BEIRUT — When Banque du Liban (BDL) unveiled Circular No. 3, it dressed it up in the usual technocratic jargon—“compliance,” “monitoring,” and “risk mitigation.”
Yet strip away the polished wording, and a far less flattering reality emerges: Lebanon’s central bank has effectively surrendered its authority, handing Washington the master key while volunteering to police its own citizens on behalf of U.S. Treasury envoys who spent only a few hours in Beirut before issuing their latest set of financial commandments.
Circular No. 3, addressed to every money exchanger, electronic-wallet provider, transfer operator, lending counter, and financial institution, demands that clients declare any cash transaction of $1,000 or more.
Not fifteen thousand, as Lebanese law established. One thousand. In other words, the price of a modest refrigerator, or a month’s rent, now triggers a full-blown financial inquisition.
According to the circular, every entity licensed to handle cash must now collect and store exhaustive customer data under the banner of “Know Your Customer.” And exhaustive is an understatement.
The forms reviewed and “proudly” approved by the Central Council require everything short of a blood sample: full identity details, birth data, address down to the nearest landmark, employment history, monthly salary, sources of income, purpose of the transaction, marital information, frequency of transfers, and anticipated cash activity.
Lebanon enters the realm of forensic accounting: beneficial owners, business activity, financial health, family circumstances, and ownership percentages, all for the privilege of transferring $1,000 of your own money.
Ironically, or perhaps predictably, the circular claims legal grounding in existing regulations, while simultaneously violating them. Lebanese law (No. 42/2015) explicitly sets the cash-declaration threshold at $15,000, following FATF guidelines.
Yet the BDL, eager to demonstrate obedience to Washington’s “recommendations,” simply rewrote the rules. Without Parliament. Without oversight. Without debate.
To make matters worse, the circular expands monitoring from border crossings to internal Lebanese transactions, effectively transforming every money exchanger into a miniature intelligence desk.
Meanwhile, the same political and financial class that looted depositors’ savings now expects citizens to trust the very banking system that evaporated their life earnings.
The message is clear: “Return to the banks that robbed you — or prove your innocence each time you touch a thousand dollars.”
The Lebanese are now subjected to invasive scrutiny harsher than what many countries on the FATF grey list impose. As a reminder: even the UAE, a country under international review, never humiliated its residents with such intrusive, arbitrary demands.
As the saying goes, “If it quacks like a duck…” this circular walks, talks, and quacks like a foreign-imposed surveillance regime disguised as reform.
One cannot help but notice the timing: U.S. officials visit Beirut under the pretext of “drying up Hezbollah’s financial resources,” then promptly leave behind a regulatory time bomb.
Days later, the Central Council rubber-stamps it with the enthusiasm of a student handing in homework written by someone else.
The deadlines are equally telling: institutions have until December 1, 2025 to forward declarations; new clients must be processed immediately; existing clients have six months to surrender their data.
Whether any of this genuinely combats money laundering is beside the point. The political utility is the message, because at the end of the day, this isn’t about $1,000 — it’s about control, subordination, and the quiet normalization of foreign interference dressed up as “compliance”.
If Lebanon’s central bank is willing to rewrite national law at the snap of foreign fingers, what comes next? How long before every financial transaction becomes a political weapon? And when will Lebanon reclaim the right to regulate its own economy — without foreign guards stationed at every cash register?
To underscore the gravity of the moment: the fact that U.S. envoy Ortagus openly hailed Central Bank governor Karim Saeed as the “spearhead” in Washington’s battle against Hezbollah is nothing short of a national scandal.
Not metaphorically, literally. An American envoy publicly assigning the governor of Lebanon’s Central Bank a frontline role in the United States’ strategic confrontations is the kind of spectacle one expects in a country under de facto occupation, where the institutions of the so-called sovereign state operate as mere administrative appendages of the occupying power.