On Thursday the 29th of January 2015, the AML Committee of the Association of Banks (“ABL”) held a meeting at the head office of the ABL in Beirut, to brief compliance/AML officers on the new manual prepared by Deloitte with the collaboration of the ABL, namely “Sanctions & Embargoes Program” (“the Manual”).
The purpose of the Manual - that is addressed to all banks of different sizes operating in Lebanon - is to strengthen awareness around the risk associated with the sanctions and understand what transactions are prohibited subject to the restrictions imposed by the Central Bank of Lebanon, the Office of Foreign Assets Control, US department of the treasury, European Union, and United Nations.
The head of committee insisted on the fact that the content of the Manual should not be adopted verbatim by the banks, who must consider tailoring specific sections of it as deemed necessary. Therefore, the manual shall be amended to be in proportion with the organizational structure, size and complexity of offered products/services of the bank.. In other words, each bank shall utilize the Manual as a cornerstone to prepare its own policies and procedures, taking into consideration that it must be implemented in conjunction with such bank’s AML policies & procedures.
During and after the briefing, compliance and AML officers addressed their questions to the head of committee and to the representative of Deloitte who responded assuredly to the issues raised.