Over the past few years, Lebanon has witnessed an explosion of cash-service kiosks and “digital wallet” agents sprawling across supermarkets, convenience stores, corner shops, and even pharmacies. What was originally marketed as a push toward digital transformation has instead turned into a dense physical network of cash-in, cash-out booths—an ecosystem that paradoxically strengthens the very cash economy the country claims it wants to reduce.
What should have been a transition toward online financial services has become the opposite: a multiplication of cash touchpoints that encourages more physical currency circulation, weakens AML controls, and introduces glaring compliance risks.
A Digital Economy That Requires… Physical Stores?
Digital wallets around the world are designed to minimize the need for physical locations. They exist to provide mobile-based, instant, low-cost financial services—without the overhead of brick-and-mortar infrastructure and without the friction of cash.
In Lebanon, however, digital wallet licensees have adopted the exact opposite model. Their agents appear in:
•every supermarket,
•every convenience shop,
•every corner mini-market,
•and countless independent kiosks.
This density is unnecessary from a technological standpoint and counterproductive from a regulatory one. When a digital financial service requires a physical booth at every street corner, it is no longer digital—it’s merely a cash-handling business with a smartphone app on top.
Before the Crisis, Lebanon Functioned Without This Proliferation
For decades, Lebanon received substantial remittances from abroad through a limited number of regulated money transfer stores. They were concentrated in main areas, staffed by workers trained—or at least oriented—in compliance, monitoring, and identification procedures.
Despite the high volume of transfers, the system functioned with far fewer touchpoints.
The explosion of kiosks was not driven by necessity. It was driven by:
•competition over transaction volume,
•the collapse of trust in banks,
•and the opportunity to profit from commissions during a cash-dominant crisis.
Kiosks as Engines of a Growing Cash Economy
Every kiosk incentivizes more cash usage. The more locations that accept deposits and withdrawals, the more people rely on physical money and the more transactions occur outside the regulated financial sector.
At scale, this creates a shadow financial system—legal on paper, but structurally unmonitored.
Why?
Because most kiosk clerks are:
•not trained in AML/CFT procedures,
•not familiar with proper KYC checks,
•not motivated to enforce controls that may reduce transaction volume.
Their income depends on speed, throughput, and commissions—not on due diligence. As long as the transaction is completed, everyone earns.
Stopping a suspicious transfer means losing a commission. There is no incentive—and in many cases no supervision—to do the right thing.
Misaligned Incentives: Compliance vs. Commissions
This incentive structure creates predictable compliance failures.
Example -a store clerk used his own ID to process a USD 300 down payment for someone who forgot their ID—is not an exception. It’s systemic.
Such behaviors occur because:
•the clerk is not trained to say no,
•the system is designed around transaction volume,
•and the kiosk environment treats identity requirements as mere formalities.
If the model relies on non-bank employees with minimal oversight handling thousands of dollars in cash every day, misuse becomes inevitable.
Global Comparison: An Outlier Model
In most countries:
•digital wallets operate digitally,
•cash-in/cash-out services are limited and regulated,
•kiosks are automated machines or official bank agents,
•and supermarkets do not operate as financial service desks.
Lebanon’s model—embedding financial services into casual retail environments—would be unimaginable in most jurisdictions due to AML and consumer protection standards.
Instead of reducing cash dependency, this model entrenches it.
Why Curbing the Kiosks Would Curb the Cash Economy
Reducing kiosk proliferation would push digital wallets to become what they were meant to be:
•online payment tools,
•digital transfer systems,
•cash-light financial instruments.
A smaller, more controlled number of agents—properly trained, monitored, and licensed—would tighten AML oversight and reduce the chaotic cash-based ecosystem that currently thrives.
Fewer kiosks means:
•fewer untrained intermediaries handling cash,
•fewer loopholes,
•fewer anonymous transfers,
•a reduced shadow economy,
•and a clearer shift toward real digital payments.
Conclusion: Lebanon Needs Digital Transformation, Not More Cash Counters
The current landscape is not digital transformation—it’s the fragmentation of financial services into a thousand unregulated cash desks. Every kiosk added to the network pushes the country further away from a cash-reduced future.
If Lebanon truly wants to modernize its economy, it must:
•limit the physical footprint of cash agents,
•strengthen training and AML compliance,
•incentivize actual digital usage,
•and enforce clear boundaries between retail shopping and financial services.
Until then, the cash economy will continue to flourish—ironically, under the banner of “digital innovation.
