Country Manuals Private Banking
We would like to inform you that BRP has updated its COUNTRY MANUAL PRIVATE BANKING for the following jurisdiction:
LEBANON OUT OF BANK’S COUNTRY OF ESTABLISHMENT (Def, RS, BT & RT)
Regulatory Template
Material changes
This document has been entirely reviewed with the help of our local lawyers in order to reflect an evolution in the interpretation of the legal and regulatory framework, in particular, with regard to the following:
– The exemption granted to “Approved Institutions” (qualified clients) in Series 2000 Licensing and Registration Regulation regarding advertisement and marketing activity applies only to investment and not to banking activities. Consequently, the relevant section in the prospecting and negotiation phases have been changed from Grey zone/YES to NO;
– The active provision of services to qualified and non-qualified clients in or into Lebanon related to credit cards and Lombard credit is no longer permitted. Providing such services based on a client’s request is still possible;
– It is still permitted to provide investment advice to qualified and non-qualified clients based on an ongoing advisory agreement. However, any transaction under such an agreement must be carried out by the foreign bank based on an express instruction from the client.
Implications for business relations with third parties
In line with the first bullet point above regarding the exemption for qualified clients, the provision and collection of contracts related to the bank’s banking services can now be performed with respect to qualified clients only upon their request.
Non-material changes
Some comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.]
Regulatory Summary
This document has now a more user-friendly layout and reflects the changes contained in the RT.
Behaviour Template
The answers in the BT have been aligned to those contained in the RT.
BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “LEBANON” in the Target Country Field.
The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.
Best regards,