The Banque du Liban (BDL) has officially announced it signed a cooperation agreement with the U.S. firm K2 Integrity, which specializes in anti–money laundering and financial risk consulting, amid rising questions about the deal’s background, transparency, and practical value. The contract comes as international pressure mounts on Lebanon to exit the Financial Action Task Force (FATF) “gray list.”

Amid growing parliamentary demands for transparency and oversight, MP Paula Yacoubian had submitted a formal question to the BDL and the government weeks before the agreement was signed. She requested clarification on the nature and purpose of the engagement; its annual cost, reportedly estimated at four million dollars over three years (a total of $12 million); and why no information about it appeared with the Public Procurement Authority. No official response was issued to her inquiry, until the BDL later announced in an official statement that it had concluded the agreement with the company.

Daraj sent the BDL a list of questions regarding the contract’s stated objectives and the company’s role in addressing the central bank’s challenges; the reasons for selecting K2 Integrity specifically; detailed terms including annual cost and duration; potential conflicts of interest; and why no formal reply was given to MP Yacoubian’s question. As of publication time, we had not received a response.

In this context, it is necessary to address the potential conflicts of interest, particularly since Daniel Glaser—Global Head of Jurisdictional Services and Head of the Washington, D.C. office at K2 Integrity—previously served as an advisor to Lebanese banker Antoun Sehnaoui of SGBL Bank.

Moreover, Glaser and Sehnaoui are partners in the Institute for Financial Integrity (IFI), a company that, according to its website, aims to “protect the financial system from illicit use and combating threats to collective security through cutting edge research, education, and training.” Glaser serves as Chairman of the Board, while Sehnaoui sits as a Board Member, highlighting the web of intersecting interests and overlapping spheres of influence surrounding this case.

The Intersecting Interests and Overlapping Spheres of Influence

Media and banking circles have also spoken about the role of Mohammad Baasiri, the former Deputy Governor of the Banque du Liban, in negotiating with K2 Integrity, as well as a potential role for him as an advisor to the current Central Bank Governor, Karim Souaid.

It is worth noting that during the “U.S.–MENA Private Sector Dialogue” of 2024, organized in partnership with the U.S. Department of the Treasury under the theme “Strengthening Compliance in the MENA Banking Sector to Meet the US Regulatory Expectations, amid Geopolitical Challenges”—an initiative led by Baasiri—Sarah Runge, Managing Director at K2 Integrity, participated as a speaker in the event.

A source familiar with the matter, who requested anonymity, indicated that Mohammad Baasiri and Wissam Fattouh—the Secretary-General of the Union of Arab Banks in Lebanon since 2010 and one of the speakers at the same event—played a role in introducing K2 Integrity to the Iraqi market. However, Daraj has not been able to independently verify this information.

These circumstances underscore the urgent need for clear and transparent answers from the Banque du Liban regarding the motives behind the contract, the selection process, the actual beneficiaries, and the influence of external advisors associated with the company, particularly given that Lebanon’s financial future and its international relationships are now closely tied to such contracts and decisions.

In an interview with Daraj, economic journalist Mounir Younes called on the Central Bank Governor to publicly disclose the value and terms of the contract signed with K2 Integrity, stressing that the bank’s expenditures come directly from depositors’ funds. “It is their right to know how what remains of the Central Bank’s reserves, essentially what remains of their deposits, is being managed and spent,” Younes said.

He added: “If there were genuine will to implement reforms, ensure compliance, and enforce accountability within a clear political decision, there would be no need to spend $12 million on a contract with a foreign company, especially since Lebanon’s banking system already has existing oversight bodies that are supposed to perform this role, including the Banking Control Commission and the Special Investigation Commission (SIC). This raises serious questions about their capacity and effectiveness.” According to Younes, outsourcing this work abroad could be seen as an implicit acknowledgment of the incompetence or failure of these institutions to fulfill the Financial Action Task Force (FATF) requirements necessary for Lebanon’s removal from the grey list.

It is also worth noting that the Special Investigation Commission had previously established a Technical Assistance Committee, which carries out similar functions to those now assigned to the foreign company. The committee includes representatives from major embassies (such as the United States, France, and Germany), along with the EU AML/CFT Global Facility and the European Union Delegation to Lebanon.

In this context, MP Paula Yacoubian told Daraj in an interview: “I had previously submitted a parliamentary question regarding the measures taken under Lebanon’s FATF action plan. The response I received mentioned ongoing coordination with several European countries contributing to this process.

The question today is: Why should we pay such an enormous amount to a company referred to as K2 Integrity? It is indeed a well-known firm, but when we reviewed the Public Procurement Platform, we found no trace of this contract. The legal framework or the legal basis for this agreement remains unclear.

These are questions that fall under parliamentary oversight, which every MP should exercise. We simply want to know: do we truly need to hire yet another company to remove Lebanon from the FATF grey list?”

Yacoubian added that she does not know whether any suspicious deal is involved in this potential contract, but stressed the need to ensure there is no conflict of interest between the foreign firm and any Banque du Liban officials.

Central Bank Statement

The Banque du Liban (BDL) issued the following official statement on July 14, 2025:

“Banque du Liban announces the signing of a cooperation agreement with K2 Integrity, a leading U.S.-based firm specializing in global risk management, compliance, and financial investigations. This agreement forms part of the Bank’s ongoing efforts to combat the expansion of the cash economy and address all forms of illicit and fraudulent activity.

This step comes within the framework of BDL’s plan to remove Lebanon from the FATF ‘grey list’, under which K2 Integrity will provide the technical and advisory support necessary to implement measures that strengthen Lebanon’s Anti–Money Laundering (AML) and Countering the Financing of Terrorism (CFT) systems.

K2 Integrity has extensive experience providing strategic advisory services to central banks, governments, commercial and investment banks, and financial and fintech institutions in over 100 countries worldwide. Its experts possess deep knowledge of international standards, global best practices, and country-specific regulatory requirements, particularly across Europe, the Middle East, and Africa (EMEA), covering 28 jurisdictions aligned with EU directives. The company also adheres to U.S. financial crime compliance frameworks, including the USA PATRIOT Act, the Bank Secrecy Act (BSA), and Office of Foreign Assets Control (OFAC) regulations.

Banque du Liban will leverage the firm’s specialized expertise and global presence to design and implement a comprehensive action plan aimed at identifying systemic gaps, closing regulatory loopholes, and restoring confidence in Lebanon’s financial system both locally and internationally.”

Mohammad Baasiri and a Possible Return to the Central Bank

Several media outlets have reported on the possible return of prominent banker and former Deputy Governor of the Banque du Liban (BDL), Mohammad Baasiri, to the central bank. Today, Baasiri reemerges from behind the scenes, raising questions about his potential involvement in managing sensitive files, including those tied to the future of Lebanon’s banking sector and the Financial Action Task Force (FATF) “gray list”.

However, Baasiri’s reappearance on the public stage also stirs serious questions about his old and new ties with major banking figures, most notably his relationships with former Central Bank Governor Riad Salameh, Association of Banks in Lebanon President Salim Sfeir, and prominent banker Antoun Sehnaoui.

In this context, MP Paula Yacoubian told Daraj:

“There have been media leaks suggesting that Mohammad Baasiri may be involved in this matter. I only referred to those leaks in order to raise the question and call for clarity and transparency with the public. Why do we need this company? Perhaps Banque du Liban should explain whether Lebanon truly requires it.

It could be merely a public relations framework—a firm capable of better communicating Lebanon’s position and improving its image with the U.S. Treasury Department or other stakeholders. The main issue is transparency with the public. I’m not accusing anyone of wrongdoing or suggesting that there’s a deal behind this; I’m simply asking questions because that’s my job.”

Mohammad Baasiri did not respond to Daraj’s questions regarding this matter.

Who Is Mohammad Baasiri?

Mohammad Baasiri is a prominent Lebanese banker who also holds U.S. citizenship. He served as Deputy Governor of the Banque du Liban (BDL) from 2009 to 2019, and in September 2019 was appointed to oversee the liquidation of Jammal Trust Bank. Later, he was assigned as interim manager of Credit Bank after suspicions arose of embezzlement and money-laundering involving millions of dollars by the bank’s former chairman, Tarek Khalife.

Within the central bank, Baasiri previously served as Secretary-General of the Special Investigation Commission (SIC) for Anti-Money Laundering, from 2001 to 2009, and has held several other high-level positions. Since 2006, he has also been Chair of the U.S.–MENA Private Sector Dialogue Initiative, and he worked as a Resident Adviser at the International Monetary Fund (IMF) between 2000 and 2001. At one point, his name was even circulated as a potential candidate for the Lebanese premiership.

Over his three-decade-long career, Baasiri became one of the key architects of the regional anti-money-laundering framework (MENAFATF) and established close ties with financial policy circles in Washington. He presents himself as a reformist, yet at every critical juncture he has remained part of Lebanon’s entrenched financial establishment.

Baasiri’s name previously appeared in a Daraj investigation published as part of the Pandora Papers Project with the International Consortium of Investigative Journalists (ICIJ). The investigation revealed that banker Marwan Kheireddine had provided Baasiri with a “letter of credibility” to facilitate the creation of an offshore company.

The letter read:

“We are pleased to confirm that we have known Mr. Mohammad Baasiri for twenty-five years and that he has never, to our knowledge and belief, been involved in any bankruptcy, felony, or similar proceedings. We consider him financially reliable and of good moral standing… This letter is addressed to you alone and may be relied upon only for the purpose of determining whether services are to be provided to Mr. Baasiri. It is strictly confidential and may not be disclosed to any third party except under compulsion of a court order or other competent authority.”

In addition to this credibility letter from Bank Al-Mawarid, two further letters signed by Marwan Kheireddine stated that Baasiri held USD 150,000 in his bank account. Baasiri used these documents to apply for the incorporation of an offshore company in the British Virgin Islands in 2016.

The leaks did not provide further information. When contacted at the time by the ICIJ, Baasiri denied owning any company in the British Virgin Islands.

What Is K2 Integrity?

K2 Integrity is a U.S.-based consultancy specializing in financial-risk management, anti-money-laundering compliance, financial investigations, and regulatory advisory services. Founded in 2009 by Jeremy and Jules Kroll, the latter widely regarded as the father of modern corporate investigations, the firm brings together a multidisciplinary team of former public- and private-sector experts, including former regulators, economic-security officials, and auditors.

K2 Integrity offers an integrated suite of services encompassing financial investigations, asset tracing, forensic auditing, cybersecurity risk management, AML/CFT advisory, and the design of compliance frameworks for financial and fintech institutions.

The First Parliamentary Question on Lebanon’s FATF Action Plan

MPs Firas Hamdan, Simon Abi Ramia, Paula Yacoubian, Ibrahim Mneimneh, Yassin Yassin, and Alain Aoun submitted a parliamentary question concerning the implementation of the Financial Action Task Force (FATF) Action Plan designed to remove Lebanon from the list of countries under increased monitoring, commonly known as the “grey list.”

The concerned entities include the Ministry of Finance (including the Customs Administration and the Directorate General of Revenues), the Ministry of National Defense (Military Intelligence and the Military Court), the Ministry of Interior and Municipalities (Internal Security Forces, General Security, the Directorate of Political Affairs and Refugees), the Ministry of Justice (Public Prosecution, Commercial Registry, and the Office of International Cooperation), the National Anti-Corruption Commission, the National Committee for Combating the Financing of Terrorism, the Beirut and Tripoli Bar Associations, and the Syndicate of Certified Public Accountants.

The responses from the ministries and concerned agencies varied widely. While the Ministry of Interior provided a detailed response, the Ministry of Finance’s reply was very limited and general. On this, MP Paula Yacoubian told Daraj:

“The responses differed significantly regarding that first question. I’m not sure if this is an administrative shortcoming, or perhaps some ministries and departments are simply more active than others. But I must note that since the formation of Nawaf Salam’s government, every parliamentary question we’ve submitted has received an answer, something that wasn’t possible before.”

The key questions remain: Have authorities verified the absence of conflicts of interest between any Banque du Liban officials (or collaborators) and the foreign company? And what is the actual benefit and necessity of contracting this firm in the first place?