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

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 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.

Current assessment

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.

Sources

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).