On May 23rd, 2025, the Central Bank issued intermediate circular 735 (Decision 13718) to amend some of the points in the basic decision 7548 concerning the banking and financial operations of e-wallets providers.
First, the circular states that the institutions that provides e-wallets should start its operations as per the submitted business plan within a period of 6 months from the issuance of the license; otherwise the Central Bank’s central council will revoke the license. However, in case of exceptional or urgent situations, the Central Bank may extend the period for an additional 6 months after sending a request to the central council justifying the reason. In case the institution stopped its operations for a period of 6 months, the central council will withdraw its license. As for the existing e-wallet providers, they have a deadline until August 25th, 2025 to abide with the business plan they provided especially concerning the number of users and forecasted operations or its license will be withdrawn by the central council of the Central Bank.
Second, the institutions have to open special and independent bank accounts in order to deposit the proceeds of e-wallets and insure that it has at all time at least 100% of e-wallets amounts in their banks accounts and/or cash at its premises, and/or with parties they deal with such as banks, money transfer companies, and others. These amounts should be separated from their own funds. These institutions are obliged to submit monthly statements signed by the General Manager to the Central Bank and Banking Control Commission of Lebanon (BCCL) showing the details of the amounts of money deposited in the independent accounts and cash money and whether it is abiding with the percentage specified above.
Third, total fund movements on e-wallets should not exceed on monthly basis:
The e-wallets fund movements are non-revolving in the same month. The Central Bank may exceptionally accept to exceed the $30,000 ceiling for corporations as per justified requests submitted by these corporations to the Central Bank.
Fourth, the institutions need to implement suitable information systems including system controls in order to abide with article 3 of the basic decision 7548. These systems should enforce institutions not to exceed the ceilings specified above and prevent overrides in order to avoid being penalized as per article 24. The penalty might be a warning, restrict institutions from performing some operations or put limits in it, prevent the chairman and/or board of directors, and/or general managers from performing operations related to this decision either permanently or temporarily, or withdraw its license issued by the Central Bank. In addition, the central council can impose a LBP 1 billion fine on the institutions violating this circular or criminally prosecute them.
Fifth, these organizations should implement effective and permanent audit to make sure that their clients are not performing activity not complying with the terms and conditions of the Central Bank and not doing any financial activity not licensed by the Central Bank such as exchange operations or trading digital currencies. Violating organizations will be penalized as per article 24 of this decision.
Sixth, these firms should sign contracts with known and licensed insurance companies that reinsure its operations with highly rated international reinsurers. The goal of this contract is to insure all companies’ operations and the risks they might face including and not limited to theft, breach of trust, electronic piracy. Additionally, insurance covers risks resulting from institutions’ board members, directors and employees’ activities including and not limited to fraud, breach of trust, and misuse. Institutions must submit on an annual basis a copy of insurance contracts to the Central Bank and BCCL. Also, the insurance contracts should be reviewed annually to reflect updated situation in case there are developments in institutions’ expansion and volume of operations. Non-compliant institutions will face penalties as stipulated in article 24 of this decision.
Furthermore, the decision mandates the institutions that provide e-wallet services a maximum of three-day period to transfer the value of the receipts, commissions and amounts collected from its users to the concerned parties (ministries, public and private entities, syndicates, telecommunication companies, landline operators, etc…). Non-compliant institutions will face penalties as stipulated in article 24 of this decision.
Lastly, the Central Bank postponed until further notice applications submission for acquiring a license to provide e-wallets and online money transfers services.
The circular is effective upon issuance and to be published in the official gazette.