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Lebanon

Retail_Trading_Status

Gray-Zone Unknown
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Analysis ID
#300
Version
Archived
Created
2025-06-26 09:20
Workflow Stage
Initial Research

Executive Summary

Lebanon's retail cryptocurrency trading status is a 'Gray-Zone,' characterized by the absence of specific legislation despite warnings from the Banque du Liban (BDL) and restrictions on financial institutions. The Capital Markets Authority (CMA) prohibits licensed financial institutions from engaging with cryptocurrencies, but no explicit ban exists for individuals. This ambiguity, coupled with economic crisis and banking restrictions, has fueled P2P crypto trading. The Special Investigation Commission (SIC) is scrutinizing crypto-related businesses, but a comprehensive regulatory framework is still lacking.

Key Pillars

The primary regulator is the Banque du Liban (BDL), which has issued warnings regarding cryptocurrencies. The Capital Markets Authority (CMA) prohibits licensed financial institutions from engaging with cryptocurrencies. There are general AML/KYC requirements for traditional financial institutions, and the Special Investigation Commission (SIC) is scrutinizing crypto-related businesses, but these are not enforced in the informal P2P market. There are no specific licensing or registration requirements for individuals trading cryptocurrency.

Landmark Laws

Announcement 30 issued by the Capital Markets Authority (CMA) on February 12, 2018, prohibits licensed financial institutions from issuing, marketing, or trading cryptocurrencies for their own account or on behalf of clients. Lebanon's Electronic Transactions and Personally Identifiable Data law includes a vague definition of 'digital and electronic money' but does not comprehensively address cryptocurrencies.

Considerations

Cryptocurrencies are viewed with caution due to concerns about unregulated transactions, lack of legal protection, volatility, and potential use in illicit activities. The BDL has issued warnings regarding the risks associated with 'virtual money'. For tax purposes, cryptocurrencies might be treated as 'intangible assets,' potentially subject to capital gains tax. Currency controls and limited access to traditional banking services have fueled the adoption of cryptocurrencies as a means to bypass restrictions.

Notes

The BDL issued initial warnings about cryptocurrencies as early as 2013. P2P trading is widespread, facilitated through OTC brokers, Telegram groups, and face-to-face transactions, operating without specific consumer protection, KYC/AML regulations, or tax guidelines. There are discussions about potential future regulations due to pressure from international bodies like the IMF. The BDL has mentioned plans to develop its own digital currency for domestic use, separate from regulating existing decentralized cryptocurrencies. The Lebanese Army Official Website indicates that regulations adopt only legal tenders/fiat currencies as an acceptable payment method.

Detailed Explanation

Lebanon's stance on retail cryptocurrency trading exists in a 'Gray-Zone'. While no outright ban exists for individuals, the regulatory environment lacks specific legislation. The Banque du Liban (BDL) has issued warnings about cryptocurrencies, beginning in 2013 when it cautioned the public about risks, and followed by more direct measures from the Capital Markets Authority (CMA). On February 12, 2018, the CMA issued Announcement 30, prohibiting licensed financial institutions from issuing, marketing, or trading cryptocurrencies for their own account or on behalf of clients. This effectively prevents banks and other regulated financial entities from engaging in the crypto market. Despite these restrictions on financial institutions, Lebanese laws do not explicitly prohibit individuals from owning, using, or trading cryptocurrencies. The Electronic Transactions and Personally Identifiable Data law includes a vague definition of 'digital and electronic money' but does not specifically address cryptocurrencies in a comprehensive manner, nor does it criminalize their individual use for trading. This ambiguity, coupled with the economic crisis where the local currency has lost significant value and access to traditional banking services is severely limited, has fueled a boom in an unregulated crypto market. Citizens have increasingly turned to cryptocurrencies, particularly stablecoins like USDT, as a store of value, a means of exchange, and a way to bypass capital controls and banking restrictions.

The P2P market thrives, often facilitated through informal channels like OTC brokers, Telegram groups, and face-to-face transactions. These activities operate without specific consumer protection measures, KYC/AML regulations tailored for crypto transactions, or clear tax guidelines. While the BDL's warnings persist, they have done little to curb adoption driven by economic necessity. The Special Investigation Commission (SIC), Lebanon's Financial Intelligence Unit, is reportedly scrutinizing crypto-related businesses, and there's an acknowledgment that AML/CFT measures need to address Virtual Asset Service Providers (VASPs), though a fully established framework is still lacking. General AML/KYC requirements exist for traditional financial institutions, but their application to the informal crypto P2P market is not enforced. Some sources mention that for tax purposes, cryptocurrencies might be treated as 'intangible assets,' with capital gains tax potentially applicable to individuals, though this also lacks specific, clear legislation. There are ongoing discussions regarding potential regulations, potentially influenced by pressure from international bodies like the IMF pushing for broader financial reforms. However, as of mid-2025, no comprehensive regulatory framework for cryptocurrencies has been implemented. The BDL has discussed plans to develop its own digital currency for domestic use, but this is separate from the regulation of existing decentralized cryptocurrencies. The Lebanese Army Official Website also acknowledges the lack of prohibition on individuals for owning/trading crypto, but regulations only adopt legal tenders as an acceptable payment method.

Summary Points

Retail Cryptocurrency Trading Status in Lebanon (as of 2025-06-26)

Overall Regulatory Status: Gray-Zone

  • No explicit ban on individuals buying, selling, or holding cryptocurrencies.
  • Lack of specific legislation addressing cryptocurrencies comprehensively.
  • Restrictions primarily target formal financial institutions.
  • Driven by economic crisis, P2P crypto adoption is high.

Key Regulatory Bodies and Their Roles:

  • Banque du Liban (BDL) - Central Bank:
    • Issued warnings about the risks of cryptocurrencies since 2013.
    • Prohibits banks from handling crypto transactions.
    • Planning to develop a central bank digital currency (CBDC), separate from regulating existing cryptocurrencies.
  • Capital Markets Authority (CMA):
    • Issued Announcement 30 (February 2018) prohibiting licensed financial institutions from issuing, marketing, or trading cryptocurrencies.
  • Special Investigation Commission (SIC) - Financial Intelligence Unit:
    • Scrutinizing crypto-related businesses.
    • Acknowledges the need for AML/CFT measures for Virtual Asset Service Providers (VASPs).

Important Legislation and Regulations:

  • Lack of Specific Cryptocurrency Legislation: No comprehensive regulatory framework exists.
  • Electronic Transactions and Personally Identifiable Data Law:
    • Includes a vague definition of "digital and electronic money."
    • Does not specifically address cryptocurrencies or criminalize their individual use.
  • CMA Announcement 30 (February 2018):
    • Prohibits licensed financial institutions from engaging with cryptocurrencies.
  • General AML/KYC Requirements:
    • Exist for traditional financial institutions.
    • Not effectively enforced in the informal crypto P2P market.

Requirements for Compliance:

  • For Financial Institutions:
    • Prohibited from issuing, marketing, or trading cryptocurrencies (CMA Announcement 30).
    • Subject to general AML/KYC requirements, but these are not crypto-specific.
  • For Individuals:
    • No specific KYC/AML regulations tailored for crypto transactions.
    • No clear tax guidelines.
    • Operating in an unregulated environment.

Notable Restrictions or Limitations:

  • Restrictions on Financial Institutions: Banks and other regulated entities cannot engage with the crypto market.
  • Lack of Consumer Protection: P2P market operates without specific consumer protection measures.
  • Absence of Clear Tax Guidelines: Tax treatment of cryptocurrencies is ambiguous, potentially treated as "intangible assets" subject to capital gains tax, but lacking specific legislation.
  • Limited Access to Formal Exchanges: BDL's ban on banks handling crypto transactions blocks formal exchanges.

Recent Developments or Changes:

  • Increased P2P Adoption: Driven by economic crisis and banking restrictions.
  • Discussions on Future Regulations: Partly due to pressure from international bodies like the IMF.
  • BDL's CBDC Plans: Separate from regulating existing decentralized cryptocurrencies.
  • SIC Scrutiny of VASPs: Acknowledgment of the need for AML/CFT measures for crypto-related businesses, but a fully established framework is still lacking.

Full Analysis Report

Report on the Current Status of Retail Cryptocurrency Trading in Lebanon

Date: 2025-06-26

Topic: Retail_Trading_Status

Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

1. Identified Current Status: Gray-Zone

2. Detailed Narrative Explanation:

Lebanon's stance on retail cryptocurrency trading is best described as a 'Gray-Zone'. While there isn't an outright ban on individuals buying, selling, or holding cryptocurrencies, the regulatory environment is characterized by a lack of specific legislation, coupled with warnings and restrictions targeting formal financial institutions. This has led to a situation where cryptocurrency adoption, particularly in peer-to-peer (P2P) markets, has surged due to the country's severe economic crisis and banking restrictions, while formal regulatory frameworks remain largely undeveloped.

Historically, the Banque du Liban (BDL), Lebanon's central bank, has issued warnings regarding cryptocurrencies. In 2013, the BDL was among the first in the Middle East to caution the public about the risks associated with "virtual money," citing concerns about unregulated transactions, lack of legal protection, volatility, and potential use in illicit activities. This was followed by a more direct measure in February 2018, when the Capital Markets Authority (CMA) issued Announcement 30, prohibiting licensed financial institutions from issuing, marketing, or trading cryptocurrencies for their own account or on behalf of clients. This prohibition effectively prevents banks and other regulated financial entities from engaging with the crypto market.

Despite these restrictions on financial institutions, Lebanese laws do not explicitly prohibit individuals from owning, using, or trading cryptocurrencies. The country's Electronic Transactions and Personally Identifiable Data law includes a vague definition of "digital and electronic money" but does not specifically address cryptocurrencies in a comprehensive manner, nor does it criminalize their individual use for trading. This legal ambiguity, combined with the dire economic situation where the local currency has lost significant value and access to traditional banking services is severely limited, has fueled a boom in an unregulated crypto market. Citizens have increasingly turned to cryptocurrencies, particularly stablecoins like USDT, as a store of value, a means of exchange, and a way to bypass capital controls and banking restrictions.

The P2P market thrives, often facilitated through informal channels like OTC brokers, Telegram groups, and face-to-face transactions. While these activities are widespread, they operate without specific consumer protection measures, KYC/AML (Know Your Customer/Anti-Money Laundering) regulations tailored for crypto transactions, or clear tax guidelines. The BDL's warnings persist, but they have done little to curb adoption driven by economic necessity.

There are discussions about potential future regulations, partly due to pressure from international bodies like the IMF for broader financial reforms. However, as of mid-2025, no comprehensive regulatory framework for cryptocurrencies has been implemented. The BDL has mentioned plans to develop its own digital currency for domestic use, but this is separate from the regulation of existing decentralized cryptocurrencies.

The Special Investigation Commission (SIC), Lebanon's Financial Intelligence Unit, is reportedly scrutinizing crypto-related businesses, and there's an acknowledgment that AML/CFT measures need to address Virtual Asset Service Providers (VASPs), though a fully established framework is still lacking. General AML/KYC requirements exist for traditional financial institutions, but their application to the informal crypto P2P market is not enforced. Some sources mention that for tax purposes, cryptocurrencies might be treated as "intangible assets," with capital gains tax potentially applicable to individuals, though this area also lacks specific, clear legislation.

In essence, individual Lebanese residents can and do engage in cryptocurrency trading, but they do so in an environment that lacks specific legal clarity, regulatory oversight, and formal investor protections. The official stance is restrictive towards the formal financial sector's involvement, but there's a practical tolerance, born out of economic crisis, for individual P2P crypto activities. This complex interplay of de facto allowance for individuals and a ban on formal institutions, all within an unregulated and high-risk environment, firmly places Lebanon's retail crypto trading status in a 'Gray-Zone'.

3. Specific, Relevant Text Excerpts:

  • Coinfomania (June 19, 2025): "Lebanon has a regulatory gray status regarding cryptocurrencies, which have neither been declared unlawful nor formally recognized. The Banque du Liban (BDL) prohibits its banks from handling any transactions related to cryptocurrency; however, the ban is not enforced against peer-to-peer trading. Most activities “informally” occur without licensing or consumer protections, usually facilitated through OTC markets or Telegram groups, where USDT hedges against a collapsed Lebanese pound."
  • Lebanese Army Official Website (Undated, referencing events up to 2020/2021): "Consequently, the Lebanese laws do not prohibit the ownership, use, trade of cryptocurrencies, but when it comes to their acceptance as a payment method, regulations only adopt legal tenders/fiat currencies." And, "However, in 2018, a partial ban has been imposed on financial institutions and exchanges. The ban prohibited them once again from issuing “e-money” and also the advertisement and exchange of “electronic currencies”. The latter warnings have sparked a mix up with the terms “e-money” and digital currencies in general and have put Lebanon in the legal grey zone of regulations."
  • bne IntelliNews (February 7, 2025): "This change in attitudes has not been matched by authorities, however, with the Central Bank of Lebanon, the first in 2013, warning locals about the risks of Bitcoin, while in February 2018, the Capital Market Authority (CMA) prohibited licensed financial institutions from issuing, marketing or trading in them."
  • Byblos Bank - Lebanon This Week (referencing CMA Announcement 30, February 12, 2018): "The CMA prohibited licensed financial institutions in Lebanon from issuing or marketing electronic money or cryptocurrencies, as well as from trading cryptocurrencies for their own account or on behalf of other parties."
  • CoinStats (June 19, 2025): "Lebanon maintains a contradictory stance on cryptocurrency—officially restrictive but practically permissive due to economic collapse. The Banque du Liban (BDL) enforces a strict banking ban on crypto transactions (since 2013), blocking formal exchanges. Yet, no KYC/AML rules apply to rampant P2P trading, creating an unregulated shadow market."
  • AInvest (June 19, 2025): "Lebanon's regulatory stance on cryptocurrencies remains ambiguous, with neither formal recognition nor outright prohibition. The Banque du Liban (BDL) has imposed a ban on banks handling cryptocurrency transactions, but this restriction does not apply to peer-to-peer trading."
  • Carnegie Endowment for International Peace (September 15, 2022): "In the case of Lebanon, while cryptocurrencies are illegal to trade in formally, there is no enforcement, and the community thrives while the state remains distracted by more pressing economic woes." (Note: The term "illegal to trade in formally" likely refers to the ban on financial institutions, as other sources clarify individuals are not prohibited).
  • Sanction Scanner (June 10, 2025): "Virtual Asset Service Providers (VASPs): While still in development, crypto-related businesses are a matter worth paying attention to. Although there is no fully established framework yet, the SIC and BDL are scrutinizing this matter."

4. Direct, Accessible URL Links to Sources:

Web Sources (13)

Sources discovered via web search grounding

Search queries used (7)
  • Lebanon cryptocurrency regulation retail trading
  • Banque du Liban cryptocurrency policy 2024 2025
  • Lebanon crypto trading laws for individuals
  • AML KYC cryptocurrency Lebanon
  • Official statements Lebanon retail crypto trading
  • Is cryptocurrency trading legal in Lebanon for residents?
  • Capital Markets Authority Lebanon cryptocurrency

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