(11)Lebanon made a high-level political commitment in October 2024 to work with the FATF and the MENAFATF, which is its FSRB, to strengthen the effectiveness of its AML/CFT regime in spite of the challenging social, economic and security situation within the country. Since the adoption of its MER in May 2023, Lebanon has made progress on several of the actions recommended in the MER and has applied measures to its financial sector, including through issuing a circular for banks and financial institutions to establish a department dedicated to combating bribery and corruption related crimes and guidance on politically exposed persons, while taking measures against unlicensed financial activity. Lebanon will continue to work with the FATF to implement its FATF action plan by: assessing specific ML/TF risks identified in the MER and ensuring that policies and measures are in place to mitigate those risks; enhancing mechanisms to ensure the timely and effective execution of requests for mutual legal assistance, extradition and asset recovery; enhancing DNFBPs’ risk understanding and applying effective, proportionate and dissuasive sanctions for breaches of AML/CFT obligations; ensuring that beneficial ownership information is up-to-date and that there are adequate sanctions and risk-mitigating measures in place for legal persons; enhancing competent authorities’ use of products of the FIU and financial intelligence; demonstrating a sustained increase in investigations, prosecutions and court rulings for types of ML in line with the risk; improving its approach to asset recovery and identifying and seizing illicit cross-border movements of currency and precious metals and stones; pursuing TF investigations and sharing information with foreign partners related to those investigations as called for in the MER; enhancing the implementation of TFS without delay, particularly at DNFBPs and certain non-banking financial institutions; and undertaking targeted and risk-based monitoring of high-risk NPOs, without disrupting or discouraging legitimate NPO activities. While recognising and welcoming the commitment and progress made by Lebanon so far despite the current challenging circumstances, the Commission concludes that Lebanon has not yet fully addressed the concerns that led to its addition to the FATF’s list of ‘Jurisdictions under Increased Monitoring’. Lebanon should therefore be considered a high-risk third country.