The Federal Reserve Board on Thursday announced a $20.4 million penalty against the National Bank of Pakistan, a foreign bank operating in the United States and headquartered in Pakistan, for anti-money laundering violations. The Board will also require the firm to improve its anti-money laundering program.

As detailed in the consent cease and desist order against the National Bank of Pakistan, the firm's U.S. banking operations did not maintain an effective risk management program or controls sufficient to comply with anti-money laundering laws.


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US aid to Pakistan has a long political history and this is not the first time money has been withheld. Here we've pulled out all the figures for both US military aid and economic assistance (including development assistance) to Pakistan between 1948 and 2010.

This case out of the United States Attorney's Office for the Southern District of Florida exemplifies how BSA data can intersect with other criminal investigative techniques to paint a full picture of terrorism material support and other threat finance crimes. The case originated in 2008 with BSA data concerning an individual who was later convicted of conspiring to provide and providing material support to the Pakistani Taliban. The defendant funneled money to Pakistan as Taliban insurgents fought for greater control in northwest Pakistan. BSA data was critical in uncovering the diverse and complex methods the individual used to send money from the United States to Pakistan, each of which was designed to conceal and support his activities. Investigators uncovered at least three methods: 1) wire transfers from the United States to Pakistan, where an associate picked up and administered the funds; 2, transfers of funds from cashier's checks drawn on U.S. banks to a bank in Pakistan where co-conspirators could draw checks; and 3) bulk cash carried by family members and other travelers from the United States to Pakistan. SAR narratives helped explain how funds traveled from the United States to areas of Pakistan. The timing of this case proved extremely helpful in the fight against the Pakistan Taliban as important information gleaned from BSA records proved critical in obtaining other leads. The data led to subpoenas for bank and financial records (admissible evidence), alerted investigators to the use of wire transfers, and revealed the centrality of specific bank accounts to the scheme. This case demonstrates that BSA data, when taken with other resources at the disposal of law enforcement, can effectively disrupt terrorism support networks and mitigate other threats to public safety.

Pakistan is one of the countries that have ongoing problems with money laundering. In addition, financial crimes such as drug and human trafficking, corruption, and financing of terrorism are essential troubles for Pakistan. Pakistan has a defenseless and sensitive location for money laundering; they share the same geography with India, Iran, and China, which are essential players in the drug market. Also, their location is on the critical drug and human trafficking route.

According to the Anti-Money Laundering (AML) Act, the Financial Monitoring Unit (FMU) serves as Pakistan's designated Financial Intelligence Unit. Its main responsibility is to act as the central agency in charge of collecting and carefully reviewing Cash Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) that various reporting entities, including working firms, have submitted. Additionally, FMU is charged with the crucial duty of informing the appropriate investigative and supervisory authorities of pertinent financial information related to suspected proceeds of crime, alleged money laundering activities, and transactions associated with the financing of terrorism. Section 6 of the AML Act (Financial Monitoring Unit) authorizes the creation of the FMU.

The Anti-Terrorism Act of 2002: This law defines the offenses of financing terrorism and money laundering as well as the relevant legal framework and punishments. To increase the maximum penalties, it underwent an amendment in October 2004.

In 2007, Pakistan introduced the AML Ordinance, which laid down comprehensive regulations for combatting money laundering and the financing of terrorism. This ordinance criminalized money laundering and led to establishing the Financial Monitoring Unit (FMU), which serves as Pakistan's Financial Intelligence Unit (FIU). The FMU was entrusted with managing Suspicious Transaction Reports (STRs). In 2010, the State Bank of Pakistan (SBP) enacted the Anti-Money Laundering Act, supplanting the 2007 AML Ordinance as the country's primary legal framework governing anti-money laundering efforts.

Money laundering is a pressing issue in Pakistan, as it poses significant challenges to the country's financial stability and security. Pakistan's government and financial institutions are increasingly focused on implementing robust anti-money laundering measures to combat this threat. In response, Sanction Scanner provides innovative AML solutions powered by AI. These solutions offer a progressive strategy for enhancing financial integrity and help organizations effectively fulfill their AML obligations. We invite you to contact us or request a demo for an in-depth presentation if you want to delve into the future of AML compliance!

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In addition to challenges spending the money, as CGD staff have written in the past, it is difficult to know just how much money has been spent. According to figures in the most recent CRS report, between FY2010 and FY2012 approximately $2.2 billion of $4 billion appropriated for economic-related assistance was disbursed (including security-related assistance, just over $3 billion was disbursed in this time period).

Dr. Sania Nishtar: Over the past year, prior to when COVID-19 struck, Ehsaas had heavily invested time, money, energy, and effort in building the infrastructure to roll out multiple programs. As part of that infrastructure-building effort, we invested in digital capabilities. Three in particular came into play as we conceptualized and rolled out Ehsaas Emergency Cash.

Dr. Sania Nishtar: Once we pulled a thread through these three capabilities, we asked people to send us their identification numbers. They could fill out online applications, but largely we sought requests through an SMS short code. Once the identity numbers arrived on our servers, they would dip into different databases, and messages of eligibility would automatically generate. Individuals who were considered eligible would be sent SMS messages asking them to go on particular dates to payment sites to collect their money. They would go and queue up, and when they entered their biometric signatures, they would be enrolled into the program and be able to withdraw the money.

We want the Government to take immediate action by introducing sanction against any individuals from Pakistan guilty of illegal activities such as corruption and money laundering. It is widely reported that many individuals connected with Pakistan have obtained funds by illegal methods and invest it outside of their country, such as in the UK. The UK must not be a shelter for corrupt Pakistani politicians who flee to the UK, especially when they have been convicted by the courts of Pakistan.

Riyadh had already pledged the money but waited for the IMF deal to be announced before depositing it. Similarly, the UAE had promised support which helped Pakistan to convince the IMF that it had enough backing to fulfil its conditions to improve the balance of payments.

12:30 p.m. Pakistan Time


Pakistan Finance Minister Shaukat Aziz: Bismillahir Rehmanir Raheem


Ladies and gentlemen of the press, good afternoon. We have just finished the second session of the U.S.- Pakistan Joint Economic Forum, which covered a wide array of subjects, which I will share with you. After the press conference there will be a press release from our side telling you what was discussed, but essentially, we talked about, first, the reforms -- economic reforms -- in Pakistan and how the economy has done, updated the Secretary and his delegation on where we are in terms of macroeconomic performance. And as you know, the U.S. has an active economic assistance program for Pakistan and is also very helpful with the international financial institutions -- World Bank, IMF, ADB -- so we covered a detailed discussion of those various programs. In addition, we talked about our privatization programs, updated the Secretary on where we are on that, particularly because foreign direct investment is a major priority of the Government.


As you all know, the United States is the largest investor in Pakistan. Last year 67% of the foreign direct investment we had in Pakistan came from the U.S. -- over three hundred million dollars. And this year, as you know, our target is a billion dollars from foreign investment worldwide, and we are hoping that the United States will be a major contributor. In Pakistan, the U.S. companies are quite active in several areas, like oil and gas, beverages, pharmaceuticals and services. So we were trying to use this forum to see how we can expand the private-sector relationships. We've agreed that at the next forum meeting in Washington sometime next year, the private-sector representatives from both countries would participate. Also, we talked to the Secretary about availability of visas for our businessmen, and they were sure that is being looked at and the situation is getting better. We've also discussed market access, and there are some tactical issues, and there are some longer-term issues, particularly for textiles. And on the tactical side, we will hope to get some response from the United States fairly soon, so that our goods can move freely into the U.S. Naturally there are bigger issues on tariffs, etc., which will be dealt with.


We updated the Secretary on our anti-money laundering efforts, and I informed the Secretary that now in the Ministry of Finance, we have set up a single window to coordinate anti-money laundering policies, because many agencies of the government are involved: the State Bank, ICCP, the NAB, the law-enforcement agencies, Ministry of Interior, Ministry of Foreign Affairs. So we have tried to put everything together in one policy unit.


In addition, we discussed the poverty reduction programs and the USAID programs being conducted in Pakistan. The Secretary was kind enough to visit Khushali Bank this morning, and he met some of the borrowers himself of micro finance and we updated him on what we are doing on micro finance in Pakistan. He also visited a school today and saw the education programs going on, and we hope that the assistance we get from the U.S. on education will continue at the same level. Naturally during the day we've also talked about debt relief, and this came up last night also: that the U.S. is looking at a billion dollars of debt cancellation. That is in Congress at the moment, and I think Congress will soon be back, if it's not back already, so we hope in the next few months we get some positive reaction. But I understand it's in the process, as they say. So that's all brief opening statement. I request the Secretary to give his remarks and then we'll take four or five questions. Thank you very much.


Treasury Secretary O'Neill: Thank you. The Minister has done a perfect job of capturing the essence of our conversations, which I found very good in reinforcing in my own mind, the value of this Joint Forum that we began a year ago. I must say I'm very impressed with what the Minister and the President have been able to accomplish. When one looks at the progress, as captured by the economic indicators of change in the fiscal position of the government, and the progress that's being made, it's really quite impressive. And the clear commitment to keep going and to persevere in poverty reduction and opportunity creation for the people of Pakistan is very clear and expressed by many of the different people we were able to hear from in the Forum conversation this morning. And I think with that, then, maybe we can take a few questions.


Q. This is Hanif Khalid. My question is that, Mr. Secretary, don't you think 143 million dollars market access to Pakistan is not significant, especially for a country who is an economic giant and who is also the leader of the international coalition against terrorism while Pakistan has played the role of a front-line state in this campaign? Moreover, the list you have finalized about the exports includes those items which are not frequently tradable with America. My question is: will you agree, or will you review this list, and will America will increase the market access amount for Pakistan? Thank you.


A. Well, as the Minister indicated to you, there's a conversation going on, there's a consideration right now in Washington of quota limits, and I indicated to the Minister that we would, on our return to Washington, do what we can to hasten these conversations so that an answer can be provided to Pakistan as soon as possible. But I think in the broader sense, again, these forums are an indication of the dedication on both sides to furthering the economic relationship between the United States and Pakistan. And as the Minister indicated, it's true that the U.S. is already a substantial economic investor in Pakistan. And I think we need to work in both directions at the same time. In a broader sense President Bush and I, as well, are committed to the idea that in the best of possible worlds there are no trade and tariff barriers at all -- not some narrow limits on individual goods, but none at all. And with the enactment, last August now, of the so-called Trade Promotion Authority, we are, in the United States, in the process of working to give life to this idea that trade and tariff barriers should disappear. So we're working on an even bigger agenda than the one you suggest in your question.


Q: Yesterday you referred to the anti-terrorism efforts and any assets of the money, if involved in Pakistan, so how do you see the efforts of the Government of Pakistan, and your efforts, because a number of your agencies are working in Pakistan? How do you see that there is some money or some assets in Pakistan regarding that terrorism money? 


Secretary O'Neill: Well, first let me show you a book; I think this may be the first copy. This is a book called "Anti-Money-Laundering Measures: A Guide for Bankers," and it's published by the Institute of Bankers in Pakistan. You know, it's the first one that I have seen here in Pakistan. I have to tell you, it's the first one I've seen around the world. So I think maybe Pakistan is leading the world in talking internally to its own institutions about the importance of finding and confiscating tainted money. And I was really quite taken with the fact that the Central Bank Governor was able to give me this booklet and then talked in some depth this morning about the efforts that are being made. I think Pakistan has been doing a great job in this work, and it's very much appreciated. 


Minister Aziz: Let me just add here that we are getting assistance from the U.S. and other friendly countries on capacity-building, for upgrading our anti-money-laundering efforts. As I've said, we have this special unit, now created, which I announced today. And another area where we hope to get assistance from the United States, where the Secretary has been very kind, is Customs collaboration. We want to work to see what the latest techniques are in getting our Customs procedures better, and especially as it pertains to exports, because we ship lot of containers to the U.S. If we can do some screening in Karachi, then it will make our clearance of containers back in the US hopefully much faster. Now these have to be explored. Similarly for incoming goods: if we get the right equipment, these containers can then be x-rayed without opening them, so you know exactly what's inside, so: no mis-declaration of goods and all the other implications which follow from that. So in capacity-building and technical assistance from the United States, in Customs and in anti-money-laundering and many other fields, we've already received and we hope to receive more.


Q: A question for Secretary O'Neill to which Mr.Aziz may also wish to respond: in this broad discussion on economic issues, can you say to what extent a theme might have been that Pakistan's continued cooperation in curbing the flow of terror finances is having an effect and will have an effect on its economic future?


Secretary O'Neill: Well, I honestly don't think these are the same subject at all. I think on the one hand, identifying tainted money and capturing it is a subject to itself. But the broader theme of economic growth and development, I think, is in good hands here in Pakistan. I think with the President's encouragement, and with the Minister's obvious knowledge and standing in world as one of the front-rank financial people of our time, there's a dedication to establishing the framework and the goals for the public sector which will permit the private sector to thrive that is as good and strong as any that I know in the world. And I think real progress is being made in everything from improving the operation of the Securities and Exchange Commission to strengthening the financial systems and people that are working on financial issues in the country. So I think it's a very positive, growth-oriented story here in Pakistan, aimed at improving the circumstances of everyone in the country.


Minister Aziz: Let me just add that the dependence of Pakistan on remittances is quite significant. Three years ago we used to get a billion dollars a year. Then they doubled to two billion . Last year they were three billion and this year, if we are lucky, we could hit four billion. In the first quarter alone we got over a billion dollars in remittances from Pakistanis outside. So any effort, any global effort, which puts more money into official channels through the banking system rather than unofficial channels is music to our ears, because it benefits the economy of Pakistan; it benefits the people of Pakistan. And that is why we are very supportive of this effort. And there are other reasons, of course: we are part of the global effort against bad money finding a home, and Pakistan's economic benefit of getting our whole remittance business and funds flows into official channels is enormous. That's why it has extra significance to Pakistan and perhaps other countries. Let me also mention here that we have extensive reform, under the State Bank of Pakistan, of our exchange companies, which will also help direct money through official channels. So this is an important issue for all of us.


Q: Did you find any clue of the terrorist funding source, and how is Pakistan is helping in this regard?


Secretary O Neill: I think we have just said that there is a major effort underway and continuing in Pakistan to go after tainted money. And again, let me show you: here's a piece of evidence that is a home-grown effort but being made in collaboration with nations around the world who are all dedicated, I think now, to dealing with the issue of tainted money, finding bad people and capturing their money.


Q: You have talked about the funding for the terrorists, the tainted money which is in Pakistan. But a lot of tainted money from Pakistan has been going to the western countries in the form of bribes taken by officials; the politicians have a lot of money in western banks. And Pakistan wants all this tainted money back. So how can the international community help Pakistan in bringing back this money?


Secretary O'Neill: I don't know.


Minister Aziz: There are a lot of initiatives globally, and Pakistan is bilaterally exploring it.


Q: I would like to follow it with the setting up of the Financial Action Task Force which was operating out of France. So that task force has been dealing with all these aspects, and there are reports that the task force has now reduced its emphasis on the other forms of money laundered except for terrorism.


Secretary O'Neill: No, I think that is absolutely not true. As a matter of fact, I think these are all, in a way, one subject, and bad people who are breaking the law and doing evil things are evil for whatever reason. And I'm confident, from my own involvement in this work around the world, that people have a relentless attitude and thoroughness in what they're doing that didn't exist two years ago. And I think it is moving forward quite well. And I think it is moving forward quite well. You know, I gave you a sharp answer to your previous question. Let me tell you: money had been confiscated or actually frozen in the banks in New York and other places around the world related to the activity of the Taliban, and one of the things that it was possible to do after the Taliban was removed was to provide those frozen moneys to the provisional government of President Karzai, and now to President Karzai the elected President. And I think there is a similar dedication that where money is found and if it's due and owing to a legitimate government, nations of the world are committed to doing that.


Q: Secretary O'Neill, as you consult with Congress over the issue of debt relief for Pakistan, is the country's cooperation in the war on terrorism sufficient to warrant US support for more debt relief or, if not, what conditions would you like to see met before you would agree to offer more on debt relief?


Secretary O Neill: I don't think these are connected subjects. President Bush has indicated that he would seek action by the Congress in order to provide debt relief and there are no ifs, ands or conditions: the President made a commitment and he will pursue it.


Minister Aziz: Thank you, Mr. Secretary.


Secretary O'Neill: Thank you. 

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