulations. It is associated with the Ministry of Economy and Trade of Lebanon. Beirut Central District, Riad Al Soleh Street, Azarieh Building, 5th Floor, 02B T: (+961) 1 982360
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Jean Baroudi Managing Partner
Lea Ferzli
Senior Associate
Baroudi & Associates
Achrafieh 5585 Building P
Gemayel Avenue
P.O. Box 11–7236
Beirut
Lebanon
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