The BDL logo on a piece of furniture at the institution in Hamra on Jan. 8, 2026. (Credit: Philippe Hage Boutros/L'Orient-Le Jour)
BEIRUT — A group of lawyers filed an appeal in January with Lebanon’s State Shura Council seeking to annul a Banque du Liban (BDL, central bank) directive that sharply tightened oversight of non-banking financial institutions, including money changers and money transfer companies, L’Orient-Le Jour has confirmed. The move targets main circular No. 3 (decision No. 13769), adopted last November, which imposes extensive reporting and identification requirements on these firms.
Under the regulation, companies must now collect verified information on customers, operators and transactions for all new clients and for any transaction exceeding $1,000, before the operation is carried out. The data must also be recorded in standardized Know Your Customer (KYC) forms, a measure typically required of banks as part of compliance.
The regulation was adopted a little over a year after Lebanon was placed on the Financial Action Task Force’s (FATF) gray list of jurisdictions vulnerable to financial crime, according to the global body coordinating the fight against it.
The directive came just over a year after Lebanon was placed on the Financial Action Task Force’s (FATF) gray list of jurisdictions vulnerable to financial crime. It aligns with recommendations from K2 Integrity, a firm hired tasked by BDL to help curb the cash economy and improve Lebanon’s FATF standing. Notably, the directive was issued shortly after a U.S. Treasury delegation visited Beirut, pressing authorities to block funding channels for Hezbollah.
The appeal, filed on Jan. 15, is awaiting a State Shura Council response, which has a 15-day window to notify BDL and receive a reply. The lawyers — Oussama Rahal, Ahmad Berjawi, Jad Tohmeh, Hicham Khoury Hanna, and Hussein Hachem — argue that the circular infringes constitutional rights and discriminates between citizens. They claim it violates Article 15, which guarantees the right to property, and creates unjustified distinctions between transactions under $1,000 and those above that threshold.
The lawyers also accuse the BDL of overstepping the prerogatives of the Special Investigation Commission, which is authorized to lift banking secrecy to fight financial crime—an institution created by a special law in 2001.
The lawyers also accuses BDL of overstepping the authority of the Special Investigation Commission, established in 2001 to lift banking secrecy in financial crime investigations. They argue the measure treats all citizens as potential suspects, a disproportionate response to Lebanon’s current risks.
"Lebanon was on the gray list from 2001 to 2017, and its institutions did not implement such discriminatory and liberticidal measures then. There is clearly a political agenda behind these measures," a source close to the matter told L’Orient-Le Jour.
The lawyers further warn that the directive raises serious concerns over client data confidentiality and security, as the collected information must be sent to BDL via email within a very short timeframe.
The central bank has not commented on the appeal. According to the previously cited source, another appeal has been recently filed with the State Shura Council, challenging a circular from the justice minister instructing notaries to avoid concluding transactions involving individuals subject to U.S. sanctions.
In parallel, in January, BDL issued a new regulation comprehensively modernizing rules for electronic payment service providers, wallet managers and money transfer companies.
Aoun hails agreement between Washington and Tehran after call from Iran FM