Lebanon has no crypto licence, and the central bank bars banks and payment providers from virtual assets

No crypto licensing regime was found in Lebanon. Since 9 January 2026, central bank rules bar banks and payment providers from issuing or dealing in virtual assets unless the Banque du Liban authorises it. Lebanon remains under FATF increased monitoring. None of the legal texts reviewed mentions crypto ATMs.

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No crypto licensing regime was found in Lebanon.^6,8 Since 9 January 2026, central bank rules bar banks and payment providers from issuing or dealing in virtual assets unless the Banque du Liban authorises it.^1,2 Lebanon remains under FATF increased monitoring.³ None of the legal texts reviewed mentions crypto ATMs.

Last updated: October 2026

Regulatory Framework

Lebanon has no crypto-specific law in the texts reviewed. The rules that touch crypto come from the Banque du Liban (BDL), which supervises banks and electronic payment providers, and from the Capital Markets Authority (CMA), which issued the warnings described below. A 2026 commentary reports that the BDL circulars govern the institutions it supervises and do not generally prohibit individuals from holding or transferring stablecoins.⁸ That is the author's reading and was not matched to a BDL text.

Banque du Liban Rules

BDL Basic Decision No. 13790 of 9 January 2026 sets a licensing regime for electronic payment service providers. Article 17(3) states that the institution is prohibited from issuing, dealing or facilitating dealings in virtual assets in any way, unless authorised by regulations issued by the BDL. Article 1(12) defines a virtual asset as a digital representation of a value that is not issued by a central bank or a public authority, which may be accepted as a means of exchange and transferred, stored or traded electronically.¹

The BDL page for Basic Decision No. 7548 says its articles were repealed by Intermediate Decision No. 13791 of 9 January 2026 and replaced with new text. Article 10 of that page bars banks and financial institutions from issuing, dealing or facilitating dealings in virtual assets in any way, with the same exception for activity the BDL authorises. The page does not define the term and refers to the definition in Decision No. 13790.²

Article 2(1) of Decision No. 13790 requires prior BDL approval for providers in licence Categories A to E, and Article 4(10) bars any activity before the licence is obtained. Article 40 allows fines of up to LBP 1,500,000,000 per violation, and Article 42 states that a violation is an offence under Article 770 of the Penal Code.¹ The commentary cited above says that, as of July 2026, the published circulars do not appear to contain rules for authorising stablecoins.⁸

BDL Basic Decision No. 13819 of 21 May 2026 on finance companies (Article 7, item 3) and Basic Decision No. 13837 of 18 August 2026 on exchange institutions (Article 8, First, item 4) carry the same prohibition, with the same exception for regulations issued by the BDL.^9,10 Decision No. 13837 takes effect on publication in the Official Gazette, and the publication date was not found.¹⁰ Its licence categories cover currency and precious metal trading, acting as an agent of an electronic payment provider, marketing prepaid cards, cross-border cash transport and informal money transfer, and the list does not include virtual asset services. Article 5 requires at least two thirds Lebanese ownership of a joint-stock company and Lebanese management, and Article 13 requires a feasibility study covering at least three years.¹⁰

Basic Decision No. 13769 of 14 November 2025 sets KYC rules for cash transactions of USD 1,000 or more at finance companies, specialised lending entities, exchange institutions and electronic payment providers, with record keeping of at least five years. It does not mention virtual assets or ATMs. Intermediate Decision No. 13815 of 4 May 2026 amends it from 30 June 2026.¹¹

Capital Markets Authority

A secondary report says the CMA warned the public on 6 November 2021 against dealing in cryptocurrencies, virtual currencies, digital currencies and electronic money, and warned registered financial service providers against offering virtual currency services. It also says the CMA said such dealings are not covered by any legislative framework. The same report says CMA Announcement 30, published in the Official Gazette on 12 February 2018, prohibited licensed financial institutions from issuing or marketing e-money or cryptocurrencies or trading them. Neither text was read at the source.⁶

FATF Listing

The FATF page of 19 June 2026 lists Lebanon among the jurisdictions under increased monitoring and says Lebanon should continue implementing its action plan. The page gives Lebanon's high-level political commitment as October 2024 and does not state the listing date. Al Jazeera reported that the FATF added Lebanon to the grey list on 25 October 2024.^3,5 The ten action items on the page do not mention virtual assets or virtual asset service providers.³ The 2023 mutual evaluation page rates Lebanon partially compliant on Recommendation 15, new technologies.⁴ Paragraph 118 of the report states that virtual asset services and their providers are among the prohibited activities in Lebanon, and that such activity outside the formal financial sector was limited and not important for money laundering risk. The paragraph does not name the legal text behind the prohibition.¹²

Government Talks

A news report dated 1 March 2026 says Lebanon's Minister of Economy, Amer Bisat, met Binance executives that week and said crypto trading among Lebanese citizens is significant and growing. The report says an inter-ministerial committee has begun groundwork for a digital asset framework, with no draft text or details, and that a BDL official called for a framework modelled on MiCA. It describes that as a proposal and not a Lebanese rule.⁷

Crypto ATMs

None of the legal texts reviewed mentions crypto ATMs. Decision No. 13790 allows only licence Categories A, B and C to install ATMs, for funds withdrawal and deposit and after prior BDL approval, and it does not mention kiosks.¹ The decision regulates electronic payment providers, and no source reviewed says whether a cash-for-crypto machine, or an operator that is neither a bank nor a payment provider, falls under the BDL or CMA texts. No licensing route for a machine operator was found.

A news report of 8 November 2021 says BitBeirut, which it describes as distributing the machines, installed two crypto ATMs, one at an exchange shop in Hamra and one at Cash Plus in Dawra.¹³ The BitBeirut website describes the company as a technology provider for crypto ATMs, lists no machine locations ("coming soon"), and names no licence or regulator. It says purchases up to USD 100 need no registration, purchases from USD 100 to 250 need a phone number and name, and larger ones need an ID and a selfie.¹⁴ Those figures are the company's own claims. A September 2022 Carnegie article describes two machines in Hamra that only sell crypto for cash, and says trading crypto is formally illegal but not enforced.¹⁵ A November 2022 CNBC report says Lebanon has six machines, one in Aamchit and five in Beirut, citing coinatmradar.¹⁶ Both are secondary sources. No later report was found, no action against a machine was found, and whether any machine operates in 2026 was not verified.

What Is Not Known

The BDL has not published regulations authorising any virtual asset activity in the texts reviewed, so it is not known whether and when the exception in Article 17(3) will be used. The CMA texts are known only through a secondary report, and the Official Gazette date of Decision No. 13837 was not found. The legal basis for the prohibition described in the 2023 evaluation report is not stated there. The date Lebanon was added to the FATF list comes from a news report and not from the FATF page. No draft digital asset law was found. Whether a crypto ATM operator needs a BDL or CMA approval, and whether a bank could serve one, are questions for Lebanese counsel and the BDL.

Sources and references

1. Banque du Liban, Basic Decision No. 13790 of 9 January 2026, Electronic Payment Services Providers, Articles 1, 2, 4, 17, 34, 40 and 42 (PRIMARY, accessed 9 October 2026) | bdl.gov.lb
2. Banque du Liban, Basic Decision No. 7548, Electronic Banking and Financial Operations, Article 10, as shown on the BDL page (PRIMARY, accessed 9 October 2026) | bdl.gov.lb
3. FATF, Jurisdictions under Increased Monitoring, 19 June 2026 (PRIMARY, accessed 9 October 2026) | fatf-gafi.org
4. FATF, Lebanon's measures to combat money laundering and terrorist financing, mutual evaluation 2023 (PRIMARY, accessed 9 October 2026) | fatf-gafi.org
5. Al Jazeera, Lebanon added to money laundering grey list, 25 October 2024 (SECONDARY, accessed 9 October 2026) | aljazeera.com
6. Unlock Blockchain, Lebanon's Capital Markets Authority warns against cryptocurrencies (SECONDARY, accessed 9 October 2026) | unlock-bc.com
7. The Beiruter, Lebanon meets with Binance on crypto regulation, 1 March 2026 (SECONDARY, accessed 9 October 2026) | thebeiruter.com
8. OMFIF, Lebanon's digital-dollar test, 22 July 2026 (SECONDARY, opinion commentary, accessed 9 October 2026) | omfif.org
9. Banque du Liban, Basic Decision No. 13819 of 21 May 2026, Conditions for the Establishment and Functioning of Finance Companies, Article 7 (PRIMARY, accessed 9 October 2026) | bdl.gov.lb
10. Banque du Liban, Basic Decision No. 13837 of 18 August 2026, Conditions for the Establishment and Functioning of Exchange Institutions, Articles 3, 5, 8, 13 and 36 (PRIMARY, accessed 9 October 2026) | bdl.gov.lb
11. Banque du Liban, Basic Decision No. 13769 of 14 November 2025, KYC Form for Cash Transactions (PRIMARY, accessed 9 October 2026) | bdl.gov.lb
12. MENAFATF, Mutual Evaluation Report of Lebanon, 2023, paragraph 118 (PRIMARY, accessed 9 October 2026) | fatf-gafi.org
13. Beirut.com, Bitcoin ATMs spotted in Hamra and Dawra, 8 November 2021 (SECONDARY, accessed 9 October 2026) | beirut.com
14. BitBeirut, company website, FAQ and location pages (company claims, accessed 9 October 2026) | bitbeirut.com
15. Carnegie Middle East Center, Cryptocurrency Mining in Lebanon, September 2022 (SECONDARY, accessed 9 October 2026) | carnegieendowment.org
16. CNBC, In bankrupt Lebanon, locals mine bitcoin and buy groceries with tether, 5 November 2022 (SECONDARY, accessed 9 October 2026) | cnbc.com

Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. Rules may change; always consult specialised local legal counsel and confirm the current position with the Banque du Liban and the Capital Markets Authority before considering market entry.