Licensing Hub

Lebanon

Lebanon has no crypto licensing regime — BDL Circular 6102 of 2018 bars licensed banks and financial institutions from any virtual-asset activity, leaving the sector in an unregulated grey zone. Payments operate under the Banque du Liban (BDL) Electronic Payment Services Provider (EPSP) regime, with Intermediate Decision No. 13791 of 9 January 2026 introducing capital, governance and AML/KYC tightening. Gambling is a strict state monopoly: Casino du Liban (land-based) and La Libanaise des Jeux (LLDJ, lotteries and sports betting) — no private licences are available.

Available licences

Crypto — none (legal grey zone; banks/CMA-licensed firms barred)

No crypto or VASP licence exists. The BDL has barred banks from crypto since 2013 and the CMA barred licensed firms from crypto activity in 2018; individual P2P USDT use is widespread but unregulated, with AML duties under Law No. 44 of 2015.

Electronic Payment Services Provider (EPSP) Licence (BDL + BCCL)

Authorisation under the new BDL framework — Basic Circular No. 69 (electronic payment services); long-standing Basic Decision No. 7548 of 30 March 2000 repealed and replaced by Intermediate Decision No. 13791 of 9 January 2026 (Intermediate Circular No. 750), with co-supervision by the Banking Control Commission of Lebanon.

Banking / Money-Changer Licence (BDL)

BDL licensing of banks under the Code of Money and Credit, plus the money-changer regime (Law regulating the money-changer profession; Basic Decision No. 7933 of 27 September 2001).

Gambling — Casino Licence (Casino du Liban — state monopoly)

Exclusive land-based casino licence held by Casino du Liban (Decree 6919 of 1995); not licensable privately.

Gambling — National Lottery (La Libanaise des Jeux — state monopoly)

LLDJ holds the sole national-lottery licence and operates PlayLebanon for online lottery; not licensable privately.

Gambling — Online Casino / Sportsbook — none (ISP-blocked)

No online-casino or sportsbook licensing regime; offshore sites blocked by Ministry of Justice direction since June 2013 (enforcement inconsistent).

Detailed overview

Lebanon at a glance

Lebanon has no crypto licensing regime — BDL Circular 6102 of 2018 bars licensed banks and financial institutions from any virtual-asset activity, leaving the sector in an unregulated grey zone. Payments operate under the Banque du Liban (BDL) Electronic Payment Services Provider (EPSP) regime, with Intermediate Decision No. 13791 of 9 January 2026 introducing capital, governance and AML/KYC tightening. Gambling is a strict state monopoly: Casino du Liban (land-based) and La Libanaise des Jeux (LLDJ, lotteries and sports betting) — no private licences are available.

Crypto regime — grey zone; banks barred:

  • No bespoke crypto/virtual-asset statute; not legal tender
  • BDL 2013 warning to banks and financial institutions; CMA 2018 prohibition on licensed firms issuing/marketing/trading cryptocurrency for own account or clients; formal financial channels closed to crypto
  • AML/CFT Law No. 44 of 2015 — Special Investigation Commission (SIC) as FIU; Basic Decision No. 7818 of 18 May 2001 AML/CFT framework for banking operations; FATF grey-list placement
  • Practical reality: P2P USDT activity is widespread (Lebanon among the top 20 countries globally for crypto transaction volume per capita); BDL is reportedly leaning toward a CBDC ("digital Lebanese lira"), with March 2026 ministerial discussions with Binance signalling possible future framework
  • Tax: no specific crypto tax; non-resident crypto-related sales taxed under the general withholding regime (e.g. 3.4%/8.5% under 2024 Budget Law amendments)
  • No KYC/AML obligations applied to retail P2P trading; high consumer-risk environment

Payments and e-money regime (BDL + BCCL):

  • Code of Money and Credit + Law No. 133 of 26 October 1999 (BDL general mission) — empower the BDL to develop and regulate payment means/systems
  • Basic Decision No. 7548 of 30 March 2000 (Electronic Financial and Banking Operations) — long-standing legacy framework; repealed and replaced 9 January 2026 by Intermediate Decision No. 13791 (Intermediate Circular No. 750) with a new EPSP regime
  • Basic Circular No. 69 — addressed to electronic payment services providers (and incorporating Basic Decision No. 13769 on banks/financial institutions/money changers)
  • Basic Decision No. 13810 of 28 April 2026 — caps the Merchant Discount Rate (MDR); in force 15 June 2026; aimed at promoting electronic payments and reducing the cash economy
  • AML framework: Basic Decision No. 7818 of 18 May 2001 (banking AML/CFT); Basic Decision No. 7933 of 27 September 2001 (money-changer profession); SIC oversight under Law No. 44/2015
  • Currency: LBP, no longer pegged; historical official LL 1,507.50/USD (Dec 1997 – Jan 2023) collapsed; current market ~LBP 89,500/USD

Gambling regime — state monopolies:

  • Casino du Liban — original exclusive gaming concession 29 July 1957; reopened 1996 after civil war; current monopoly under Decree 6919 of 1995; partly state-owned via Intra Investment (with BDL holding ~38% of Intra)
  • La Libanaise des Jeux (LLDJ) — national-lottery monopoly; operates online lottery via PlayLebanon
  • Online (non-lottery) gambling: Ministry of Justice ISP-blocked offshore sites from June 2013 (to protect the Casino du Liban monopoly); blocking is inconsistent; no licensing regime
  • Horse-racing pari-mutuel betting permitted at the Beirut hippodrome under specific decrees
  • Orient Queen cruise-ship offshore casino — destroyed in the Beirut port explosion of 4 August 2020
  • Penal Code criminalises operation of unauthorised gambling
  • Casino du Liban monopoly term reportedly running through ~2026 — a potential reform inflection point (not yet enacted)

Last verified: May 2026. Reference rate: USD 1 = LBP 89,500 (1 LBP ≈ USD 0.0000112). The Lebanese pound was fixed at LL 1,507.50/USD from December 1997 to January 2023 and devalued >95% during the post-2019 crisis; multiple official rates (BDL Sayrafa, Sabra unified rate) have broadly converged; re-verify against the prevailing market rate for any filing.

Lebanon is a financial-collapse jurisdiction with two closed verticals (gambling = state monopolies; crypto = grey zone with banks barred) and one constrained route — BDL/BCCL-supervised payments/e-money under a newly overhauled (9 January 2026) Electronic Payment Services Providers framework — in a high-inflation, multi-rate-history, FATF-grey-listed, sanctions-exposed environment.

Is there a crypto licence in Lebanon?

No. There is no crypto or VASP licence in Lebanon. The BDL barred banks from crypto in 2013 and the CMA barred licensed firms in 2018; individual P2P use is widespread but unregulated. AML/CFT Law No. 44 of 2015 applies via the Special Investigation Commission; Lebanon is on the FATF grey list.

The legal foundation:

  • No bespoke crypto statute; not legal tender
  • BDL 2013 warning + CMA 2018 prohibition — formal financial channels closed
  • AML/CFT Law No. 44 of 2015 — SIC oversight; Basic Decision No. 7818 of 18 May 2001 (banking AML)
  • Possible future framework — BDL signalling a CBDC and engaging with international exchanges (March 2026 ministerial meeting with Binance)
  • Sanctions exposure (paramount): US OFAC Hezbollah/SDGT designations and broader financial-sector scrutiny create acute compliance risk for any crypto activity associated with Lebanon

Structure:

  • No positive VASP/exchange/custody licence; banks and CMA-licensed firms cannot service crypto
  • Activity is informal P2P/OTC/Telegram-mediated USDT — outside consumer/AML protection
  • No specific crypto tax; non-resident-related crypto income captured by general withholding (e.g. 2024 Budget Law amendments)

Operational reality:

  • A high-risk, high-adoption-by-necessity environment — not a viable jurisdiction for licensed crypto activity
  • Reform is signalled (BDL CBDC; Binance engagement) but unenacted and timeline-uncertain
  • Independent sanctions/AML screening and direct verification with the BDL/SIC are essential before any planning

Payments & E-money (BDL + BCCL — overhauled regime)

Best for payment service providers prepared to license under the new BDL Electronic Payment Services Providers framework in a financial-collapse, FATF-grey-listed environment.

What it is: BDL authorisation under the Code of Money and Credit, Law No. 133 of 26 October 1999, and the newly overhauled EPSP framework — Basic Circular No. 69; Basic Decision No. 7548 of 30 March 2000 (repealed) replaced by Intermediate Decision No. 13791 of 9 January 2026 (Intermediate Circular No. 750); co-supervised with the BCCL.

Who it suits: Domestic payment service providers and (selectively) international groups able to operate under acute country/sanctions risk; banks, money-changers and financial institutions extending electronic-payment services.

Covers: Electronic financial and banking operations; EPSP licensing; merchant discount rate (capped under Basic Decision No. 13810 of 28 April 2026, in force 15 June 2026); banking operations under the Code of Money and Credit; money-changer activity (Basic Decision No. 7933 of 27 September 2001).

Operational requirement: Lebanese entity; BDL authorisation (often with BCCL approval); customer-risk classification (high/medium/low); AML/CFT compliance under Law No. 44/2015 + Basic Decision No. 7818 of 18 May 2001; technical/safety/compliance measures per the new framework; sanctions-screening; cash-economy reduction objectives.

Headline figures

  • Primary instruments: Code of Money and Credit (Arts 70 et seq.); Law No. 133 of 26 October 1999 (BDL general mission); Basic Circular No. 69; Intermediate Decision No. 13791 of 9 January 2026 (Intermediate Circular No. 750; repealing Basic Decision No. 7548 of 30 March 2000); Basic Decision No. 13810 of 28 April 2026 (MDR cap; in force 15 June 2026); Basic Decision No. 7818 of 18 May 2001 (AML/CFT); Basic Decision No. 7933 of 27 September 2001 (money changers); AML Law No. 44 of 2015
  • Regulators: BDL; BCCL; SIC (AML)
  • Currency: LBP, no longer pegged; historical LL 1,507.50/USD peg (Dec 1997–Jan 2023) collapsed; current market ~LBP 89,500/USD

Is there a gambling licence in Lebanon?

Partly — only state monopolies. Casino du Liban holds the country's exclusive land-based casino licence (Decree 6919 of 1995) and La Libanaise des Jeux operates the national lottery (PlayLebanon online). There is no private licensing route. Offshore online sites have been ISP-blocked since June 2013.

The legal foundation:

  • Casino du Liban — exclusive gaming concession dating to 29 July 1957; current monopoly under Decree 6919 of 1995; partly state-owned via Intra Investment (BDL holding ~38% of Intra)
  • La Libanaise des Jeux (LLDJ) — state national-lottery monopoly; operates PlayLebanon online lottery
  • Ministry of Justice direction (June 2013) — ISPs to block offshore gambling sites (to protect the casino monopoly); enforcement inconsistent
  • Penal Code criminalises unauthorised gambling; horse-racing pari-mutuel betting permitted under specific decrees (Beirut hippodrome)

Structure:

  • Casino: single, exclusive land-based operator; ~60 tables / ~400 slots; no sports betting offered; bet levels from LBP 50,000 to LBP 10,000,000 per room/table
  • Lottery: LLDJ monopoly via PlayLebanon (online ticket sales); other forms of online gambling not licensable
  • Online (non-lottery): no domestic licensing; offshore casinos/sportsbooks ISP-blocked since June 2013; VPN access common, no documented prosecutions of players
  • Reform inflection: Casino du Liban monopoly term reportedly running through ~2026 — potential opening to broader licensing or extension; not yet enacted
  • Minimum gambling age 21 (Casino du Liban) — reported and consistent with the venue's own rules

Gambling — Casino du Liban / LLDJ (state monopolies)

Best for engagement with the Casino du Liban / LLDJ state structures; not for private casino, sportsbook or online operators.

What it is: State monopolies — Casino du Liban (exclusive land-based casino) under Decree 6919 of 1995 and LLDJ (national lottery, PlayLebanon online); no private licensing route.

Who it suits: No private operator — engagement is via the state monopolies and the relevant ministries. Suppliers/vendors may have niche scope through the existing operators.

Covers: Land-based casino at Casino du Liban; national lottery (incl. PlayLebanon online); horse-racing pari-mutuel betting under specific decrees; no private online casino/sportsbook regime.

Operational requirement: Not applicable for private operators; offshore targeting subject to ISP-blocking and AML/sanctions risks.

Headline figures

  • Statute/decree: Decree 6919 of 1995 (Casino du Liban monopoly); Penal Code; Ministry of Justice 2013 ISP-block direction
  • Casino: Casino du Liban (single national operator; partly state-owned via Intra Investment / BDL ~38%); ~60 tables / ~400 slots
  • Lottery: LLDJ + PlayLebanon online (state monopoly)
  • Online (non-lottery): unregulated/grey; ISP-blocked since June 2013; no licensing route
  • Reform outlook: Casino du Liban monopoly term reportedly through ~2026 — potential inflection (not enacted)

Costs and timelines at a glance

  • Crypto: no bespoke law; grey zone; BDL 2013 ban on banks; CMA 2018 prohibition on licensed firms; AML Law No. 44/2015 + Basic Decision No. 7818/2001; SIC FIU; FATF grey list; possible CBDC; March 2026 BDL/Binance discussions
  • Payments primary instruments: Code of Money and Credit; Law No. 133 of 26 October 1999; Basic Circular No. 69; Intermediate Decision No. 13791 of 9 January 2026 (Intermediate Circular No. 750) repealing Basic Decision No. 7548 of 30 March 2000; Basic Decision No. 13810 of 28 April 2026 (MDR cap; in force 15 June 2026); Basic Decision No. 7818 of 18 May 2001 (AML); Basic Decision No. 7933 of 27 September 2001 (money changers)
  • Payments regulators: BDL + BCCL; SIC for AML
  • Gambling: state monopolies — Casino du Liban (Decree 6919/1995) + LLDJ (national lottery/PlayLebanon); horse-racing pari-mutuel under specific decrees; offshore online ISP-blocked since June 2013; Casino du Liban monopoly term reportedly through ~2026
  • Currency: LBP; historical LL 1,507.50/USD official peg (Dec 1997–Jan 2023) collapsed
  • FX: USD 1 = LBP 89,500 (1 LBP ≈ USD 0.0000112)

Who Lebanon suits and who it does not

Suitable for

  • (Severely constrained) domestic payment service providers prepared to license under the new BDL/BCCL EPSP framework (Intermediate Decision No. 13791 of 9 January 2026) and operate within strict AML/CFT, MDR-cap and sanctions-screening constraints
  • Banks, money-changers and financial institutions extending electronic-payment services into a cash-heavy, dollarized economy with strong risk appetite and country-risk capacity
  • Groups with deep independent legal/AML/sanctions counsel able to monitor a possible BDL CBDC or future crypto framework — and to verify status directly with the BDL/CMA/SIC
  • Suppliers/vendors engaging with the Casino du Liban / LLDJ state monopolies under appropriate Lebanese government processes

Not suitable for

  • Any crypto/VASP business — there is no licence; banks and CMA-licensed firms are barred; sanctions and FATF-grey-list exposure make formal entry impractical
  • Private casino, sportsbook, online-casino or lottery operators — all gambling outside the state monopolies is unlicensable; offshore online has been ISP-blocked since June 2013
  • Payment/fintech firms needing stable banking, predictable FX, a credible single official rate, or operations untouched by sanctions/AML scrutiny
  • Operators sensitive to active financial collapse, multi-rate-history currency, FATF grey-listing, and US/EU sanctions adjacency
  • Anyone expecting near-term broad liberalisation of crypto or gambling — reform is signalled but unenacted and timeline-uncertain; the Casino du Liban monopoly may extend rather than open

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