Context
In June 2026, Banque du Liban (BDL) formally adopted Intermediate Circulars 768 and 769 extending Circulars 158 and 166 for an additional year, while introducing several technical amendments aimed at increasing depositor access and flexibility.
Earlier in May, BDL issued a press release reviewing the implementation of Circulars 158 and 166 - a notable effort towards transparency. However, a closer look at the circulars reveals that they are disproportionately funded by taxpayers relative to bank shareholders and, in the absence of a comprehensive bank restructuring law, are leading to an unfair allocation of losses.
- Headline Figures
According to BDL, Circulars 158 and 166 inject $2.5 billion in foreign exchange (FX) liquidity annually through direct payouts to depositors.
- The Scope: As of late March 2026, 578,770 depositors have benefited from these circulars, with 266,166 having recovered the full amount they are entitled to under Circular 158.
- The Payouts: A total of $6.1 billion has been disbursed since 2021.
- The Burden Sharing: BDL has covered 69 % ($4.2 billion) of the payouts, while commercial banks only 31% ($1.9 billion).
2. Three Mechanisms, Three Circulars
To understand the full scope of BDL's policy, these numbers must be looked at through the lens of three distinct regulatory mechanisms:
- Circular 151 (Issued in 2020): Not mentioned in the BDL communiqué as it expired in December 2023. It facilitated withdrawals from USD accounts in LBP at exchange rates significantly lower than the market rate (3,900 LL/$ then 8,000 LL/$ then 15,000 LL/$), with monthly withdrawal caps being progressively reduced over time ($5,000, then $3,000, then $1,600).
- Circular 158 (Issued in 2021): Applies to USD accounts opened prior to October 2019, withdrawal cap of $50,000. Previously: Monthly withdrawals partially in “fresh dollars” and partially at below market rates (at different rates). Current terms allow for up to $1,000/month ($800 in cash + $200 via card).
- Circular 166 (Issued in 2024): Applies to USD accounts opened prior to June 30, 2023 with exclusions. Current terms allow for up to $500/month ($400 in cash + $100 via card) with a current annual cap at $5,500. Intermediate Circular 769/2026 increased the maximum eligible balance to $15,200 per depositor per bank,
3. What the Figures Fail to Disclose
Behind these aggregates lies a strategy that has led small depositors into accepting a single option with steep and implicit haircuts and delayed recovery, bearing the brunt of the financial crisis.
