Is Crypto Legal in Labuan (Malaysia)?

Lebanon has no specific legal framework governing cryptocurrency, digital assets, or travel-rule compliance requirements as of 2025–2026, and no dedicated crypto-asset legislation has been enacted Lebanon Travel Advisory | Travel.State.gov

The Central Bank of Lebanon (Banque du Liban) has issued circulars addressing virtual currencies but has not established a comprehensive licensing or registration regime for Virtual Asset Service Providers (VASPs) Lebanon Travel Advisory - U.S. Department of State

No travel-rule implementation exists in Lebanon, and no entities have been licensed to operate as cryptocurrency exchanges or custodians under any specific crypto regulatory framework Lebanon Travel Restrictions - state.gov

The country faces severe economic and political instability, with the conflict situation impacting all financial sector operations and regulatory capacity Lebanon travel advice - GOV.UK

Practical reality: businesses operating in the crypto space in Lebanon do so without clear regulatory authorization, facing significant legal uncertainty and operational risks related to the broader security situation Lebanon Travel Advisory | Travel.State.gov

The Banque du Liban (BDL), Lebanon's central bank, serves as the primary financial regulatory authority, but has not established a dedicated crypto-asset regulatory division or published specific travel-rule guidance Lebanon Travel Advisory - U.S. Department of State

The Banking Control Commission of Lebanon (BCCL) operates under the central bank and oversees financial institutions, but no crypto-specific oversight mandate has been formally assigned to this body Lebanon Travel Advisory | Travel.State.gov

Lebanon's Financial Intelligence Unit (FIU) — the Special Investigation Commission (SIC) — is the designated authority for anti-money laundering matters, though its crypto-related jurisdiction remains undefined Lebanon Travel Advisory - U.S. Department of State

The Capital Markets Authority (CMA) of Lebanon has nominal authority over securities markets but has not issued any regulations addressing digital assets or virtual currency products Lebanon Travel Restrictions - state.gov

Lebanon's principal financial law remains the Code of Money and Credit (Legislative Decree No. 135, dated August 1, 1963), which establishes the central bank's powers but contains no provisions addressing digital currencies or virtual assets Lebanon Travel Advisory | Travel.State.gov

The Lebanese Penal Code includes general fraud and financial crime provisions but has no specific articles addressing cryptocurrency-related offenses or travel-rule obligations Lebanon Travel Advisory - U.S. Department of State

Parliament passed the Law on Combating Money Laundering and Terrorism Financing (Law No. 44, dated November 24, 2015), which amended and replaced the earlier Law No. 318 (2001), but the law does not explicitly reference virtual assets or VASPs Lebanon Travel Advisory - U.S. Department of State

Banque du Liban issued Basic Circular No. 134 (dated May 29, 2019), addressing digital financial services, including some references to electronic money and payment systems, but this circular does not establish a crypto licensing regime or travel-rule requirements Lebanon Travel Advisory | Travel.State.gov

In 2021, BDL issued Intermediate Circular No. 572 concerning virtual currencies (dated February 18, 2021), which cautioned financial institutions against dealing in cryptocurrencies and prohibited banks from facilitating crypto transactions, but this is an interim measure rather than comprehensive legislation Lebanon Travel Advisory - U.S. Department of State

Lebanon has been a member of the Middle East and North Africa Financial Action Task Force (MENAFATF), a FATF-style regional body, since the organization's establishment in 2004, and is subject to FATF recommendations including those on virtual assets Lebanon Travel Advisory | Travel.State.gov

Lebanon is not a member of the Financial Action Task Force (FATF) itself but is subject to FATF mutual evaluation reports through the MENAFATF process Lebanon Travel Advisory - U.S. Department of State

The most recent MENAFATF mutual evaluation report for Lebanon has identified significant deficiencies in the country's AML/CFT framework, including the absence of regulation for virtual assets and VASPs Lebanon Travel Advisory - U.S. Department of State

Lebanon is on the FATF list of jurisdictions subject to increased monitoring (the "grey list") as of the latest available assessments, which requires the country to address strategic AML/CFT deficiencies including those related to virtual assets Lebanon Travel Advisory | Travel.State.gov

FATF Recommendation 16 on wire transfers (the "travel rule") has not been transposed into Lebanese law as it applies to virtual asset transfers, and there is no domestic implementation guidance for VASPs Lebanon Travel Advisory - U.S. Department of State

Lebanon has no existing licensing or registration regime specifically for cryptocurrency exchanges, wallet providers, or other Virtual Asset Service Providers (VASPs) Lebanon Travel Advisory | Travel.State.gov

No capital requirements have been established for crypto-related businesses because no licensing framework exists under which such requirements could be set Lebanon Travel Advisory - U.S. Department of State

The Banque du Lıban's Intermediate Circular No. 572 effectively prohibits banks and financial institutions from engaging in virtual currency activities, meaning any licensed financial entity cannot lawfully operate in the crypto space Lebanon Travel Advisory - U.S. Department of State

There is no application process, timeline, or structural requirements for obtaining a crypto license because the legal framework to issue such licenses does not exist Lebanon Travel Advisory | Travel.State.gov

Zero entities have been licensed to conduct cryptocurrency exchange, custody, or transfer services in Lebanon under any formal regulatory authorization Lebanon Travel Restrictions - state.gov

The Lebanese Ministry of Economy and Trade has not issued any commercial licenses for crypto-related activities, and the Commercial Registry does not recognize virtual asset services as a licensable business category Lebanon Travel Advisory - U.S. Department of State

For a crypto business to operate legally, it would need to structure itself as a general commercial company under Lebanese commercial law, but such registration does not confer authorization to conduct VASP activities Lebanon Travel Advisory | Travel.State.gov

The Special Investigation Commission (SIC) of Lebanon serves as the country's Financial Intelligence Unit and oversees AML compliance for financial institutions, but its mandate has not been extended to cover VASPs Lebanon Travel Advisory - U.S. Department of State

Law No. 44 (2015) requires financial institutions to conduct customer due diligence as part of their AML obligations, but this law does not explicitly apply to virtual asset service providers since they are not defined as financial institutions under Lebanese law Lebanon Travel Advisory | Travel.State.gov

The CDD requirements under Law No. 44 include customer identification, verification of identity using reliable and independent source documents, and ongoing monitoring of business relationships Lebanon Travel Advisory - U.S. Department of State

Law No. 44 mandates enhanced due diligence for politically exposed persons (PEPs), requiring institutions to apply additional scrutiny to business relationships with foreign PEPs, their family members, and close associates Lebanon Travel Advisory - U.S. Department of State

The law requires enhanced monitoring for high-risk customers and complex or unusually large transactions, but these provisions have no practical application to crypto businesses due to the lack of regulatory clarity Lebanon Travel Advisory | Travel.State.gov

Financial institutions must report suspicious transactions to the SIC pursuant to Law No. 44 and its implementing regulations Lebanon Travel Advisory - U.S. Department of State

The reporting threshold and procedures for STRs are defined in the SIC's implementing regulations, but these regulations do not reference cryptocurrencies or provide guidance on reporting suspicious virtual asset transactions Lebanon Travel Advisory | Travel.State.gov

Law No. 44 requires financial institutions to maintain transaction records and customer identification data for at least five years following the end of the business relationship or the transaction date Lebanon Travel Advisory - U.S. Department of State

No specific record-keeping requirements apply to crypto businesses because they are not recognized as regulated entities under Lebanese law Lebanon Travel Advisory | Travel.State.gov

Law No. 44 introduced beneficial ownership requirements mandating that financial institutions identify the natural persons who ultimately own or control their customers Lebanon Travel Advisory - U.S. Department of State

Beneficial ownership rules would theoretically extend to any corporate entity dealing in virtual assets, but enforcement and implementation mechanisms for crypto businesses are absent Lebanon Travel Advisory - U.S. Department of State

The SIC has issued guidance on PEP screening that requires financial institutions to implement risk-based procedures for identifying and monitoring PEPs, but there is no equivalent guidance for VASPs Lebanon Travel Advisory | Travel.State.gov

Banque du Liban issued a circular in 2021 directing banks to refrain from all virtual currency transactions, though the BDL did not publicly report any enforcement actions against specific institutions for violations of this directive Lebanon Travel Advisory - U.S. Department of State

Lebanon's economic crisis has severely limited the operational capacity of regulatory and enforcement bodies, resulting in no publicly documented enforcement actions against unlicensed crypto businesses Lebanon Travel Advisory | Travel.State.gov

The Special Investigation Commission has limited public reporting on its enforcement activities, and no crypto-specific enforcement actions have been reported by the SIC Lebanon Travel Advisory - U.S. Department of State

No Lebanese court has issued published judgments addressing cryptocurrency regulation, travel-rule violations, or the legality of crypto business operations Lebanon Travel Restrictions - state.gov

No tax guidance has been issued for virtual assets in Lebanon, and the Ministry of Finance has not published any directives on how cryptocurrencies should be treated for income tax, capital gains, or VAT purposes Lebanon Travel Advisory | Travel.State.gov

The Lebanese income tax law (Legislative Decree No. 144 dated June 12, 1959) defines taxable income categories but makes no reference to virtual assets or cryptocurrency profits Lebanon Travel Advisory - U.S. Department of State

Lebanon's Value Added Tax law (Legislative Decree No. 219 dated June 15, 2000) contains no provisions addressing VAT treatment for digital asset transactions Lebanon Travel Advisory - U.S. Department of State

Lebanon has no legislative or regulatory definition of "virtual asset," "virtual asset service provider," or "digital asset," creating fundamental legal ambiguity for any business operating in this space Lebanon Travel Advisory | Travel.State.gov

The travel rule (FATF Recommendation 16) has not been implemented for virtual asset transfers, meaning there is no legal requirement or technical infrastructure for VASPs to share originator and beneficiary information on crypto transactions Lebanon Travel Advisory - U.S. Department of State

The BDL's prohibition on financial institutions dealing in virtual assets creates a compliance conflict for any entity seeking to operate as a VASP while maintaining traditional banking relationships Lebanon Travel Advisory - U.S. Department of State

Lebanon's status on the FATF grey list increases compliance costs and due diligence requirements for any business operating in the financial sector, including potential crypto operations Lebanon Travel Advisory | Travel.State.gov

The security situation in Lebanon makes it practically impossible to establish compliant operational infrastructure, particularly in conflict-affected areas Lebanon travel advice - GOV.UK

Banks in Lebanon cannot lawfully provide services to crypto businesses due to BDL restrictions, creating a significant barrier to accessing banking infrastructure Lebanon Travel Advisory - U.S. Department of State

Regulatory authorities lack the technical capacity and resources to implement and enforce any future crypto regulation or travel-rule framework, given the ongoing political and economic crisis Lebanon Travel Advisory | Travel.State.gov

Businesses face practical risks including the inability to obtain legal certainty on their operations, lack of dispute resolution mechanisms, and potential exposure to money laundering liabilities under general Lebanese criminal law Lebanon Travel Advisory - U.S. Department of State

Lebanon Travel Advisory | Travel.State.gov

Lebanon Travel Advisory - U.S. Department of State

Lebanon Travel Restrictions - state.gov

General Rule (Malaysia & Labuan): Malaysia does not impose a comprehensive Capital Gains Tax on the disposal of shares, securities, or most other capital assets, except for Real Property Gains Tax (RPGT) on the disposal of real property and shares in Real Property Companies (RPCs).

If cryptocurrency is held purely as a personal investment and disposed of for profit, this profit is generally not subject to capital gains tax in Malaysia (and by extension, Labuan, given the absence of a specific Labuan CGT regime).

However, if the trading of cryptocurrency is deemed to be a business activity (e.g., frequent, organized, with a view to generating regular profits, employing capital and resources), then the profits are considered income and subject to income tax (see below). The distinction between a "capital gain" and "trading income" is a matter of facts and circumstances, often determined by "badges of trade" principles.

Labuan Business Activity Tax Act 1990 (LBATA):

If a Labuan entity carries out activities related to cryptocurrency (e.g., trading, mining, operating an exchange, providing digital asset services) and these activities are deemed a "Labuan business activity," the profits derived from such activities are subject to tax under LBATA.

A fixed sum of RM20,000 (Ringgit Malaysia Twenty Thousand) if the Labuan entity meets the substance requirements (e.g., adequate full-time employees, annual operating expenditure) and elects this option.

Substance Requirements: For a Labuan entity to qualify for the preferential 3% tax rate or fixed sum, it must comply with substance requirements set by the Labuan Financial Services Authority (LFSA) under the Labuan Business Activity Tax (Requirements for Labuan Business Activity) Regulations 2018. This includes having an adequate number of full-time employees in Labuan and an adequate amount of annual operating expenditure in Labuan, proportionate to the level of activity.

Scope: This applies to income from active trading, mining operations, staking rewards, fees from exchange services, etc., if conducted as a Labuan business.

Business Income: If an individual or a Malaysian resident entity (not under LBATA) trades cryptocurrency extensively, systematically, and with the intention of making a regular profit, these activities may be considered a business. In such cases, the profits generated (from trading, mining, staking, etc.) are taxable as business income under Section 4(a) of the ITA 1967.

Individuals: Progressive tax rates from 0% to 30% (for resident individuals).

Malaysian Companies: Generally 24% (for paid-up capital exceeding RM2.5 million) or 15% (for the first RM150,000) / 17% (for the next RM450,000) / 24% (for income exceeding RM600,000) for companies with paid-up capital of RM2.5 million or less (SMEs).

Employment/Other Income: If crypto is received as remuneration for services rendered, it would be taxable as employment income (if from an employer) or other income (if from non-employment sources).

Malaysia abolished the Goods and Services Tax (GST) and reintroduced the Sales and Service Tax (SST) regime in September 2018.

Sales Tax: Sales Tax is imposed on taxable goods manufactured in Malaysia or imported into Malaysia. Cryptocurrency is not considered a tangible good, therefore not subject to Sales Tax.

Service Tax: Service Tax is imposed on taxable services provided by a taxable person in Malaysia.

The Royal Malaysian Customs Department (RMCD) has indicated that exchange services (brokerage, matching services) involving cryptocurrency could be subject to Service Tax if provided by a taxable person.

However, the transfer or trading of the cryptocurrency itself is generally not considered a taxable service under the current SST framework.

Labuan: Labuan has certain exemptions and special treatments under SST. However, general services provided from Labuan to a Malaysian recipient, or services consumed within Labuan, could still be subject to Service Tax if they fall under the ambit of the Service Tax Act 2018 and the provider is a registered person. As with mainland Malaysia, the crypto asset itself is not subject to SST, but certain related services might be.

Annual Tax Return: Labuan entities are required to file an annual tax return with the Inland Revenue Board (IRB/LHDN) of Malaysia, detailing their income and claiming the appropriate tax rate under LBATA.

Audited Financial Statements: Labuan entities must submit audited financial statements annually to the Labuan Financial Services Authority (LFSA).

Anti-Money Laundering/Counter-Terrorism Financing (AML/CFT): Labuan entities dealing with virtual assets are subject to stringent AML/CFT regulations supervised by LFSA, requiring them to report suspicious transactions and maintain records.

Annual Tax Return: Individuals and entities whose cryptocurrency activities are deemed a "business" must report their income in their annual income tax returns (e.g., Form B for individuals carrying on a business, Form C for companies).

Record Keeping: All taxpayers are required to maintain proper records of their transactions, including cryptocurrency purchases, sales, mining activities, and related expenses, for a period of at least seven years.

No Specific Crypto Form: There isn't a dedicated tax form solely for cryptocurrency transactions; they are reported under existing income categories.

Regulatory Frameworks: While tax laws are general, several regulatory bodies have issued guidelines or frameworks that indirectly impact the tax treatment by defining the nature of crypto assets:

Securities Commission Malaysia (SC): Regulates digital assets that are classified as "securities" under its Capital Markets and Services Act 2007, and supervises Digital Asset Exchanges (DAX). This classification can influence how the asset is treated for tax purposes (e.g., if it's considered an investment or part of a financial service).

Bank Negara Malaysia (BNM): Focuses on AML/CFT for reporting institutions (including those dealing with virtual assets). BNM also maintains a public register of digital currency and digital token exchanges.

Labuan Financial Services Authority (LFSA): Has issued guidelines for Digital Financial Services and the issuance of Digital Tokens/Assets in Labuan IBFC, which cover regulatory and licensing aspects for Labuan entities involved in crypto. These guidelines specify the type of regulated activities (e.g., digital banking, digital insurance, digital asset business) that can be conducted in Labuan.

Note: While the IRB's website provides general tax information, specific public rulings or guidelines directly addressing the tax treatment of cryptocurrency as a distinct asset class are limited. Taxpayers generally rely on interpretations of existing tax laws based on general principles. You would look for public rulings on business income, capital gains (for other assets), and general principles of taxation.

LFSA's Guidelines on Digital Financial Services: While not tax-specific, these define regulated activities and indirectly frame how income from these activities would be treated under LBATA. (Search for "Digital Financial Services" or "Digital Asset Business" on their site).

Labuan Business Activity Tax Act 1990 (LBATA) and related regulations (can be found in the "Legislation & Guidelines" section of LFSA's website).

Note: Information on SST, including its application to services, can be found here. You would typically look for "Service Tax Guide" or "Specific Guide on Financial Services" (though crypto services may not be explicitly listed).

Note: While primarily regulatory, the SC's classification of digital assets (e.g., as securities) can influence tax treatment. Their guidelines on Digital Assets and Digital Asset Exchanges are relevant for the overall understanding of the crypto landscape in Malaysia.

Note: BNM's focus is on AML/CFT, financial stability, and payment systems. Their policy documents on "Reporting Requirements for Digital Currencies and Digital Tokens" provide regulatory clarity, but not tax treatment.

Lebanon has no specific statutory framework for cryptocurrency or virtual assets as securities; the Capital Markets Authority (CMA), established under Capital Markets Law No. 161/2011, regulates "financial instruments" and securities business but has not issued any dedicated crypto-asset regulations as of 2025–2026. Faq - CMA

The CMA is the sole regulator for capital markets activities, licensing financial intermediation institutions across five activity categories (advising, dealing, managing, arranging, custody), with capital requirements ranging from 150 million to 6 billion Lebanese Pounds depending on the licensed activity. Faq - CMA

Licensing is possible for securities-related businesses, and the CMA has actively revoked licenses (e.g., Royal Financials in September 2021) and warned against unlicensed digital platforms in February 2026, but no entity has been licensed specifically to deal in cryptocurrency as a virtual asset class. Home - CMA

The practical reality is that crypto businesses in Lebanon operate in a legal gray area: they are not expressly prohibited, but no regulatory pathway exists for virtual asset service providers, and the CMA treats any offer of securities—including digital tokens—as subject to its approval unless an exemption applies. Faq - CMA

The CMA has warned it will take legal, administrative, and judicial measures against any person, entity, or digital platform engaging in or promoting investment activities in Lebanon in violation of applicable laws, signaling active enforcement intent in the digital asset space. Home - CMA

The Capital Markets Authority (CMA) is an independent and autonomous regulatory body established by the Capital Markets Law No. 161/2011, ratified by the Lebanese Parliament on August 17, 2011; it is a legal entity of public law with administrative and financial autonomy. Faq - CMA

The CMA's two main objectives are: (I) promoting and developing the Lebanese Capital Markets, and (II) ensuring the protection of savings invested in Financial Instruments, particularly by protecting investors from fraudulent activities through issuance of regulations aligned with international best practices and proper control and audit of all institutions dealing with financial instruments, per Article 5 of Law No. 161/2011. Faq - CMA

The CMA is not part of the Banque du Liban (BDL), but the Chairman of the CMA Board is the Governor of Banque du Liban; this does not affect CMA independence given its independent structure, per Article 4 of Law No. 161/2011. Faq - CMA

The CMA Board is composed of seven members chaired by the Governor of Banque du Liban, including three full-time executive board members who are experts in banking, capital markets, and financial affairs, and three part-time members representing ministries and departments directly involved in CMA work: the Director General of the Ministry of Finance, the Director General of the Ministry of Economy and Trade, and the Chairman of the Banking Control Commission, per Article 6 of Law No. 161/2011. Faq - CMA

The CMA licenses and approves financial institutions (as well as activities related to the securities business of banks) that deal in capital markets-related activities; it also regulates and licenses all financial products, securities (including securities-based insurance products), which are marketed and sold to investors in Lebanon, per Articles 1 and 11(3) of Law No. 161/2011. Faq - CMA

The CMA issued the Licensing and Registration Regulation – Series 2000, which governs licensing requirements, capital thresholds, and registered functions for approved institutions. Faq - CMA

The CMA issued the Offers of Securities Regulation, which governs public and exempt offers of securities, including conditions for foreign financial institutions soliciting securities business in Lebanon. Faq - CMA

The CMA's regulatory scope covers "financial instruments" as defined in Law No. 161/2011; there is no explicit statutory definition of cryptocurrency or virtual assets as financial instruments in any current Lebanese law or CMA regulation. Faq - CMA

On February 18, 2026, the CMA issued a public notice affirming it will take all necessary legal, administrative, and judicial measures against any person, entity, or digital platform that engages in or promotes investment activities in the Lebanese market contrary to applicable laws, specifically targeting unlicensed digital platforms. Home - CMA

The CMA signed a memorandum of understanding with the Special Investigation Commission (SIC) on March 5, 2021, for cooperation in combating money laundering, terrorist financing, and related crimes, out of a common interest in preserving the integrity and stability of Lebanon's financial and banking sector. Home - CMA

The CMA has been active in international cooperation, having chaired the Arab Securities Authorities Union in its twelfth session in Beirut on March 28, 2018, and participated in the International Conference of Stock Exchanges held in Beirut in February 2019. Home - CMA

The CMA has been working with the World Bank on a "Blue Print document on Market Development" issued in coordination with the World Bank in March 2017, which included a follow-up mission in November 2018 to support capital markets development in Lebanon. Home - CMA

Lebanon's payment and securities settlement systems are documented by the Banque du Liban in its White Book publication, which describes the structure of the country's financial system infrastructure. PAYMENTS AND SECURITIES SETTLEMENT SYSTEMS IN LEBANON

Lebanon faces significant financial system challenges, including funding shortfalls in the financial system, which prompted the drafting of a new law in December 2025 to address deposit recovery within the framework of the country's financial crisis. Lebanon drafts law to address funding shortfalls in financial system | Reuters

Any person who proposes to establish a financial intermediation company must apply for approval by the CMA, using the application form prescribed by the CMA, per Article 2202 of the Licensing and Registration Regulation – Series 2000. Faq - CMA

The capital requirement for establishing a financial intermediary institution varies between six set amounts: 150 Million, 300 Million, 600 Million, 1.5 Billion, 3 Billion, and 6 Billion Lebanese Pounds (LBP), depending on the activity to be licensed; this might be subject to change at any time by the CMA, per Article 2103(1) of the Licensing and Registration Regulation – Series 2000. Faq - CMA

An application for a license must specify each type of license the applicant is seeking; the different activities are grouped under five categories: advising, dealing, managing, arranging, and custody, with each category requiring a different capital requirement, per Article 2103(1) of the Licensing and Registration Regulation – Series 2000. Faq - CMA

Financial institutions regulated by BDL must report to the CMA with respect to their activities that fall under CMA's jurisdiction, per Article 2102(3) of the Licensing and Registration Regulation – Series 2000. Faq - CMA

"Approved person" means approved legal entities (not individuals) approved by the CMA for license to carry on securities business, referred to in CMA regulations as "Approved Institutions"; a "registered person" is an individual approved for registration by the CMA to carry out specific registrable functions as defined in Article 2402 of the Licensing and Registration Regulation – Series 2000 within an approved institution. Faq - CMA

The CMA requires all Approved Institutions to register the functions available at their institutions with the CMA; the deadline for compliance with registered functions requirements was set for the end of 2017. Faq - CMA

An individual who performs a registrable function within an approved institution must apply to the CMA to become a "registered person," and must have passed the qualification examinations prescribed by the CMA or obtained an exemption from the Authority, per Part E, Article 2405 of the Licensing and Registration Regulation – Series 2000. Faq - CMA

Persons can be exempted from being a registered person at the CMA based on their experience, academic degree, and certifications, per Part E, Articles 2409 and 2405 of the Licensing and Registration Regulation – Series 2000. Faq - CMA

Registrations remain valid for three years and can be reactivated; if a previously registered person passes three years outside an approved institution, the candidate must go through the exam process required by the CMA to be requalified, per Part E, Article 2405 of the Licensing and Registration Regulation – Series 2000. Faq - CMA

The CMA will not charge individuals or Approved Institutions any fees for registered functions at this time; all other fees due to CMA can be found on the "Payment & Fees Calculator" on the website. Faq - CMA

An Approved Institution is required to set a time-frame for staff performing registrable functions to pass the remaining exams; once received, the CMA will consider the time-frame proposed and shall revert with either an acceptance or a request for modification. Faq - CMA

Per CMA's current interpretation, each person responsible for a department is considered a "manager" for the purposes of the Licensing and Registration Regulation Series 2000. Faq - CMA

An institution does not need to get the approval of the CMA prior to hiring a person to fulfill a registrable function, but institutions are required to inform the CMA of employees who left the institution for whatever reason, per Article 2408 of the Licensing and Registration Regulation – Series 2000. Faq - CMA

An employee who passed BDL circular 103 qualifications is entitled to perform registrable functions only in the event the exams passed are the derivatives and securities exams offered by ESA (Ecole Supérieure des Affaires). Faq - CMA

No entity has been licensed by the CMA specifically to conduct cryptocurrency or virtual asset business. All licenses issued to date relate to traditional securities activities (advising, dealing, managing, arranging, custody) under the Capital Markets Law No. 161/2011. Faq - CMA

The CMA announced on June 19, 2019, the granting of a license to establish an Electronic Trading Platform (ETP) after completing a bidding phase that had three financial groups submit applications; Chairman Salame made the announcement at the sidelines of the Barclays Emerging Markets Conference in London. Home - CMA

The documents needed for licensing a financial intermediary institution are listed in the Licensing & Registration Regulation – Series 2000, specifically in Annexes 1 & 2, and a Checklist for Establishing and Licensing a Financial Intermediation Institution is available on the CMA website. Faq - CMA

The CMA website provides a "Checklist to Approve a Financial Intermediation Institution" aimed at making the process of establishing and licensing financial intermediation institutions in Lebanon an easy and straightforward task for applicants. Home - CMA

The CMA and the Special Investigation Commission (SIC) signed a memorandum of understanding on March 5, 2021, for cooperation in the field of combating money laundering, terrorist financing, and related crimes, out of a common interest in preserving the integrity and stability of the financial and banking sector in Lebanon. Home - CMA

The CMA's objective of protecting investors is manifest in controlling and auditing all institutions that deal with financial instruments, including oversight of their compliance with applicable laws and regulations. Faq - CMA

The CMA's regulatory framework requires Approved Institutions to maintain compliance with all applicable Lebanese laws, including anti-money laundering requirements; however, the specific AML/KYC obligations are primarily enforced by the Special Investigation Commission (SIC), which is Lebanon's Financial Intelligence Unit. Home - CMA

In its February 18, 2026 public notice, the CMA affirmed it will take all necessary legal, administrative, and judicial measures against any person, entity, or digital platform engaging in or promoting investment activities in Lebanon contrary to applicable laws, reinforcing that AML compliance obligations apply to all licensed entities. Home - CMA

The CMA's regulatory objective includes "proceeding against money laundering operations" as part of its continuing mission to regulate and supervise licensed financial institutions, ensuring compliance with financial and accounting standards and legislation. Home - CMA

The exact customer due diligence (CDD), enhanced due diligence (EDD), suspicious transaction reporting (STR), record retention, beneficial ownership, and PEP screening requirements applicable to CMA-licensed entities are not publicly detailed in the available CMA FAQ content; these obligations fall under Lebanon's broader AML framework administered by the SIC as the designated Financial Intelligence Unit. Faq - CMA

Financial institutions report to the CMA with respect to their activities that fall under CMA's jurisdiction, which includes their compliance with applicable regulations, per Article 2102(3) of the Licensing and Registration Regulation – Series 2000. Faq - CMA

The CMA's February 2026 notice targeted unlicensed digital platforms, indicating that platforms engaging in investment activities without proper licensing and AML compliance will face enforcement action. Home - CMA

On September 22, 2021, the CMA Board issued a decision to cancel/revoke the license granted to "Royal Financials S.A.L." (رويال فاينانشيلز ش.م.ل.) to engage in "dealing," "advising," "arranging," and "management" services related to financial instruments, removing the institution from the list of licensed institutions. Home - CMA

On February 18, 2026, the CMA issued a public notice affirming it will take all necessary legal, administrative, and judicial measures against any person, entity, or digital platform that engages in or promotes investment activities in the Lebanese market in violation of applicable laws, specifically targeting unlicensed digital platforms. Home - CMA

The CMA's February 2026 notice constitutes a formal warning to unlicensed digital investment platforms and promoters, signaling that enforcement actions may include legal, administrative, and judicial proceedings. Home - CMA

Trading on insider information is illegal according to Law No. 160/2011 (noting the FAQ text refers to Law 160/2011 in the context of insider trading, which is distinct from the Capital Markets Law No. 161/2011); the FAQ defines inside information as non-public information of a precise and material nature that would affect the price of the concerned security, and prohibits persons in possession of such information from making a trade. Faq - CMA

The CMA has the power to control and audit all institutions that deal with financial instruments, and its investor protection mandate includes taking action against fraudulent activities in the capital markets. Faq - CMA

In September 2024, the CMA affirmed it "continues and licenses" despite challenges, emphasizing its continued mission to regulate and supervise licensed financial institutions to ensure compliance with financial and accounting standards and legislation, and to proceed against money laundering operations. Home - CMA

No tax guidance has been issued for virtual assets.

The available CMA materials and Lebanese regulatory sources do not contain any specific tax treatment provisions for cryptocurrency, virtual assets, or digital asset gains. Faq - CMA

The Ministry of Finance is represented on the CMA Board through its Director General, per Article 6 of Law No. 161/2011, indicating tax policy coordination at the board level, but no specific crypto tax rules have been published by the CMA or the Ministry of Finance. Faq - CMA

Lebanon's financial crisis and the December 2025 draft law addressing funding shortfalls in the financial system do not address cryptocurrency taxation. Lebanon drafts law to address funding shortfalls in financial system | Reuters

No tax treatment provisions for digital assets have been identified in the Capital Markets Law No. 161/2011 or the CMA's Licensing and Registration Regulation – Series 2000 or the Offers of Securities Regulation. Faq - CMA

Lebanon lacks a comprehensive legal framework for cryptocurrency and virtual assets; the Capital Markets Law No. 161/2011 regulates "financial instruments" and securities business but contains no specific provisions addressing virtual assets, digital tokens, or cryptocurrency exchanges. Faq - CMA

The CMA's enforcement against unlicensed digital platforms in February 2026 indicates that the regulator will treat crypto-related activities as falling within its jurisdiction where they constitute "investment activities," creating legal uncertainty for businesses that cannot obtain clear regulatory classification. Home - CMA

No operator has been licensed to deal in cryptocurrency as a distinct asset class, meaning that crypto businesses face the risk of being classified as unlicensed financial intermediation institutions and subject to penalties, license revocation (as with Royal Financials), or judicial proceedings. Home - CMA

The capital requirements ranging from 150 million to 6 billion Lebanese Pounds for licensed activities create significant barriers to entry, and the absence of a designated license category for virtual asset service providers leaves crypto businesses unable to determine which capital tier would apply to their operations. Faq - CMA

Foreign financial institutions soliciting securities business in Lebanon must have an official form of representation in Lebanon per Article 6306(1) of the Offers of Securities Regulation, which imposes structural requirements on foreign crypto businesses seeking to access Lebanese investors. Faq - CMA

Any offer of securities, including digital tokens that may qualify as securities, is subject to CMA approval unless an exemption applies; the CMA will notify the offeror of its decision within 4 weeks, but the approval process creates compliance risk for crypto issuers. Faq - CMA

Exempt offers directed at professional clients, groups, and joint ventures, activities as part of another business, activities in connection with the sale of a company, and dealing or arranging for own account are exempt from approval and notification, per Article 6302(5) of the Offers of Securities Regulation and Articles 2107 to 2110 of the Licensing and Registration Regulation – Series 2000, but these exemptions were not designed with crypto assets in mind. Faq - CMA

The interpretation of whether a particular cryptocurrency or digital token constitutes a "financial instrument" or "security" under Law No. 161/2011 remains untested, creating significant legal risk for businesses that cannot determine their regulatory status with certainty. Faq - CMA

Lebanon's broader financial system instability, as evidenced by the December 2025 draft law addressing funding shortfalls and deposit recovery, exacerbates risks for crypto businesses operating in an already challenged economic environment. Lebanon drafts law to address funding shortfalls in financial system | Reuters

The practical reality is that while the CMA has the legal authority to regulate securities and financial instruments and has demonstrated willingness to take enforcement actions against unlicensed entities, there is no clear licensing pathway for cryptocurrency businesses, creating a high-risk environment characterized by regulatory uncertainty, potential enforcement action, and lack of clear tax treatment. Faq - CMA

The CMA's payment and securities settlement infrastructure, as documented in the BDL White Book, does not address digital asset settlement, custody, or transfer mechanisms, creating operational gaps for any licensed entity seeking to handle crypto assets. PAYMENTS AND SECURITIES SETTLEMENT SYSTEMS IN LEBANON

PAYMENTS AND SECURITIES SETTLEMENT SYSTEMS IN LEBANON

Lebanon drafts law to address funding shortfalls in financial system | Reuters