The Association of Banks announced in a statement that "eleven Lebanese banks submitted today to the Ministry of Finance a conflict memorandum, through lawyers Eli Amil Shamon and Akram Azouri, demanding the Lebanese state to pay its debts and obligations to the Central Bank of Lebanon so that the latter can meet its obligations to the Lebanese banks, which in turn can return the depositors' funds." The statement pointed out that "the memorandum was based on the financial statements of the Central Bank of Lebanon, the results of the forensic audit issued by Alvarez & Marsal, and the accounting audit provided by Oliver Wyman, at the request of the Lebanese state.
After a detailed account of the manner in which losses were accumulated in the Central Bank of Lebanon, through the state's use of funds, which are depositor funds deposited voluntarily by banks in the Central Bank or through mandatory circulars and decisions issued by the Central Bank that obligate the banks, the plaintiff banks summarized their demands in three points:
First - Requesting the state to pay its debt to the Central Bank amounting to approximately $16 billion and $617 million.
Second - Requesting the state to pay about $51 billion and $302 million, to cover the losses of the Central Bank evident in its 2020 financial statement, in accordance with the Law of Money and Credit, especially Article 113 thereof.
Third - Covering the increase in the deficit of the Central Bank for the years 2021 and 2022, by following the accounting method utilized by Alvarez & Marsal in determining losses up to 2020.
The memorandum hinted, according to the statement, at resorting to "the administrative judiciary to compel the Lebanese state to fulfill its legal obligations toward the Central Bank, in case it does not respond to these demands."