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[]
[]
[null,"Prepared By:","Contributors:"]
[null,"Moghaizel Law Office","Fadi Moghaizel"]
[null,null,"Caroline Rizk"]
[]
[]
["Lex Mundi Global Anti-Corruption Compliance Guide"]
[]
["Report Generated: 5/9/2025"]
[]
["View your report results on next tab"]

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["Question","Lebanon"]
["Anti-Corruption Compliance"]
["What is the key anti-bribery and corruption legislation in your jurisdiction?"," Lebanon has no general anti-corruption law, although Lebanon ratified the United Nations Convention against Corruption (\" UNCAC \") by Law No. 33, dated 16 October 2008 .  \n\n The laws that deal with anti-bribery and anti-corruption in Lebanon are the following: \n\n \n\t The Criminal Code enacted by Decree-Law no. 34, dated March 1, 1943  (as amended). This Code prohibits bribery of public officials and bribery of employees in the private sector ( Articles 350 to 356 ), trading in influence ( Articles 357 and 358 ), and embezzlement and misuse of function by public officials and government contracting parties ( Articles 359 to 366, 371, 376 and 377 ). \n\t The Rules on Civil Servants issued by Decree-Law no. 112/1959, dated June 12, 1959 , prohibit public officials from accepting any benefit in the course of their duties ( Article 15-7 ).   \n\t Law no. 154, dated December 27, 1999 , on illicit enrichment (of civil servants). This law exposes public officials to prosecution for illicit enrichment resulting from bribery, misuse of function, or any other illegal act. A civil servant is any public official in the public sector, including military and customs officials, judges, government contracting parties, the President of the Republic, the Speaker, the Prime Minister, ministers, members of Parliament, and any elected or appointed persons entrusted with a public office such as notaries and mayors.  \n\t   Law no. 44, dated November 24, 2015, on fighting money laundering and terrorist financing . For the purpose of this Law, illicit funds include assets, tangible and intangible, movable and immovable, including any legal documents or instruments evidencing title to, or interest in, such assets, resulting from the commission of, or the punishable attempted commission of, or the participation in any of the offenses listed in the law, whether in Lebanon or abroad. That said, corruption, including bribery, trading in influence, embezzlement, abuse of functions, abuse of power, and illicit enrichment are listed as offenses under this law.  \n\t Law no. 25, dated October 8, 2008, on Parliamentary Elections prohibits parliamentary election candidates from providing services or paying sums of money to voters, except if the candidate has regularly provided such services for at least three years prior to the start of the election campaign ( Article 59 ). The willful breach of this prohibition is criminally sanctioned by imprisonment for up to six months and/or by a fine from LBP 50,000,000 (USD 33,334) up to LBP 100,000,000 (USD 66,667) ( Article 62 ).   \n\t Access to Information Law of January 19, 2017 . This law allows any person, whether Lebanese or a foreigner, a natural person or a legal entity, to request access to information from all public entities and a small number of private entities as well. The law provides a limited list of exceptions to this right including secrets of national defense and information that falls within the right of privacy of individuals. The law also requires all public entities to release annual reports and documents to strengthen the understanding of regulations and decisions made.  \n\t Law no. 83 dated October 10, 2018, governing the protection of whistleblowers. This law aims to encourage whistleblowing by protecting individuals who disclose information about a job or abstinence, that already happened, is happening or could happen, believed to be related, or could assist in proving corruption. This law protects the concerned individuals from negative consequences within their career framework (disciplinary action, discharge, etc…) and outside their career framework (vengeance, threats, violence, etc…). \n\t  \n \n"]
["Has there been a specific anti-bribery and corruption law enacted in your jurisdiction in the last ten years?"," There are two relevant laws mentioned in our response to \" What is the key anti-bribery and corruption legislation in your jurisdiction? \" above which were enacted in Lebanon in the last ten years: \n\n \n\t The Access to Information Law of January 19, 2017, which gives any person and legal entity the right to obtain information and documents held by the public administration. This law makes it possible to take a major step in the wake of democracy, in harmony with the principles of transparency and the fight against corruption; and \n\t Law no. 83 of October 10, 2018 , concerning the protection of whistleblowers. This law protects whistleblowers by securing confidentiality and guaranteeing their employment and personal safety. It also includes specific mechanisms for compensation and assistance for whistleblowers \n\t  \n \n"]
["Is a bribe payment to domestic government officials prohibited by the legislation?","Yes, a bribe payment to domestic government officials is prohibited in Lebanon. \nThe \nLebanese Criminal Code distinguishes between active bribery (the act of offering a bribe), and passive bribery (the act of soliciting or accepting a bribe). \nUnder \nArticle 353 of the \nLebanese Criminal Code, the same sanctions applicable to passive bribery apply to the briber. \n\n\n \n"]
["Is a bribe payment to foreign government officials prohibited by the legislation?","The \nCriminal Code does not contain any provisions regarding the bribery of foreign public officials. \nThat said, the \nCriminal Code does hold that a Lebanese national who commits an offense outside Lebanon is liable for prosecution in Lebanon if such offense is punishable under the Lebanese law by imprisonment for three years and above, or if such offense is punishable under Lebanese law by imprisonment for less than three years provided it is sanctioned by the law of the state where it was committed (\nArticles 20 and \n24 of the \nCriminal Code). Therefore, a Lebanese national who commits an act of bribery with an official abroad would be criminally prosecuted in Lebanon under the relevant provisions of the \nCriminal Code.\n\n\n \n"]
["Is requesting or accepting a bribe prohibited by the legislation?"," Yes, soliciting or accepting a bribe is prohibited under the Lebanese Criminal Code . \n\n It is a criminal offense for a public official to:  \n\n \n\t Solicit or accept for himself/herself, or for a third party, a gift, promise, or any other benefit in order to perform his duty ( Article 351 of the Criminal Code ). \n\t Solicit or accept for himself/herself, or for a third party, a gift, promise, or any other benefit in order to perform any act in breach of his/her duties, or that he/she claims as falling within his/her duties, or neglect or delay the performance of his/her duties ( Article 352 of the Criminal Code ). \n\t Accept an undue remuneration for the performance of a duty previously performed ( Article 356 of the Criminal Code ). \n\t Obtain a personal benefit resulting from his/her duties, whether directly or through an intermediary ( Article 359 of the Criminal Code ). \n\t Carry out a work not provided for in the law in violation of his/her duties in order to obtain a personal benefit or a benefit for a third party, or in order to cause damage to a third party ( Article 376 of the Criminal Code ). \n \n\n Moreover, it is a criminal offense for a person to receive or solicit an undue remuneration or accept a promise of such undue remuneration, whether for himself/herself or for a third party, in order to obtain or attempt to obtain for a third party, a position, work, project, profit, or grant from the State or from any government body, or in order to alter the behavior of the public authorities in any manner ( Article 357 of the Criminal Code ).  \n\n Lawyers are also prosecuted if they commit the above acts in order to obtain the sympathy of a judge, receiver, or expert ( Article 358 of the Criminal Code ).   \n\n Finally, it is a criminal offense for contracting parties with public authorities to misuse their position in order to obtain a personal benefit for themselves or for third parties ( Article 363 of the Criminal Code ). \n\n It is a criminal offense for a private sector employee to solicit or accept for himself/herself, or for a third party, a gift, promise, or any other benefit in order to disclose secrets or information harmful to work or to carry out his duties or refrain from it with the intention of causing material or moral damage to the employer or to his/her business ( Article 354 of the Criminal Code ). \n  \n"]
["Who is subject to the legislation?","In general, public officials, individuals, and employees in the private sector. \nUnder \nArticle 350 of the \nLebanese Criminal Code, is regarded as a government employee/public official (and thus is subject to the provisions of said \nCode) any employee in public administrations, public institutions, municipalities, the army, judicial authorities, every worker or employee of state departments and every person appointed or elected to perform public service with or without remuneration. \nPolitical candidates are not deemed public officials, nor officers or employees of a public international organization.\nFurthermore, \nArticle 354 of said \nCode prohibits all employees of the private sector from soliciting or accepting any form of bribery.   \n\n\n \n"]
["Is there criminal liability for corporate entities who have either paid or accepted a bribe payment?","Under \nArticle 210 of the \nCriminal Code, legal entities are criminally responsible for the activities of their directors, board members, representatives and agents when such activities are undertaken on behalf of, or using the means of such legal entities.  \nTherefore, legal entities are criminally liable for any criminal activity, including the act of bribery, committed by any of their directors, board members, representatives, and agents only, provided the conditions mentioned in the abovementioned \nArticle 210 of the \nCriminal Code are available. \n"]
["What is the penalty for individuals violating the law?"," Regarding the violation of the law in the public sector: \n\n \n\t A public official and/or any person entrusted with an official duty (whether elected or appointed), who solicits or accepts for himself/herself or for a third party, a gift, promise, or any other benefit to perform any legal activity falling within the scope of his/her duties is punished by imprisonment from three months to three years and a fine amounting to not less than twice the amount received or accepted ( Article 351 of the Criminal Code ). \n\t A public official and/or any person entrusted with an official duty (whether elected or appointed), and/or the lawyer, who solicits or accepts for himself/herself or for a third party a gift, promise, or any other benefit in order to perform any activity in breach of his/her duties or activity he/she alleges to be falling within the scope of his/her duties or in order to neglect or delay performing his/her duties is punished by provisional forced labor and to a fine amounting to not less than three times the amount received or accepted ( Article 352 of the Criminal Code ). \n\t The above sanctions (in Articles 351 and 352 of the Criminal Code ) also apply to the briber ( Article 354 of the Criminal Code ).  Moreover, any accomplice in bribery or any other offense is criminally sanctioned ( Articles 213, 219, and 220 of the Criminal Code ), and, an attempt to bribe a public official is criminally sanctioned. The accomplice in a crime is subject to the relevant sanction provided for in the violated law ( Article 213 of the Criminal Code ). Attempted bribery of a public official is sanctioned by imprisonment for at least three months and by a fine not less than twice the value of the offered bribe ( Article 355 of the Criminal Code ).  \n\t A public official and/or any person entrusted with an official duty (whether elected or appointed) who accepts an undue remuneration for an act he/she has previously performed in the scope of his/her function or duties is punished by imprisonment from one month to one year and a fine amounting to no less than twice the amount he/she has accepted ( Article 356 of the Criminal Code ).  \n\t Public officials who obtain a personal benefit resulting from their duties, whether directly or through an intermediary, are punished by imprisonment from three months to two years and a fine amounting to not less than LBP 200,000 (USD 167) ( Article 364 of the Criminal Code ). \n\t Public officials who perform an act in breach of their duties in order to obtain a benefit for themselves or for a third party, or in order to cause prejudice to a third party, are punished by imprisonment from one month to three years and a fine amounting to not less than LBP 20,000 (USD 14) up to LBP 200,000 (USD 167) ( Article 376 of the Criminal Code ). \n\t Any person who receives or solicits an undue remuneration or accepts a promise of such undue remuneration, whether for himself/herself or for a third party, in order to obtain or attempt to obtain for a third party, a position, work, project, profit, or grant from the State or from any governmental body, or in order to alter the behavior of public authorities in any manner, is punished by imprisonment from two months to two years and a fine amounting to not less than twice the amount received or accepted ( Article 357 of the Criminal Code ).  \n\t A lawyer who commits the actions listed in the abovementioned Article 357 of the Criminal Code in order to obtain the sympathy of a judge, receiver, or expert is punished by imprisonment from one year to three years and disbarred for life ( Article 358 of the Criminal Code ).  \n\t Contracting parties with public authorities are also punished by imprisonment from three months to three years and a fine amounting to not less than 200,000 LBP (USD 134) and up to LBP 1,000,000 (USD 667) if they misuse their position in order to obtain a personal benefit for themselves or for third parties ( Article 363 of the Criminal Code ). \n \n\n Regarding the violation of the law in the private sector: \n\n \n\t Any person working in the private sector, whether an employee, an expert, or a consultant, who solicits or accepts for himself/herself or for a third party a gift, a promise, or any other benefit, in order to disclose secrets or information harmful to his/her employer’s business, or to carry out or refrain from carrying out any act for the purpose of causing material or moral damage to the employer or to his/her business interests is punished by imprisonment from two months to two years and a fine amounting to not less than  LBP 100,000 (USD 67) up to LBP 200,000 (USD 134). The above sanctions also apply to the briber ( Article 354 of the Criminal Code ).  \n\tThe criminal court may also decide to deprive the convicted person of certain of his/her civil rights ( Article 378 of the Criminal Code ). This is subject to the court’s authority. For example, if the convicted person is deprived of his/her civil rights, this means that he/she cannot run for elected office. \n \n"]
["Assuming corporate entities are liable for violating the legislation, what is the penalty for corporate entities violating the law?","Under \nArticle 210 of the \nLebanese Criminal Code, legal entities may be sentenced only to a fine, confiscation of assets and publication of the judgment. If the law provides for a primary penalty other than a fine, that penalty shall be replaced by a fine. \nThat said, a legal entity in the private sector may be compelled to cease its operations, if its directors, board members, representatives, or agents have committed, on its behalf or using its means, an intentional offense sentenced by not less than two years of imprisonment. The ceasing of activities can be from one month to two years. Moreover, the criminal court may require the dissolution of the legal entity within a period of five years from the date of the court’s decision ordering the entity to cease its activities (\nArticles 108, 109, and \n110 of the \nCriminal Code).\n\n\n \n"]
["Assuming corporate entities are liable for violating the legislation, does having a compliance program designed to prevent bribery constitute a defense?","Under \nArticle 179 of the \nLebanese Criminal Procedure Code, the parties have the freedom of proof in criminal matters. \nAs such, a compliance program designed to prevent bribery can constitute a defense. However, its evidence worth depends entirely on the judge’s discretion and evidently on the circumstances of each case.   \n\n\n \n"]
["Assuming corporate entities are liable for violating the anticorruption law, is it possible for a corporate entity to reach a deferred prosecution agreement or leniency agreement with the enforcement authorities?","This is not applicable under Lebanese law. \n"]