Panel Submits Action Plan to Meet FATF Demands, Exit Grey List

A committee appointed by Justice Minister Adel Nasr has submitted a comprehensive report aimed at implementing key judicial reforms required under the Financial Action Task Force (FATF) action plan, as Lebanon seeks to exit the FATF grey list and avoid the risk of further international isolation.

The committee, established on February 20, 2025, was tasked with devising corrective measures to address long-standing gaps in Lebanon’s legal and institutional framework for combating money laundering and terrorism financing.

The committee, chaired by lawyer Karim Daher, includes Judge Rana Akoum, former Judge Jean Tannous, lawyers Lara Saadeh and Mohammad Moughabit, and financial expert Mohammad Fahili. 

According to a Justice Ministry statement, the report, handed to Minister Nassar on May 7, includes the committee’s findings, detailed annexes, and a set of additional recommendations from individual members. It reflects months of work, consultations, and targeted assessments designed to align Lebanon’s judicial and financial oversight institutions with FATF standards.

The committee’s analysis centered on Lebanon’s most recent FATF mutual evaluation report, with particular focus on shortcomings involving the Special Investigation Commission (SIC), the judiciary, international cooperation mechanisms, and the non-financial business sector, including notaries, lawyers, and corporations.

According to the report, these professions are critical to Lebanon’s compliance efforts due to their role in property registration, ownership transfers, client verification, and the monitoring of beneficial ownership, highlighting this sector as a priority for reform.

The document also outlines a series of structural and institutional reforms intended to strengthen the Justice Ministry's capabilities, reinforce the functioning of the judiciary, especially the Office of the Public Prosecutor and law enforcement agencies, and upgrade the operations of the International Cooperation Office to ensure more effective cross-border collaboration.

Among its key proposals are enhanced oversight of the notarial profession, modernization of the commercial registry, and improved coordination with the country’s bar associations and certified accountants. These measures are intended to elevate Lebanon’s practical compliance levels and shield the country from slipping further into global financial isolation.

While the reforms align closely with FATF benchmarks, the committee stressed that the recommendations were not simply technical compliance with external demands. Rather, they form part of a broader national strategy to confront financial crime and bolster the rule of law.

Committee members reaffirmed their commitment to support the Ministry of Justice through the next phases of implementation, pledging continued engagement and technical assistance.

Lebanon was officially placed on the FATF grey list in October 2024, with the global watchdog citing “weak measures by the Lebanese government in combating money laundering and terrorism financing.” The designation has further complicated the country’s economic recovery, restricting access to international financial markets and deterring foreign investment.