APG Mutual Evaluation Report Pakistan Ratings - October 2019
1. Anti-money laundering and counter-terrorist financing measures in Pakistan - Mutual Evaluation Report - October 2019 1
Anti-money laundering and counter-
terrorist financing (AML/CFT)
measures in Pakistan
Fourth Round Mutual Evaluation
Ratings
October 2019
http://www.fatf-gafi.org/publications/mutualevaluations/documents/mer-Pakistan-2019.html
2. Anti-money laundering and counter-terrorist financing measures in Pakistan - Mutual Evaluation Report - October 2019
Ratings – Effectiveness (1/3)
2
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Pakistan has
achieved this
objective
1. ML and TF risks are understood and, where appropriate,
actions co-ordinated domestically to combat ML and TF
Low
2. International co-operation delivers appropriate information,
financial intelligence, and evidence, and facilitates action
against criminals and their assets
Moderate
3. Supervisors appropriately supervise, monitor and regulate
financial institutions and designated non-financial
businesses and professions (DNFBPs) for compliance with
AML/CFT requirements commensurate with their risks.
Low
4. Financial institutions and DNFBPs adequately apply AML/CFT
preventive measures commensurate with their risks, and
report suspicious transactions.
Low
3. Anti-money laundering and counter-terrorist financing measures in Pakistan - Mutual Evaluation Report - October 2019 3
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Pakistan has
achieved this
objective
5. Legal persons and arrangements are prevented from misuse
for money laundering or terrorist financing, and information
on their beneficial ownership is available to competent
authorities without impediments
Low
6. Financial intelligence and all other relevant information are
appropriately used by competent authorities for money
laundering and terrorist financing investigations.
Low
7. Money laundering offences and activities are investigated
and offenders are prosecuted and subject to effective,
proportionate and dissuasive sanctions
Low
8. Proceeds and instrumentalities of crime are confiscated. Low
Ratings – Effectiveness (2/3)
4. Anti-money laundering and counter-terrorist financing measures in Pakistan - Mutual Evaluation Report - October 2019 4
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which
Pakistan has
achieved this
objective
9. Terrorist financing offences and activities are investigated
and persons who finance terrorism are prosecuted and
subject to effective, proportionate and dissuasive sanctions.
Low
10. Terrorists, terrorist organisations and terrorist financiers are
prevented from raising, moving and using funds, and from
abusing the non-profit sector.
Low
11. Persons and entities involved in the proliferation of weapons
of mass destruction are prevented from raising, moving and
using funds, consistent with the relevant United Nations
Security Council Resolutions.
Low
Ratings – Effectiveness (3/3)
5. Anti-money laundering and counter-terrorist financing measures in Pakistan - Mutual Evaluation Report - October 2019 5
Ratings – Effectiveness
6. 6
Ratings – technical compliance
(1/5)
September
2016
AML/CFT POLICIES AND COORDINATION
1. Assessing risks & applying a risk-based approach Part ParPa Pa Partially Compliant
2. National cooperation and coordination LargLarLarLar Largely Compliant
MONEY LAUNDERING AND CONFISCATION
3. Money laundering offence LargLarLarLar Largely Compliant
4. Confiscation and provisional measures LargLarLarLar Largely Compliant
TERRORIST FINANCING AND FINANCING OF PROLIFERATION
5. Terrorist financing offence LargLarLarLar Largely Compliant
6. Targeted financial sanctions related to terrorism & terrorist
financing Part ParPa Pa Partially Compliant
7. Targeted financial sanctions related to proliferation Part ParPa Pa Partially Compliant
8. Non-profit organisations Part ParPa Pa Partially Compliant
7. 7
Ratings – technical compliance
(2/5)
September
2016
PREVENTIVE MEASURES
9. Financial institution secrecy laws ComCo Co Co Compliant
Customer due diligence and record keeping
10. Customer due diligence Part Pa Pa Pa Partially Compliant
11. Record keeping LargLarLarLar Largely Compliant
Additional measures for specific customers and activities
12. Politically exposed persons Part Pa Pa Pa Partially Compliant
13. Correspondent banking LargLarLarLar Largely Compliant
14. Money or value transfer services Part Pa Pa Pa Partially Compliant
15. New technologies Part ParPa Pa Partially Compliant
16. Wire transfers LargLarLarLar Largely Compliant
8. 8
Ratings – technical compliance
(3/5)
September
2016
PREVENTIVE MEASURES (continued)
Reliance, Controls and Financial Groups
17. Reliance on third parties Part Pa Pa Pa Partially Compliant
18. Internal controls and foreign branches and subsidiaries Part Pa Pa Pa Partially Compliant
19. Higher-risk countries Part Pa Pa Pa Partially Compliant
Reporting of suspicious transactions
20. Reporting of suspicious transactions Part Pa Pa Pa Partially Compliant
21. Tipping-off and confidentiality Part Pa Pa Pa Partially Compliant
Designated non-financial Businesses and Professions (DNFBPs)
22. DNFBPs: Customer due diligence Non NonNo No Non Compliant
23. DNFBPs: Other measures Part ParPa Pa Partially Compliant
9. 9
Ratings – technical compliance
(4/5)
September
2016
TRANSPARENCY AND BENEFICIAL OWNERSHIP OF LEGAL
PERSONS AND ARRANGEMENTS
24. Transparency and beneficial ownership of legal persons Part ParPa Pa Partially Compliant
25. Transparency and beneficial ownership of legal arrangements Non NonNo No Non Compliant
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES
Regulation and Supervision
26. Regulation and supervision of financial institutions Part ParPa Pa Partially Compliant
27. Powers of supervisors Part ParPa Pa Partially Compliant
28. Regulation and supervision of DNFBPs Non NonNo No Non Compliant
Operational and Law Enforcement
29. Financial intelligence units Part ParPa Pa Partially Compliant
30. Responsibilities of law enforcement and investigative
authorities Part ParPa Pa Partially Compliant
31. Powers of law enforcement and investigative authorities Part ParPa Pa Partially Compliant
32. Cash couriers Part ParPa Pa Partially Compliant
10. 10
Ratings – technical compliance
(5/5)
September
2016
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES (continued)
General Requirements
33. Statistics Part Pa Pa Pa Partially Compliant
34. Guidance and feedback Part Pa Pa Pa Partially Compliant
Sanctions
35. Sanctions Part Pa Pa Pa Partially Compliant
INTERNATIONAL COOPERATION
36. International instruments LargLarLarLar Largely Compliant
37. Mutual legal assistance Part Pa Pa Pa Partially Compliant
38. Mutual legal assistance: freezing and confiscation Non NonNo No Non Compliant
39. Extradition LargLarLarLar Largely Compliant
40. Other forms of international cooperation Part ParPa Pa Partially Compliant
11. Anti-money laundering and counter-terrorist financing measures in Pakistan - Mutual Evaluation Report - October 2019 11
Ratings – technical compliance