Lebanese Canadian Bank Laundering Case

2007–2015$329 million wired (alleged); $102 million forfeited

What did US authorities allege about Lebanese Canadian Bank, and how did the case end?

On 10 February 2011 the US Treasury's FinCEN found Lebanese Canadian Bank (LCB) of primary money laundering concern, citing drug proceeds, exchange houses and used-car exports to West Africa. LCB lost its licence in September 2011. In December 2011 prosecutors sued for forfeiture, and in June 2013 LCB agreed to forfeit $102 million. The allegations, including those about Hizballah, are from US authorities, not court findings.

As of November 2026: As of November 2026 the 2013 settlement is the last resolution of the claims against LCB found. The SDNY said the forfeiture action continued against other alleged participants in June 2013; its later outcome was not reviewed. The December 2011 press release, the original and amended complaints and the settlement order were not opened, so details of the complaints rest on the SDNY's June 2013 release, and whether LCB admitted or denied the allegations is not known from the sources reviewed. The US indictment of Ayman Joumaa and its outcome were not reviewed. The Hizballah links are allegations by US authorities and no court finding on them was found. The date of the Section 311 announcement is 10 February 2011 in the Treasury fact sheet and the SDNY release, while the finding itself is dated 9 February and was published on 17 February. Private lawsuits against SGBL and others were not reviewed.

What happened?

Lebanese Canadian Bank SAL (LCB) was a Beirut bank with 35 branches in Lebanon and a representative office in Montreal. FinCEN, the US Treasury’s financial crimes bureau, said it was the eighth largest Lebanese bank by assets, with more than $5 billion in 2009.

On 10 February 2011 FinCEN announced that LCB was a financial institution of primary money laundering concern, using Section 311 of the USA PATRIOT Act. It also proposed barring US institutions from holding correspondent accounts for the bank. In December 2011 federal prosecutors in Manhattan sued LCB and two Lebanese exchange houses for civil forfeiture. LCB lost its licence in September 2011 and settled the US claims in June 2013. Everything below about the scheme is what US authorities alleged.

Which techniques did it use?

FinCEN’s finding described a network linked to Ayman Joumaa, whom the US Treasury had designated as a narcotics trafficker in January 2011. It said the network moved cocaine from South America to Europe and the Middle East via West Africa, then laundered the cash.

  • Cash into exchange houses. Bulk cash was deposited at Lebanese exchange houses (see currency exchanges and bulk cash smuggling). The exchange houses then deposited it into their LCB accounts.
  • Wires through US accounts. The exchange houses told LCB to wire dollars through its US correspondent accounts to US used-car dealers.
  • Cars as the vehicle. The dealers bought vehicles, which were shipped to West Africa, and the sale proceeds were returned to Lebanon. This is trade-based money laundering.
  • A second channel. FinCEN said other funds paid Asian suppliers of consumer goods that were sold in Latin America, then laundered through the Black Market Peso Exchange.

The SDNY’s amended complaint alleged at least $329 million was wired to the United States for the used cars from about January 2007 to early 2011, mostly from LCB and two exchange houses. It said the cash from the cars and drug proceeds went to Lebanon through “Hizballah-controlled money laundering channels.” FinCEN went further on the bank’s own role, saying it had reason to believe LCB managers were complicit. Both are allegations.

How was it found?

Several US agencies worked in sequence. The Treasury’s sanctions office (OFAC) designated Joumaa’s network and three Lebanese exchange houses in January 2011. FinCEN then published its Section 311 finding in February 2011. A DEA task force investigated for the SDNY case. FinCEN’s finding gave some of the data it relied on. By value, 94% of the transfers tied to the exchange houses since January 2006 that named a Lebanese originating bank came from LCB. A review of dollar wires with the two main exchange houses from 2004 to 2008 found 72% sent by one of them through LCB.

What was the outcome?

  • FinCEN, February 2011. The finding took effect immediately. A proposed rule would have barred US institutions from opening or keeping correspondent accounts for LCB. FinCEN withdrew it in 2015 because LCB no longer existed.
  • Licence and sale. Lebanon’s central bank revoked LCB’s licence on 20 September 2011. Its former shareholders sold its assets and liabilities to SGBL. FinCEN said its withdrawal did not acknowledge any remedial measure by LCB.
  • Civil forfeiture, 2011 to 2013. Prosecutors filed on 15 December 2011. In August 2012 they seized $150 million from a US correspondent account of Banque Libano-Française, held as a substitute for an escrow that SGBL had set up in Lebanon for the purchase.
  • Settlement, 25 June 2013. LCB forfeited $102 million. To settle SGBL’s $90 million claim on the funds, LCB paid it another $12 million, and SGBL received the remaining $48 million. A June 2013 order made Hassan Ayash Exchange forfeit more than $720,000.
  • Other exchange houses. In April 2013 FinCEN found Kassem Rmeiti & Co. For Exchange and Halawi Exchange Co. of primary money laundering concern. It said Rmeiti sent at least $27 million to US car dealers from 2008 to 2011 and used LCB accounts, and that Halawi sent used-car wires from 2008 to 2011, many through LCB.

What were the warning signs?

These are the indicators FinCEN and the SDNY described, as investigators would read them.

  • Heavy bulk cash deposits by exchange houses, which serve customers that are hard to check.
  • Concentration. One bank carrying most of the dollar wires for a group of exchange houses.
  • Oddly structured wires to many US used-car dealers, some linked to drug investigations.
  • A trade flow that does not fit the money. Dollars sent to US car dealers by Lebanese exchange houses, with the vehicles shipped to West Africa and the proceeds returned to Lebanon.
  • Insider ties. Branch managers who were relatives of network members, and an exchange house in the same building as a key branch, according to FinCEN.
  • Weak customer checks. FinCEN cited inadequate due diligence on high-risk customers such as exchange houses and failure to control cash and cross-border wires.

What changed afterwards?

LCB ceased to exist within months of the FinCEN finding, before any settlement. FinCEN’s April 2013 findings said the alleged network adapted after the US actions by moving to other exchange houses, and acted against those houses too. The 2013 settlement left claims open against other alleged participants.

The case is a standard example of how the US uses the dollar to reach a foreign bank: a Section 311 finding, an asset seizure from correspondent accounts, and a forfeiture suit. Compare the settlements at HSBC and Wachovia, a later 311 case at ABLV Bank, and see transaction monitoring and know your customer.

Frequently asked questions

Was Lebanese Canadian Bank convicted of money laundering?

No criminal conviction was found. The 2011 FinCEN finding was an administrative step, and the SDNY case was a civil forfeiture action. It ended for LCB in a June 2013 settlement order in which the bank forfeited $102 million. The sources reviewed do not report an admission of liability, and all the claims about the scheme were allegations by US authorities.

Did the court find that Hizballah was behind the scheme?

No court finding on this was located. FinCEN said it had reason to believe Hizballah derived financial support from the criminal activities of the network, and the SDNY complaint alleged that funds went through Hizballah-controlled channels. Both statements are US government allegations. Hizballah is a US-designated terrorist organisation and a political party in Lebanon.

Why was a bank in Beirut affected by US rules?

LCB held correspondent accounts at US banks to move US dollars. Section 311 lets the US Treasury find a foreign bank of primary money laundering concern and then bar US institutions from dealing with it. FinCEN proposed that step for LCB, and the bank also faced a US forfeiture action over dollars passing through US accounts.

Does Lebanese Canadian Bank still exist?

No. Lebanon's central bank revoked its banking licence on 20 September 2011, and its former shareholders sold its assets and liabilities to SGBL. FinCEN stated in 2015 that LCB no longer existed as a foreign financial institution, and withdrew the proposed rule against it. Customer and staff outcomes were not covered in the sources reviewed.

Techniques used in this case

  • Trade based money laundering (TBML) · Moving value across borders through trade paperwork: over- or under-invoicing goods, double-invoicing shipments, or invoicing shipments that never happened.
  • Currency exchanges and MSBs · Using currency exchange houses, remitters, and other money services businesses to convert and send cash abroad, either through complicit operators or through firms whose controls are too weak to notice.
  • Bulk cash smuggling · Physically carrying, shipping, or driving criminal cash across a border so it can be deposited or spent where it draws less attention and leaves no record in transit.
  • Correspondent banking and wire layering · Small or weakly supervised banks reach the dollar system through accounts at big correspondent banks, and rapid wires through many accounts and countries bury the origin of the money.

Related cases

  • HSBC and the Sinaloa cartel · Weak controls let Mexican and Colombian cartels move at least $881 million in drug money through HSBC, which paid a then-record $1.92 billion in 2012 to defer prosecution.
  • Wachovia · In 2010 Wachovia admitted it failed to monitor more than US$420 billion in transactions with Mexican exchange houses and paid US$160 million, a record Bank Secrecy Act penalty at the time.
  • ABLV Bank and FinCEN Section 311 · A 2018 US Treasury finding against Latvia's ABLV Bank triggered a deposit run, an ECB failure ruling and liquidation, and was withdrawn in 2024.
  • TD Bank · The first US bank to plead guilty to money laundering conspiracy paid about US$3.09 billion after three networks moved over US$670 million through its accounts.

Glossary

Sources

  1. Finding That the Lebanese Canadian Bank SAL Is a Financial Institution of Primary Money Laundering Concern (76 FR 9403) (FinCEN, US Department of the Treasury (Federal Register), February 17, 2011).
  2. Fact Sheet: Overview of Section 311 of the USA PATRIOT Act (US Department of the Treasury, February 10, 2011).
  3. Manhattan U.S. Attorney Announces $102 Million Settlement Of Civil Forfeiture And Money Laundering Claims Against Lebanese Canadian Bank (US Attorney's Office, Southern District of New York, June 25, 2013).
  4. Notice of Finding That Kassem Rmeiti & Co. For Exchange Is a Financial Institution of Primary Money Laundering Concern (FR Doc. 2013-09783) (FinCEN, US Department of the Treasury (Federal Register), April 25, 2013).
  5. Notice of Finding That Halawi Exchange Co. Is a Financial Institution of Primary Money Laundering Concern (FR Doc. 2013-09785) (FinCEN, US Department of the Treasury (Federal Register), April 25, 2013).
  6. Withdrawal of the Proposed Rulemaking against Lebanese Canadian Bank SAL (FR Doc. 2015-24912) (FinCEN, US Department of the Treasury, September 28, 2015).