In 2018, Pakistan was found lacking in its legislation in terms of criminalizing and targeting terrorism financing and money laundering through its domestic legal frameworks. As a result of these “structural deficiencies”, Pakistan was placed on the Financial Action Task Force’s (FATF) list of jurisdictions with enhanced monitoring – or the “grey list” – and was instructed to improve its legislative frameworks to align with international AML/CFT standards.
In February 2020, FATF had declared Pakistan “fully compliant” on 14 out of 27 points, with varying degrees of compliance on the remaining 13 targets.The AML/CFT watchdog also set a deadline to ensure compliance to the remaining targets – ending originally in June 2020, which was later extended to October 2020.
With the upcoming FATF plenary in October, RSIL has proactively charted legislative developments from 21st February 2020 onwards, when FATF announced its decision to retain Pakistan on the ‘grey list’, up to the time of writing. This article maps and analyzes recent and proposed legislation in time for the submission of Pakistan’s Progress Report to FATF on September 30, 2020.