In 2018, the Financial Action Task Force (FATF) placed Pakistan on its list of “Jurisdictions under Increased Monitoring” – or the ‘grey-list’ – citing ‘structural deficiencies’ that resulted in failure to effectively target terrorism financing and money laundering (TF/ML). In collaboration with the International Cooperation Review Group (ICRG), FATF issued a 27-Point Action Plan for Pakistan aimed at remedying these structural deficiencies.
Pakistan’s progress on its Action Plan was reviewed by FATF in its plenary on 23 October 2020. Efforts to remove its structural deficiencies and improve compliance with global Anti-Money Laundering/Countering Financing of Terrorism (AML/CFT) standards were acknowledged and Pakistan was found largely compliant on 21 of the 27 items of the Action Plan. However, it was retained on the FATF ‘grey-list’ pending further progress on the remaining points.
The objective of this paper is to identify the key legislative and administrative measures undertaken by Pakistan to comply with the FATF-ICRG Action Plan. This paper seeks to provide an objective, non-partisan overview of Pakistan’s progress from June 2018 to October 2020, highlighting outstanding areas flagged by FATF pending compliance as well as identifying the way forward in achieving all objectives under the Action Plan.