Based on these findings it was concluded that, overall, Lebanon is meeting expectations in relation to sorting, preparing and validating the information. It was also noted that there is room for improvement with respect to the sorting, preparing and validating of the information to ensure that all exchanges partners accept the information received. Lebanon should therefore continue its implementation process accordingly, including in relation to the area highlighted.
Recommendations:
Lebanon should continue to work with its exchange partners to address the issues raised.
SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.
Findings:
In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Lebanon linked to the CTS.
Based on these findings it was concluded that Lebanon is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Lebanon is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.
Findings:
It is noted that Lebanon faced significant technical issues and as a consequence was delayed in sending the information to its exchange partners. However, Lebanon successfully addressed most of the issues and sent the information as soon as possible thereafter, except for with respect to one partner which stated that it has still not yet received the information.
Based on these findings it was concluded that Lebanon is partially meeting expectations in relation to exchanging the information in a timely manner. However, significant issues have been identified, including with respect to exchanging information in a timely manner. Lebanon should continue its implementation process to ensure its effectiveness, including by addressing the recommendations made.
Recommendations:
Lebanon should ensure that exchanges are conducted in a timely manner.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Lebanon’s exchange partners did not raise any concerns with respect to Lebanon’s use of the agreed transmission methods and therefore with Lebanon’s implementation of this requirement.
Based on these findings it was concluded that Lebanon is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Lebanon is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.
It should be noted that, as Lebanon exchanges information on a non-reciprocal basis and does not therefore receive information, it is not required to have in place systems to receive the information and provide status messages. SR 2.8 has therefore not been assessed in this case.
Findings:
Not applicable.
Recommendations:
Not applicable.
SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.
Findings:
Lebanon appears ready to respond to notifications and to provide corrected, amended or additional information in a timely manner and no such concerns were raised by Lebanon’s exchange partners and therefore with respect to Lebanon’s implementation of these requirements.
Based on these findings it was concluded that Lebanon appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Lebanon is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.