With the stroke of a pen, Lebanon has once again been restored on the Financial Action Task Force’s (FATF) grey list. Between its first listing in 2000 and its second in October 2024, twenty-two years of anti-corruption and anti-money laundering legislation were simply “discarded” into the sea of negligence. Layers of official indifference, wrapped in partisan interests, buried a fresh legislative framework under bureaucratic inertia, making its implementation nearly impossible.

While it is well known that Lebanon’s listing on the grey list is due to its failure to implement 46 corrective measures—21 of which were never enacted and 25 only partially executed—it is less acknowledged that one of the primary reasons behind this failure is sheer negligence. This is the key finding of a comprehensive study conducted by Sky for Research and Consulting and Euro-Med Human Rights Monitor, based on official correspondence between Lebanon’s Prime Minister’s Office and relevant ministries, agencies, and professional bodies.

Silence from the authorities

As FATF scrutinized Lebanon’s anti-money laundering framework since 2022, the country’s officials remained in deep slumber, despite repeated warnings that gray-listing was imminent. In January 2024, the Prime Minister’s Office reached out to 13 key institutions, urging them to implement specific corrective measures in line with FATF’s evaluation.

The first letter, sent in February 2024, was addressed to the Ministries of Finance, Defense, Justice, Interior, and Economy, as well as the Insurance Control Commission, the Special Investigation Commission at the Central Bank of Lebanon, the Directorate General of Internal Security Forces, Customs, the Public Prosecutor’s Office, the National Anti-Corruption Commission, the Beirut and Tripoli Bar Associations, and the Lebanese Association of Certified Public Accountants. Only five entities responded: the Insurance Control Commission, the National Anti-Corruption Commission, the Public Prosecutor’s Office, the Minister of Justice, and the Beirut Bar Association. However, their responses were vague, focusing on future intentions rather than the immediate actions FATF demanded, according to Euro-Med Human Rights Monitor director Mohammad Al-Mughaybir.

In April 2024, a second reminder was sent to the unresponsive institutions. Yet again, silence.

Deadlines crossed without action

By July 2024, the Special Investigation Commission informed the government that Lebanon’s deadline for implementing the required corrective measures had expired in mid-July. The commission urged continued pressure on the relevant authorities to avoid negative repercussions. In a tragicomic twist, it even urged officials to "take the matter seriously."

Facing this persistent inertia, the Prime Minister’s Office issued a final reminder on August 20, 2024, at the request of the Special Investigation Commission. FATF had requested additional clarifications by August 26. The outcome? Only five institutions responded within the deadline, three replied late, and four—including the Ministry of Interior, the Beirut and Tripoli Bar Associations, and the Accountants’ Association—chose not to respond at all.

Grey Listing Becomes Inevitable

By October 25, 2024, Lebanon’s listing on the gray list was a foregone conclusion. A ministerial committee was formed to oversee the implementation of corrective actions. However, in a further sign of complacency, the committee did not meet for an entire month. It was only on December 19, 2024, that a fourth letter was sent to the relevant institutions, instructing them to:

• Set a clear timeline for implementing the required measures.

• Appoint a designated contact person for official coordination.

By mid-January 2025, no responses had been received.

The requests were unreasonable

FATF’s requests were far from unmanageable. For instance, the Ministry of Justice was required to improve the commercial registry and verify economic beneficiaries. Instead, it responded by stating that it was seeking funding to digitize the registry—while notaries had not received any training on anti-money laundering since 2018.

The Ministry of Finance took eight months to comment on a simple amendment to tax procedures, proposing to incorporate it into the 2025 budget, in direct violation of Lebanon’s constitution and financial regulations.

Customs authorities waited nine months before finally stating that they would “enhance cooperation with judicial bodies.”

A Crisis beyond the Grey List

Now, with a two-year window to comply with FATF’s standards, Lebanon must rethink its approach. The grey list is not the only concern—its financial sector faces potential isolation from the global banking system, posing severe risks to the economy and human rights.

According to Sky for Research and Consulting and Euro-Med Human Rights Monitor, the Lebanese government must take clear, immediate steps to address FATF’s concerns. This includes ensuring that responsible institutions take accountability seriously and that reform efforts are no longer met with indifference.