LEBANON Trends and Developments Contributed by: Zeina Obeid and Lea Maalouf, Obeid & Partners
The Law includes a ten-year retroactive clause, which allows the competent authorities to access banking data and operations dating back to 2015. Articles 1 and 2 of the law were adopted in full, which grant the supervisory and regulatory authorities (specified under Article 7 of the Banking Secrecy Law), name- ly the Lebanese Central Bank, the Banking Control Commission and the National Deposit Guarantee Institution, the right to request all banking information without being required to specify a purpose for such request. These authorities are also entitled to con- duct named-account audits, allowing them to review individual bank accounts by name, trace deposit ori- gins and identify potential irregularities or suspicious transactions. Article 3 of the law, which amends Article 150 of the Currency and Credit Law, was adopted in an amended form. The final version of Article 3 authorises the Leba- nese Central Bank and the Banking Control Commis- sion to delegate access to banking information to third parties, such as independent auditing firms. Banks are therefore precluded from invoking banking secrecy to withhold or restrict access to such information, ensur- ing that authorised auditing firms can obtain the data or information indispensable for conducting thorough financial audits and investigations. This amendment was reportedly emphasised by the International Mon- etary Fund as crucial for the successful restructuring of Lebanon’s banking sector. Another amendment introduced to Article 3 removed the Ministry of Finance’s sole authority to regulate how the supervisory authorities may obtain the relevant banking information when required. This power lies with the Council of Minister, which will issue decrees upon the proposal of the Minister of Finance and after consulting the Central Bank. This aims to prevent unilateral decisions by the Minister of Finance and to ensure stronger institutional oversight. In short, this law breaks through long-standing walls of banking secrecy that have long obstructed finan- cial reform, particularly during Lebanon’s economic collapse since 2019. The inclusion of the ten-year retroactive provision enables the relevant authorities to investigate any suspicious financial activity that occurred during the years of crisis. Finally, the Prime
Minister noted that the law’s enactment “opens a new chapter” in the fight against tax evasion, money laun-
dering and financial corruption. Amendments to the Labour Law
Published in the Official Gazette on 16 May 2025, Law No 3 dated 9 May 2025 entered into force to introduce amendments to Articles 1, 2 and 12 of the Lebanese Labour Law of 23 September 1946, modernising Lebanon’s labour framework by explicitly introducing flexible work arrangements. These amendments are an overdue response to the realities of the modern workforce and rapid market changes, as reflected in the law’s explanatory memo- randum, which highlights the growing prevalence of remote, part-time and project-based work driven by technological change, rising production costs, and local and international competition. The reform aims to bring these new forms of employment under the protection of the Labour Law, ensuring social security coverage, enhancing competitiveness, and aligning Lebanon’s legislation with modern international labour standards. In what follows, we highlight the key provisions pro- vided under Law No 3, which amended Articles 1, 2 and 12 of the Lebanese Labour Law of 1946. Under the amended provision of Article 1, an “employ- er” is defined as any natural or legal person who employs an employee by virtue of a written or verbal employment agreement in exchange for remunera- tion, even when such remuneration is provided in kind or as share of profits. This expanded definition of an employer redefines the scope of the employment relationship to accommodate flexible work models. Under the amended provision of Article 2, an “employ- ee” is defined as every individual, including a minor, who performs work for remuneration for an employer under the conditions set out in Article 1, whether full- time, part-time or seasonal, and whether the work is performed on-site or remotely. The definition also applies when the employee uses their own tools or equipment to perform the job.
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