The issue goes beyond the mere freezing of bank accounts. A decision issued by the Special Investigation Commission (SIC) at Banque du Liban, dated September 18, 2026, places a group of individuals and companies linked to different financial and judicial files under a single set of measures, including the freezing of accounts, restrictions on the disposal of assets and safe-deposit box holdings, and the lifting of banking secrecy vis-à-vis the competent authorities.

 According to the decision circulated to banks and financial institutions operating in Lebanon, the measures cover 11 individuals and two companies, while excluding salary-domiciliation accounts from the freeze.

 The list includes former Banque du Liban Governor Riad Salameh, his brother Raja Salameh, Marianne Hoayek, Samir Hanna, Hassan Ahmad Moukalled, André Machnouk, Bachir Mansour, Bassem al-Hout, Alaa Khawaja, Mohammad Hariri and Samara Kazzi, in addition to CTEX Company for Exchange SAL and V Limited Investment Inc.

 But the more important question is not simply who is on the list, but why individuals associated with different cases appear together in a single decision.

 Different Files Under One Decision

What stands out is that, based on the information currently available, the list does not appear to reflect a single judicial case involving all those named.

Rather, it brings together individuals linked to different investigations and proceedings, some dating back to Riad Salameh’s tenure at Banque du Liban and others related to separate financial cases or previous U.S. sanctions.

 Therefore, the fact that these names appear in the same document should not be interpreted as evidence that they are all involved in one common case.

 Among the most prominent names are Riad Salameh, his brother Raja and his former assistant Marianne Hoayek, whose names have been linked in recent years to financial investigations in Lebanon and abroad.

The list also includes Samir Hanna, former chairman of Bank Audi, as well as Alaa Khawaja, Mohammad Hariri and others whose names, according to published reports, have appeared in financial files investigated in recent years.

 Hassan Moukalled and CTEX: A Different Track

 The inclusion of Hassan Moukalled and CTEX Company for Exchange introduces a different dimension to the decision.

 In January 2023, the U.S. Treasury Department imposed sanctions on Moukalled and CTEX, linking them at the time to Hezbollah. These are U.S. sanctions, not Lebanese judicial rulings, and they should be distinguished from the current measures taken by the Special Investigation Commission.

 However, more recent developments make the inclusion of Moukalled and CTEX particularly significant from a news perspective.

According to press reports published this week, Banque du Liban filed a complaint against Moukalled in his capacity as chairman of CTEX over a financial advance that the company allegedly received during Riad Salameh’s tenure to finance U.S. dollar purchases on behalf of the central bank.

The case reportedly led to judicial proceedings over alleged breach of trust and was referred to an investigating judge. These remain allegations under judicial investigation and do not constitute a final determination of liability.

 What Does Lifting Banking Secrecy Mean?

This is one of the most significant elements of the decision.

The Special Investigation Commission did not limit its action to freezing accounts and assets and restricting access to safe-deposit box holdings. It also decided to lift banking secrecy on the accounts concerned vis-à-vis the competent judicial authorities.

 In practical terms, this allows the competent authorities, within the scope of their legal powers, to access relevant banking information and examine account activity and financial movements rather than having such information remain protected by banking secrecy.

 This is precisely what makes the decision broader than simply preventing account holders from moving their funds. It potentially enables banking records to be used in the relevant investigations.

 Why Now?

 The timing of the decision also raises questions.

The move comes as Banque du Liban Governor Karim Souaid has announced legal and judicial action in Lebanon and abroad aimed at recovering funds that the central bank says may have been embezzled, misused or improperly transferred.

Banque du Liban has also said it is working to determine the amounts made available to successive Lebanese governments through the end of 2023.

 However, there is not yet enough official information to conclude that the Special Investigation Commission’s decision forms part of a single judicial case or that all the individuals named are directly connected to the same legal proceedings.

This is where it is essential to distinguish between events occurring at the same time and a connection that has actually been established.

Freezing Accounts Does Not Mean Conviction

This may be the most important point when interpreting the decision.

The inclusion of an individual or company in a decision to freeze accounts and lift banking secrecy does not, in itself, amount to a conviction or establish that a criminal offense has been committed.

 The decision sets out banking and financial measures, while criminal liability is a separate matter to be determined through investigations and judicial proceedings.

 Likewise, the inclusion of several names in the same decision does not necessarily establish a direct financial or judicial connection among them.

The true significance of the September 18 decision will therefore depend not only on the list of names, but on what follows: Which cases will move forward before the courts? What could the examination of banking records reveal after banking secrecy is lifted? And will the investigations ultimately lead to the recovery of funds, or will the measures remain limited to asset freezes and ongoing investigations?

The answers to these questions will determine whether the September 18 decision is primarily a broad precautionary measure or the beginning of a new phase in examining financial files linked to the years surrounding Lebanon’s financial collapse.

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