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