Lebanon’s Central Bank Circular No. 3, imposing strict KYC rules on cash transactions, has sparked criticism for perceived U.S. influence and overreach in the country’s financial sector.
Iran criticizes Lebanon’s BDL policies
The impact of the recent policies and decision taken by Lebanon’s Central Bank, also known as Banque du Liban (BDL), seems to have been witnessed sooner than expected.
The aforementioned effects have even reached Tehran itself, given that the Iranian-backed Hezbollah has been the primary group affected by the BDL’s circulars.
One particular circular which prompted criticism is the recent Circular No. 3 (Decision No. 13769) that the BDL issued on November 14, 2025, also known as the “KYC Form for Currency Transactions and Exchange Operations.”
Tehran times accuses BDL of bowing to Washington
On November 15, 2025, the Iranian newspaper, Tehran Times, claimed that “Lebanon’s central bank has effectively surrendered its authority, handing Washington the master key while volunteering to police its own citizens on behalf of U.S. Treasury envoys who spent only a few hours in Beirut before issuing their latest set of financial commandments.”
The newspaper ridiculed the decision by saying that “in other words, the price of a modest refrigerator, or a month’s rent, now triggers a full-blown financial inquisition.” It added that “the forms reviewed and ‘proudly’ approved by the Central Council require everything short of a blood sample: full identity details, birth data, address down to the nearest landmark, employment history, monthly salary, sources of income, purpose of the transaction, marital information, frequency of transfers, and anticipated cash activity.”
Moreover, Tehran Times believed that the BDL’s circular contradicts Lebanese law, claiming that law No. 42/2015 “explicitly sets the cash-declaration threshold at $15,000, following FATF guidelines,” meanwhile the Lebanese Central Bank believed that its move (amongst many yet to come) aim at enhancing the compliance environment within the financial sector in order to remove the country from the FATF (Financial Action Task Force) gray list, as “the inclusion of any country on this list is considered an indicator of gaps in combating illicit financial transactions, which leads to increased international scrutiny and oversight and a decrease in trust from global financial institutions.” Despite this fact, the newspaper accused the BDL of being “eager to demonstrate obedience to Washington’s ‘recommendations’,” by simply rewriting “the rules. Without Parliament. Without oversight. Without debate.”
Tehran Times continued its allegations, this time touching on the Lebanese banking system. It claimed that “to make matters worse, the circular expands monitoring from border crossings to internal Lebanese transactions, effectively transforming every money exchanger into a miniature intelligence desk,” adding that “meanwhile, the same political and financial class that looted depositors’ savings now expects citizens to trust the very banking system that evaporated their life earnings.” Thus, it considered the message to be clear: “Return to the banks that robbed you, or prove your innocence each time you touch a thousand dollars.”
The newspaper ended its critical article by saying, “Whether any of this genuinely combats money laundering is beside the point. The political utility is the message, because at the end of the day, this isn’t about $1,000, it’s about control, subordination, and the quiet normalization of foreign interference dressed up as ‘compliance’.” It claimed that an “American envoy publicly assigning the governor of Lebanon’s Central Bank a frontline role in the United States’ strategic confrontations is the kind of spectacle one expects in a country under de facto occupation, where the institutions of the so-called sovereign state operate as mere administrative appendages of the occupying power.”
However, the Iranian newspaper’s article was somewhat similar to a local one, considered to be affiliated with Hezbollah and the so-called “Axis of Resistance.” On the same day, al-Akhbar published as well a critical article regarding the very same circular, claiming the Central Council to be “subject to American dictates.”
What is BDL’s controversial circular No. 3
As outlined above, Lebanon’s Central Bank issued Circular No. 3, as “the first step in a series of precautionary measures aimed at strengthening the compliance environment within the financial sector. This step involves imposing preventive measures on all non-banking financial institutions licensed by the Central Bank of Lebanon, including money transfer companies, exchange companies, and other entities that carry out cash transactions in foreign currencies and their transfers to and from Lebanon.”
Article 2 of the circular clearly states that “in implementation of the applicable regulations and procedures and the instructions issued by the Central Bank of Lebanon, and in line with international standards on combating money laundering and financing of terrorism, and to prevent the misuse of the licensed financial system in suspicious operations that pose high risks (high-risk operations) and other illegal activities aimed at concealing the true source of funds and the beneficiaries thereof, all non-banking financial institutions are required to collect information and data related to their operations, verify, record, and maintain them, in accordance with what is stated in the ‘RFI Model - Cash Operations,’ attached herewith, and any subsequent amendments to this model.”
More specifically, Article 3 mentions that the “non-bank financial institutions are required to fill out the table specified in paragraphs (I), (II), and (III) in the ‘RF1 Cash Operations Form’ attached to this decision whenever a cash transaction equals or exceeds the amount of $1,000, or its equivalent, for a single transaction.”
The decision came following BDL’s Circular No. 170, which bars funds linked to Lebanese entities under international sanctions from entering the country’s formal banking sector, as well as Lebanese Minister of Justice Adel Nassar’s Circular No. 1355. The latter requested notaries, when organizing powers of attorney and transactions, to verify that all parties involved are not listed on national and international sanctions lists, refrain from organizing transactions if otherwise, and to inform the Ministry of Justice and the Special Investigation Commission about the matter. Furthermore, the BDL’s decision came after a joint Lebanese-American meeting in the Baabda Palace on November 9, 2025, during which President General Joseph Aoun and a delegation from the United States Treasury agreed to combating illicit finance; including money laundering (ML) and financing of terrorism (FT).
