A circular issued by Lebanon’s Justice Minister Adel Nassar, now in force, has placed notaries public on the front line of the country’s fight against money laundering, requiring them to verify the source of funds and the identities of parties involved in sales contracts, purchase agreements, and powers of attorney.
The measure, which took effect at the start of this year, is aimed at curbing the cash economy and boosting transparency in line with international standards on combating money laundering and terrorism financing.
It has also reignited and intensified a political campaign by Hezbollah, which says the move tightens pressure on the party and its support base.
The law requires notaries to carry out several key tasks, notably verifying that parties to transactions are not listed on national or international sanctions lists, refraining from completing any transaction if that proves otherwise, and notifying the Justice Ministry and the Special Investigation Commission at Lebanon’s central bank.
The circular also stresses the need to verify the source of funds and to state it explicitly in the transaction or contract, and to refrain from drafting or certifying any document if it is not possible to establish the identity of the beneficial owner.
The measure targets all those listed on the US sanctions lists and mainly affects Hezbollah, its officials, and its institutions. The party considers the step part of what it describes as a US blockade against it and says it strips citizens of their civil rights.
Hezbollah Secretary General Sheikh Naim Qassem said the justice minister was “not a judicial police officer for America and Israel” and should stop preventing citizens from completing their transactions.
Qassem asked: “Has Lebanon turned into a prison for its citizens under American management? Is the justice minister or the governor of the central bank an employee of the American administration in Lebanon’s American prison?”
The circular has moved beyond political and legal objections raised against it. The justice minister said all notaries had complied with its requirements since implementation began at the start of the year, noting ongoing coordination to address practical issues that emerged during execution.
Nassar told Asharq Al-Awsat that meetings had been held between representatives of notaries and the Special Investigation Commission at the central bank, during which mechanisms and standards were clarified.
He said an office within the commission had also been designated to respond to notaries’ inquiries and provide necessary information while transactions are being processed.
The minister said the measures put Lebanon on a path of transparency and would positively affect the Financial Action Task Force's view of the country’s situation.
He described the circular as part of a package of steps adopted by the state to exit the FATF gray list or at least avoid being placed on the blocklist, adding that the measure was a key factor in curbing money laundering without infringing on the civil rights of sellers or buyers.
Hezbollah continued its attack on those involved in the decision.
MP Ali Fayyad said in a speech to parliament during budget discussions that the justice minister, the foreign minister, and the central bank governor were “carrying out a systematic strangulation of our community, sheltering behind the law while overstepping it.”
“We are a people subjected to daily assassination by Israel, and there are those inside who are pouncing on us,” he said.
A number of those affected have filed an appeal before the Shura State Council seeking to annul the circular, arguing that its provisions are not practically applicable and that they impose responsibilities on notaries that exceed their legal authority.
The appellants warned that the circular could turn notaries into quasi-judicial police officers and entangle them in political and security matters unrelated to their work.
Despite objections that have reached the level of accusing anyone who complies with international anti-money laundering standards of treason, the justice minister said there would be no retreat from the circular.
He stressed that it meets international compliance requirements while providing notaries with a legal protective framework that shields them from future accountability if they adhere to the specified procedures.
Some notaries acknowledged that implementation has entered a practical phase, even if conditions and standards sometimes differ from one notary to another. One pointed to inconsistencies between notaries’ procedures and those of the land registry in property registration.
He told Asharq Al-Awsat that verifying the source of funds has become an established procedure, carried out in coordination with the Special Investigation Commission at the central bank.
“There is no doubt that many of the ambiguities that accompanied the issuance of the circular are gradually becoming clearer with implementation,” he said.
