Mohamed AlgarjA company-by-company reading of the June 2025 disclosure attributed about $593 million—roughly 43% of the month’s $1.38 billion total—to companies grouped by family ties. The grouping is an analytical classification, not a legal finding of common ownership or misconduct.
Estimated share of June 2025 credits attributed to thirty family-linked groups
A concentration question hidden inside a monthly ledger
The June 2025 disclosure recorded about $1.38 billion in letters of credit over one month. Reclassifying the listed companies by apparent family or beneficiary links produced an estimated $593 million across thirty groups—about 43% of the monthly total. That percentage is the starting point of the investigation: it asks whether access to Libya’s official foreign currency is broadly distributed or repeatedly concentrated within connected commercial networks.
The calculation is not a criminal finding. It is a concentration screen built from names appearing in a central-bank disclosure. A reliable ownership map requires commercial-register extracts, shareholder histories, directors, authorized signatories and beneficial owners. Without those records, the result should be understood as a list of relationships requiring verification, not proof that separate companies acted as one undertaking.
Why the 43% matters
Letters of credit allocate scarce oil-derived dollars at an administratively determined price. Concentration therefore has consequences beyond banking: it can determine which importers expand, which suppliers gain market share and which businesses can price against competitors that buy currency through more expensive channels. Even lawful concentration can create systemic exposure if the same economic group depends on several banks or dominates imports of essential products.
A meaningful test would compare the thirty groups’ share with their share of customs-cleared imports, domestic sales, tax payments and employment. If 43% of financing produced a comparable share of verified goods and public revenue, the policy question differs sharply from a case in which the financing cannot be reconciled with imports or market supply.
What the published table cannot answer
The central-bank ledger identifies companies, banks and values, but it does not provide a common transaction identifier linking each credit to customs declarations, shipping documents, amendments, cancellations and final settlement. It also does not disclose whether companies with similar names are under common control or merely share a family name.
The monthly figure may combine different stages—applications, accepted requests, coverage or execution—depending on the specific table. Those stages cannot be added or compared without a shared definition. Concentration in approvals is not necessarily concentration in goods that actually arrived.
The oversight test
Bank supervision should examine aggregate exposure by beneficial owner, not only by the legal name on each application. That requires related-party rules, connected-client limits and a consolidated view across banks. Customs and tax authorities need the same identifier so that financed value, landed value, declared sales and tax outcomes can be reconciled.
The public-interest question is not whether relatives may own businesses. It is whether the state can see the full economic group when it allocates a scarce national resource, and whether comparable applicants face comparable rules.
The disclosure that would settle the debate
The Central Bank of Libya should publish a machine-readable monthly file containing the applicant, beneficial owner, financing bank, purpose, commodity code, value, approval date, execution date, amendments and status. Customs should publish a reconciliation rate showing how much of the executed value was matched to cleared goods.
That disclosure would allow concentration to be measured without speculation. It would also protect legitimate companies: a verified chain from approval to import, sale and tax payment is stronger than either an accusation or a blanket defence.
Editorial method: This investigation rebuilds the original calculation from the linked public records, preserves the source period and transaction stage, and separates documented figures from estimates, interpretation and allegations.
Mohamed Algarj