--- title: "Pakistan (PK) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/pakistan/ source_html: /jurisdictions/pakistan/index.html description: "Financial integrity intelligence for Pakistan (PK): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 5d2299ba381a8096f9d5ad8ea25f21f2fdb1bfe515192fe3c84a7d4759bfeaff generator: "fe-fleet/md-twin@1.0" --- # Pakistan (PK) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Pakistan PK Domains covered 8 of 8 Sources 173 Role actions 8 Horizon <90d 2 Jurisdiction profile FATF status: Compliant Tier: B Risk direction: Stable Enablement vs enforcement: Mixed Pakistan operates under the Anti-Money Laundering Act 2010 (as amended), with the Financial Monitoring Unit (FMU) as FIU, State Bank of Pakistan and SECP as sectoral AML/CFT supervisors, and a 2025-created Pakistan Virtual Assets Regulatory Authority (PVARA) for crypto. More Delisted from FATF grey list October 2022; remains in APG enhanced follow-up on residual technical-compliance gaps. Key deficiencies - Unsupervised/under-supervised hawala-hundi sector used for cross-border value transfer with Afghanistan and Iran - Low ML investigation-to-prosecution conversion and limited use of financial intelligence by law enforcement agencies (LEAs) - Beneficial ownership information held by SECP disclosed largely on-request rather than via open, interconnected public registry - Nascent virtual-asset supervisory capacity (PVARA) relative to already-high informal/grassroots crypto adoption - Persistent terrorist-financing risk from groups historically based in or transiting Pakistan (LeT/JuD, TTP, Haqqani Network, ISIS-Khorasan) via hawala, NPO abuse, and cash smuggling Recent developments (18m) - FATF February 2026 and June 2026 Plenaries confirm Pakistan remains off both the grey list and the high-risk call-for-action list - Pakistan Crypto Council formed March 2025; Pakistan Virtual Assets Regulatory Authority (PVARA) established July 2025 as the world's second dedicated VASP regulator after Dubai's VARA - Pakistan Crypto Council partnership with Trump family-linked World Liberty Financial announced May 2025, alongside plans for a Strategic Bitcoin Reserve - FMU-UNODC risk-scoring and STR-prioritisation modernisation workshops (December 2025, February 2026) supported by UK International Development funding - Pakistan launched its first National Action Plan to counter migrant smuggling (February 2026), formally engaging the national AML/CFT authority to disrupt smuggling-network finance - OFAC counter-terrorism designation (16 January 2026) named a Pakistani-national individual linked to a Houthi-connected petroleum trading network based in Dubai Brief ## Lead signal #### Lead Signal The defining development for Pakistan this cycle is a live Federal Investigation Agency case against mobile-wallet payment aggregators that the agency alleges channelled roughly PKR 119.93 billion toward six offshore gambling platforms through JazzCash and Easypaisa corporate wallet accounts. The case is notable less for its gambling subject matter than for its typology profile: investigators have flagged digital hawala activity and the possible use of USDT or other crypto channels, and the Foreign Exchange Regulation Act 1947 is cited as the statutory basis for treating the aggregator conduct as unauthorised payment-settlement channelling. JazzCash has closed or suspended more than one hundred aggregator accounts, and Easypaisa's merchant settlement channels have been delayed since early October 2026 with no restoration date announced, making this a payments-architecture disruption in its own right, independent of the case's eventual legal outcome. Read full brief #### Lead Signal The defining development for Pakistan this cycle is a live Federal Investigation Agency case against mobile-wallet payment aggregators that the agency alleges channelled roughly PKR 119.93 billion toward six offshore gambling platforms through JazzCash and Easypaisa corporate wallet accounts. The case is notable less for its gambling subject matter than for its typology profile: investigators have flagged digital hawala activity and the possible use of USDT or other crypto channels, and the Foreign Exchange Regulation Act 1947 is cited as the statutory basis for treating the aggregator conduct as unauthorised payment-settlement channelling. JazzCash has closed or suspended more than one hundred aggregator accounts, and Easypaisa's merchant settlement channels have been delayed since early October 2026 with no restoration date announced, making this a payments-architecture disruption in its own right, independent of the case's eventual legal outcome. Running alongside this enforcement track, and on a separate institutional path, Pakistan's National Executive Committee on AML-CFT approved, on 27 October 2026, two amendments to the Anti-Money Laundering Act, 2010: adding the Pakistan Virtual Assets Regulatory Authority to Schedule IV as a designated AML/CFT regulator for virtual-asset service providers, and raising the currency-transaction-report threshold from PKR 2 million to PKR 3 million. Both approvals await formal gazette notification before taking legal effect, and no primary notification document was retrieved confirming that step has occurred. #### Other Developments Predicate-offence expansion. The same NEC action reportedly adds Section 28 of the Pakistan Maritime Zones Act 2023, concerning maritime piracy, to AMLA Schedule I as a predicate offence, broadening the set of underlying crimes that can support a money-laundering charge under the Act. As with the other NEC approvals this cycle, this amendment has been approved at committee level but awaits statutory notification. Institutional architecture for virtual assets. The prospective PVARA Schedule IV inclusion would formalise what existing State Bank of Pakistan circulars have already begun to address operationally: segregation requirements between client money accounts and other account types held by virtual-asset service providers, and a dedicated foreign-exchange framework introduced via a new paragraph in the State Bank's Foreign Exchange Manual. Read together, the banking-sector circulars and the pending AMLA amendment describe a regulatory perimeter being built around virtual-asset activity from two directions: prudential and foreign-exchange control on one side, and AML/CFT reporting-entity status on the other. FATF standing. Pakistan remains outside the FATF grey list, having been removed in October 2022. No primary confirmation of the October 2026 plenary outcome for Pakistan was retrieved this cycle, so this status is carried forward from the last confirmed position rather than freshly verified. #### Cross-Monitor Connections The gambling-payments case sits at an intersection point that other monitors will recognize: a trade-based or payment-based money-laundering typology using mainstream domestic payment rails to move value to offshore destinations, with a secondary crypto-channel dimension that has not yet been substantiated through a primary case document. The institutional thread, by contrast, speaks to conventional AML architecture strengthening rather than typology discovery — raising reporting thresholds and adding regulatory perimeter around virtual-asset service providers are governance moves, not enforcement outcomes, and should be read as capacity-building rather than as evidence that illicit flows through virtual assets have been detected and addressed in Pakistan specifically. The juxtaposition is worth holding in mind: an active enforcement case is substantiating exactly the kind of payment-channel exploitation that the pending virtual-asset AML perimeter is designed to pre-empt, but the perimeter itself has not yet taken legal effect. #### Outlook Three things determine whether this cycle's signal consolidates into durable change rather than remaining a snapshot of parallel but unconnected developments. First, whether the Finance Division formally gazettes the AMLA Schedule IV, CTR-threshold and Schedule I amendments, converting committee-level NEC approval into binding law; this is a near-term, concrete marker to watch. Second, whether the FIA's Faisalabad Composite Circle case produces a primary charge-sheet or court filing that would substantiate the digital-hawala and crypto-channel allegations currently resting on secondary reporting. Third, whether JazzCash and Easypaisa restore the aggregator and merchant settlement capacity they have suspended, which will indicate whether the payment-sector response to this case is temporary remediation or a more lasting tightening of onboarding standards for payment aggregators. None of these three threads has resolved as of this record. Earlier periodic briefs (7) 4 Nov 2026 · fim-2026-11-01 #### Lead Signal The defining development for Pakistan is a live Federal Investigation Agency case against mobile-wallet payment aggregators that the agency alleges channelled roughly PKR 119.93 billion toward six offshore gambling platforms through JazzCash and Easypaisa corporate wallet accounts. The case is notable less for its gambling subject matter than for its typology profile: investigators have flagged digital hawala activity and the possible use of USDT or other crypto channels, and the Foreign Exchange Regulation Act 1947 is cited as the statutory basis for treating the aggregator conduct as unauthorised payment-settlement channelling. JazzCash has closed or suspended more than one hundred aggregator accounts, and Easypaisa's merchant settlement channels have been delayed since early October 2026 with no restoration date announced, making this a payments-architecture disruption in its own right, independent of the case's eventual legal outcome. Running alongside this enforcement track, and on a separate institutional path, Pakistan's National Executive Committee on AML-CFT approved, on 27 October 2026, two amendments to the Anti-Money Laundering Act, 2010: adding the Pakistan Virtual Assets Regulatory Authority to Schedule IV as a designated AML/CFT regulator for virtual-asset service providers, and raising the currency-transaction-report threshold from PKR 2 million to PKR 3 million. Both approvals await formal gazette notification before taking legal effect, and no primary notification document was retrieved confirming that step has occurred. #### Other Developments Predicate-offence expansion. The same NEC action reportedly adds Section 28 of the Pakistan Maritime Zones Act 2023, concerning maritime piracy, to AMLA Schedule I as a predicate offence, broadening the set of underlying crimes that can support a money-laundering charge under the Act. As with the other NEC approvals, this amendment has been approved at committee level but awaits statutory notification. Institutional architecture for virtual assets. The prospective PVARA Schedule IV inclusion would formalise what existing State Bank of Pakistan circulars have already begun to address operationally: segregation requirements between client money accounts and other account types held by virtual-asset service providers, and a dedicated foreign-exchange framework introduced via a new paragraph in the State Bank's Foreign Exchange Manual. Read together, the banking-sector circulars and the pending AMLA amendment describe a regulatory perimeter being built around virtual-asset activity from two directions: prudential and foreign-exchange control on one side, and AML/CFT reporting-entity status on the other. FATF standing. Pakistan remains outside the FATF grey list, having been removed in October 2022. No primary confirmation of the October 2026 plenary outcome for Pakistan was retrieved, so this status is carried forward from the last confirmed position rather than freshly verified. #### Cross-Monitor Connections The gambling-payments case sits at an intersection point that other monitors will recognize: a trade-based or payment-based money-laundering typology using mainstream domestic payment rails to move value to offshore destinations, with a secondary crypto-channel dimension that has not yet been substantiated through a primary case document. The institutional thread, by contrast, speaks to conventional AML architecture strengthening rather than typology discovery — raising reporting thresholds and adding regulatory perimeter around virtual-asset service providers are governance moves, not enforcement outcomes, and should be read as capacity-building rather than as evidence that illicit flows through virtual assets have been detected and addressed in Pakistan specifically. The juxtaposition is worth holding in mind: an active enforcement case is substantiating exactly the kind of payment-channel exploitation that the pending virtual-asset AML perimeter is designed to pre-empt, but the perimeter itself has not yet taken legal effect. #### Outlook Three things determine whether the signal consolidates into change rather than remaining a snapshot of parallel but unconnected developments. First, whether the Finance Division formally gazettes the AMLA Schedule IV, CTR-threshold and Schedule I amendments, converting committee-level NEC approval into binding law; this is a near-term, concrete marker to watch. Second, whether the FIA's Faisalabad Composite Circle case produces a primary charge-sheet or court filing that would substantiate the digital-hawala and crypto-channel allegations currently resting on secondary reporting. Third, whether JazzCash and Easypaisa restore the aggregator and merchant settlement capacity they have suspended, which will indicate whether the payment-sector response to this case is temporary remediation or a more lasting tightening of onboarding standards for payment aggregators. None of these three threads has resolved as of this record. 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Pakistan's financial-integrity picture is dominated by an institutional reform package rather than a single enforcement incident. The National Executive Committee on AML-CFT approved adding the Pakistan Virtual Assets Regulatory Authority to Schedule IV of the Anti-Money Laundering Act, 2010, positioning it as a designated AML/CFT regulator for virtual asset service providers. This step is a committee approval, not yet a statutorily effective change -- it still requires gazette notification before virtual asset service providers formally become reporting entities obliged to meet AML/CFT standards. In parallel, the same reform round raised the currency transaction reporting threshold that banks and other reporting entities must apply when reporting to the Financial Monitoring Unit, from PKR 2 million to PKR 3 million, and added maritime piracy under the Maritime Zones Act 2023 as a new predicate offence under AMLA Schedule I. All three elements sit at the same procedural stage: approved by the committee, pending formal notification. The architecture-over-incident reading is that Pakistan is extending the statutory perimeter of its AML/CFT regime to capture a sector -- virtual assets -- that had previously sat outside formal reporting-entity status, while simultaneously recalibrating reporting thresholds that affect the volume of suspicious and currency-transaction reporting flowing to the Financial Monitoring Unit. Both moves shift the structural boundary of the regime rather than resolving a single case. #### Other Developments A concurrent enforcement episode illustrates the risk the reform targets. The Federal Investigation Agency's Faisalabad Composite Circle traced transactions worth more than Rs119.93 billion linked to gambling applications, routed through mobile-wallet corporate accounts, with a first information report registered against eight individuals and eleven shell companies. Sources cited in the investigation flagged indicators consistent with digital hawala/hundi activity and possible use of USDT or other crypto channels, though these elements have not been substantiated by a retrieved charge sheet or primary case document. Pakistan's standing outside the FATF grey list continues without confirmed change. Pakistan was removed from the FATF grey list in October 2022, and no primary-source confirmation of the October 2026 plenary outcome for Pakistan was retrieved. #### Cross-Monitor Connections The gambling-payment aggregator investigation has a direct corridor into payments-system oversight, since the flows under examination moved through mobile-wallet corporate accounts rather than conventional banking rails -- a channel whose commercial and operational dimensions are more naturally the province of payments-sector monitoring than financial-integrity typology. The crypto/digital-asset regulatory extension (PVARA's prospective Schedule IV status) also connects to active-defence and compliance-technology questions for virtual asset service providers once reporting-entity obligations are formally notified, though no compliance-technology signal was found to develop that connection further. #### Outlook The near-term marker to watch is gazette notification of the Schedule IV and Schedule I amendments: until that occurs, PVARA's regulatory status over virtual asset service providers and the raised currency-transaction threshold remain administratively approved but not legally operative. Separately, the State Bank of Pakistan's existing requirement that virtual asset service providers maintain strict segregation between client money accounts and other account types, alongside the separate foreign-exchange framework introduced via Chapter 14 Para 11A, forms part of the regulatory scaffolding into which the prospective PVARA designation would fit once notified. Whether the FIA's gambling-linked investigation produces a substantiated charge sheet identifying the specific predicate conduct -- including the digital-hawala and crypto-channel indicators currently flagged but unproven -- is the second marker worth tracking. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal An enforcement action by Pakistan's Federal Investigation Agency against gambling-linked payment-aggregator flows has surfaced, as a secondary finding, evidence of USDT and cryptocurrency layering running through mobile-wallet channels. The FIA traced transactions exceeding PKR 119.93 billion linked to gambling applications moving through aggregators operated by JazzCash and Easypaisa, with JazzCash reported to have closed over one hundred affected accounts and Easypaisa settlements delayed. A separate first information report filed by the FIA's Composite Circle in Faisalabad names eight suspects connected to six online gambling platforms, and describes evidence of illegal money transfers, alleged layering, and digital hawala or hundi activity, alongside possible use of USDT and other crypto channels. The structural significance of this finding is not the gambling nexus itself but its timing: it lands squarely on top of Pakistan's newly-operative virtual-asset licensing perimeter, established by the Virtual Asset Services Regulations 2026 and the Activity Specific Regulations 2026, both of which took effect from 21 August 2026, with a transitional no-objection-certificate deadline of 5 September 2026 that has already passed. #### Other Developments Virtual-asset licensing transition now past its compliance deadline. Entities operating as virtual asset service providers before 5 March 2026 were required to obtain a certificate of no objection from the Pakistan Virtual Assets Regulatory Authority by 5 September 2026 or cease operations under section 70 of the governing Act. That deadline has passed, meaning any unlicensed virtual-asset activity identified from this point forward sits inside a defined non-compliance window rather than a regulatory grey area. The crypto-layering evidence surfacing in the gambling-payment probe has not yet been connected in the public record to any specific licensed or unlicensed virtual-asset entity, and no enforcement action under the new licensing regime has been reported this period. FATF grey-list status holds as at the most recently confirmed published list. Pakistan has remained off the Financial Action Task Force's increased-monitoring list since its removal in October 2022, and the most recently confirmed published list, dated June 2026, does not carry Pakistan. India has signalled intent to press for Pakistan's re-listing at the Financial Action Task Force's plenary meeting in Paris, but no confirmed outcome of that review had been located as at the time of this brief. The standing position is therefore unchanged on the public record, with a material forward-looking question still open. #### Cross-Monitor Connections The payment-aggregator enforcement action connects directly to the parallel monitoring of payment-system regulation in Pakistan, where the same account closures at JazzCash and Easypaisa are being tracked as the first visible enforcement materialisation of the State Bank of Pakistan's payment-intermediary tightening introduced in May 2026. The illicit-finance reading and the payment-system reading are two lenses on the same underlying enforcement event: one asks what the money-laundering exposure is, the other asks what it means for payment-intermediary supervision. The gambling nexus itself, including the specific platforms named in the Faisalabad filing, sits outside this analysis and belongs instead to gambling-sector monitoring; it is referenced here only insofar as it is the vector through which the layering evidence and the aggregator-closure evidence emerged. #### Outlook The clearest near-term marker to watch is the outcome of the Financial Action Task Force's October 2026 plenary review and whether Pakistan's off-list status is confirmed or disturbed. A second marker is whether any enforcement action under the new virtual-asset licensing regime follows from the crypto-layering evidence already surfaced in the gambling-payment investigation, which would be the first visible test of the Pakistan Virtual Assets Regulatory Authority's enforcement posture since its transitional compliance deadline passed. Absent a primary regulatory notice corroborating the PKR 119.93 billion transaction-value figure, that number should continue to be treated as press-sourced rather than confirmed. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Pakistan enters the current cycle with two structural tracks moving in opposite directions, both unresolved. On the one hand, the Securities and Exchange Commission of Pakistan has escalated enforcement of beneficial-ownership disclosure, issuing show-cause notices to 28,761 companies for failing to file Form-19 declarations of Ultimate Beneficial Ownership under Companies Act 2017 section 123A. On the other, India is reported to be pressing the Financial Action Task Force to return Pakistan to its increased-monitoring list at the October 2026 plenary, a decision that, if realised, would reverse a status Pakistan has held since removal from that list in October 2022. Neither development is settled. The SECP notices are enforcement in motion rather than enforcement concluded, and the FATF push is reported advocacy rather than an adopted plenary outcome. Together they frame a jurisdiction whose domestic transparency architecture is visibly tightening even as its external reputational position faces a renewed external challenge whose outcome will not be known until the plenary concludes. #### Other Developments Virtual-asset licensing continues its transitional build-out. The Pakistan Virtual Assets Regulatory Authority is reported to be moving toward issuance of its first full virtual-asset-service-provider licences in the fourth quarter of 2026, a step beyond the no-objection-certificate phase that has governed the sector since the Virtual Assets Act was enacted. Secondary reporting also describes a Travel Rule threshold set at the Pakistani-rupee equivalent of USD 1,000 under Regulation 100 of the Pakistan Virtual Asset Services Regulations 2026, though this figure rests on a single source and has not been corroborated against PVARA's own gazetted text. A supervisory sandbox opened without a parallel supervisory standard. The State Bank of Pakistan launched the second cohort of its Regulatory Sandbox on 2 October 2026, inviting applications through 30 November 2026 for artificial-intelligence, payments, and remittance innovations. No codified supervisory guidance addressing AI or machine-learning model risk in anti-money-laundering transaction monitoring accompanies this experimental track, leaving a gap between what the sandbox is testing and what supervisors would expect of a live deployment. #### Cross-Monitor Connections The virtual-asset licensing trajectory intersects directly with payments-market developments being tracked elsewhere: the same PVARA licensing regime and its Travel Rule threshold bear on how digital-asset service providers will interoperate with banking rails. The SECP beneficial-ownership enforcement action also has a corporate-structuring dimension relevant to any entity using Pakistani corporate vehicles in cross-border arrangements, a theme that recurs wherever enabler-jurisdiction analysis intersects with transparency enforcement elsewhere in the fleet. The AI-themed sandbox cohort is a compliance-technology signal worth watching alongside similar experimental tracks in other jurisdictions, particularly given the absence of a matching supervisory expectation. #### Outlook The FATF plenary decision in October 2026 is the single most consequential near-term event: a re-listing to increased monitoring would reintroduce correspondent-banking de-risking dynamics that Pakistan's financial sector experienced during its prior grey-list period, while a decision not to re-list would leave the current enablement posture undisturbed. Separately, SECP's enforcement escalation is likely to continue generating compliance activity among the thousands of companies now under notice, and the outcome of that process, whether driving mass compliance or mass deregistration, will be a material future signal for the beneficial-ownership register's practical effectiveness. On the crypto side, the transition from transitional no-objection certificates to full PVARA licences, as scheduled for the fourth quarter of 2026, will be the next structural marker worth confirming against a primary regulatory source once PVARA's own gazetted text becomes available. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Pakistan's crypto-regulatory perimeter completed its transition from statute to operative supervision this period. The Pakistan Virtual Assets Regulatory Authority's Virtual Asset Services Regulations, 2026 and Activity-Specific Regulations, 2026 entered force on 21 August 2026, the date of their gazette notification, establishing licensing, prudential, conduct, technology and AML/CFT/CPF standards for virtual-asset service providers under the Virtual Assets Act, 2026. The transitional No-Objection Certificate deadline for pre-existing VASPs, set under section 70 of the Act, passed on 5 September 2026; unlicensed operation of virtual asset services is now a criminal offence. Industry has limited track record under the new regime, and no licence grants or enforcement outcomes under it have yet been confirmed. #### Other Developments An alleged crypto-facilitated unlicensed betting network surfaced in the same window. The Federal Investigation Agency's Faisalabad circle registered a case against eight suspects alleging an unlicensed online-gambling network with a combined credit turnover of PKR 119.93 billion across eleven single-member companies, using bank, wallet and crypto or USDT channels and raising the possibility of digital hawala or hundi layering, proceeding under the Foreign Exchange Regulation Act and the Pakistan Penal Code. This rests on a single Tier-2 press source citing FIA officials; no primary FIA document has been located this period, capping confidence at probable. Pakistan's AML/CFT baseline remains stable and off both the FATF and EU high-risk lists. The Anti-Money Laundering Act, 2010, as amended, continues to anchor the regime, with the Financial Monitoring Unit as the designated financial intelligence unit under section 6, jointly supervised with the State Bank of Pakistan and the Securities and Exchange Commission of Pakistan. Pakistan exited FATF's increased-monitoring list in October 2022 and remains absent from FATF's 19 June 2026 list and from the European Union's consolidated high-risk third-country list as most recently amended by Delegated Regulations (EU) 2026/46 and (EU) 2026/83. #### Cross-Monitor Connections The FIA's Faisalabad enforcement action sits at the intersection of this monitor's crypto/digital-assets domain and the gambling-regulatory monitor's enforcement tracking, since the same alleged network and the same reported turnover figure are the subject of parallel reporting on each page; the legal basis differs by monitor only in emphasis, not in underlying fact. The newly operative PVARA licensing perimeter also intersects with the world-payments monitor's tracking of Pakistan's broader non-bank payments liberalisation, since a licensed VASP's banking access and a licensed EMI's banking access now both run through State Bank of Pakistan frameworks, albeit under different instruments. #### Outlook The period following the passed NOC deadline is the one to watch for this jurisdiction: whether PVARA begins issuing licences, denying applications, or taking enforcement action against operators that did not file a NOC application by 5 September 2026 will determine how the newly operative regime is actually applied in practice. Separately, whether a primary FIA charge-sheet or prosecution emerges from the Faisalabad case will determine whether the current probable-confidence enforcement signal can be upgraded, and whether the case in fact demonstrates coordinated use of crypto rails for unlicensed gambling-related financial flows at the scale alleged. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Pakistan enacted the Virtual Assets Act, 2026, converting the Pakistan Virtual Assets Regulatory Authority (PVARA) from a body first stood up by a July 2025 presidential ordinance into a permanent, statutory federal licensing and supervisory authority for virtual asset service providers. The Act carries criminal penalties for unlicensed operation and states an AML/CFT alignment objective, extending the designated-reporting perimeter to licensed VASPs. This is the most structurally significant financial-integrity development touching Pakistan this cycle: it closes what had been an unregulated crypto-laundering surface by establishing a licensing gate that did not previously exist. The gazetted statutory text of the Act was not directly retrieved this cycle, so the finding rests on PVARAs own published material and contemporaneous trade press rather than a primary legal text. Alongside the new licensing authority, the State Bank of Pakistan issued BPRD Circular Letter No. 10 of 2026, permitting bank accounts for PVARA-licensed virtual asset service providers. This reverses SBPs prior blanket 2018 ban on banks servicing crypto firms, but only for the newly licensed cohort, which means the reversal is conditioned entirely on the new licensing gate functioning as intended. #### Other Developments Pakistan remains off both FATF lists. Pakistan exited the FATF grey list in October 2022 and remains off both the increased-monitoring list and the blacklist as of the 19 June 2026 plenary. This is a stable-architecture finding rather than a new development, and it forms the backdrop against which the new VASP perimeter should be read: the reporting-entity extension to licensed VASPs sits within an AML/CTF framework that FATF has not flagged for deficiencies since 2022. A virtual-asset-zone designation remains only authorised, not exercised. The Virtual Assets Act, 2026 authorises PVARA to designate special virtual-asset zones intended to attract blockchain companies. As of the most recent secondary reporting available this cycle, no such zone has been designated. This is a forward-looking horizon item rather than an observed development, and its eventual exercise would extend Pakistans crypto-integrity perimeter further, in either a permissive or a more tightly supervised direction depending on how the zones are structured. #### Cross-Monitor Connections The crypto-perimeter closure under the Virtual Assets Act, 2026 is directly relevant to gambling-related illicit finance tracking: secondary commentary on the Act frames it explicitly as an instrument aimed in part at tracing illicit betting-linked crypto fund flows, rather than as any liberalisation of gambling policy, which remains prohibited under Pakistans separate gambling-prohibition framework. The SBP circular permitting bank access for licensed VASPs also bears on correspondent and domestic banking-sector exposure: banks that previously had no lawful channel to service crypto firms now have a conditional one, which shifts (without eliminating) the intermediation risk that had previously sat entirely outside the regulated banking perimeter. #### Outlook The near-term watch item is whether PVARA designates any virtual-asset zones, expected on current reporting around 2027-Q1, and whether the licensing regime under the new Act demonstrates operational capacity to actually license and supervise VASPs rather than existing only in statutory form. Pakistans stable FATF standing provides no near-term catalyst for renewed listing pressure, but the durability of the new VASP perimeters AML alignment claim has not been independently corroborated against a primary text this cycle, and that gap should be closed before the framework is treated as a settled compliance baseline. 21 Sep 2026 · fim-2026-08-21 #### Lead Signal Pakistan's Virtual Assets Act, 2026 is this cycle's dominant financial-integrity development for the jurisdiction. The statute converts the Pakistan Virtual Assets Regulatory Authority, PVARA, from a body created by presidential ordinance in July 2025 into a permanent statutory regulator, vesting it with licensing, AML/CFT, and sanctions-compliance powers over virtual-asset service providers, including exchanges, custodians, and token-issuance platforms. The enforcement backbone attached to this authority is explicit: fines of up to PKR 50 million and prison terms of up to five years for unlicensed operation. This is a High-confidence, T1-anchored finding, sourced directly to PVARA's own published material and corroborated by multiple independent crypto-trade-press outlets, which removes much of the single-source risk that often accompanies statutory-change claims in this jurisdiction. Read architecturally rather than as an isolated legislative event, the Virtual Assets Act closes what had previously been an undefined regulatory perimeter over a market that PVARA itself estimates runs into tens of millions of users. That closure matters specifically for financial-integrity purposes because the statute embeds AML/CFT and sanctions-compliance obligations directly into the design of VASP licensing, rather than leaving digital-asset activity to operate as an unsupervised channel outside any obliged-entity framework. Under a three-pillar reading that gives AML, CTF, and CPF findings equal analytical weight rather than defaulting to whichever generates the most enforcement volume, this is properly read as a CTF/CPF-relevant architectural gain as much as an AML one. Prior to this enactment, the absence of any licensing or AML/CFT obligation for VASPs operating in or into Pakistan was itself analytically significant under an enablement-as-signal reading: a large, estimated tens-of-millions-of-users market operating with no obliged-entity status represented a standing sanctions-evasion and money-laundering surface that this cycle's enactment is the first structural step toward closing. The statute is not yet fully operational — PVARA's own licensing portal is presently accepting NOC applications, with full exchange licensing described as forthcoming rather than live — so the correct characterisation this cycle is a materially strengthened statutory architecture, not yet a fully realised supervisory practice. #### Other Developments Beneficial-ownership disclosure shows a formally strengthened but practically unverified posture. The Securities and Exchange Commission of Pakistan states that it has established a Corporate UBO Registry and has proposed, via 2026 SRO 57(I), amendments to Regulation 92 of the Companies Regulations 2024 that would expand beneficial-interest and shareholding-pattern disclosure obligations. Independent reporting as of this cycle, however, finds no publicly searchable, centralised UBO register accessible to third parties. This is an Assessed-confidence finding resting on single-domain T3 corroboration; no T1 SECP register-status statement was located this cycle to independently confirm either the registry's existence in operational form or its accessibility. The gap between a stated registry and a practically searchable one is itself the analytically significant fact, and it is the kind of enablement-by-omission signal that a purely enforcement-volume-weighted reading would miss entirely. A beneficial-ownership regime that exists on paper, with supervisory rule-making in train, but that produces no publicly searchable interface, does not close the transparency gap that beneficial-ownership disclosure regimes exist to address; it instead produces a disclosure architecture whose practical utility to counterparties, investigators, or cross-border information-sharing partners cannot presently be verified. This is a structural finding, not an incident, and it should be weighted accordingly against the more visible statutory activity in the crypto domain. #### Cross-Monitor Connections The Virtual Assets Act 2026 finding routes directly to the Global Crypto Regulatory Monitor, which tracks the same enactment's licensing mechanics, token-classification provisions, and consumer-protection mandate in more granular form; this monitor's framing of the same statute is deliberately narrower, foregrounding only its AML/CFT and sanctions-compliance architecture rather than duplicating the crypto monitor's licensing-pathway analysis. No World Payments Monitor nexus is evidenced this cycle for either the beneficial-ownership or the crypto/digital-asset finding, and this cycle's claim set does not support a connection to state-capture, conflict-finance, or information-operations monitoring lines. Analysts tracking Pakistan across monitors should treat the crypto monitor as the authoritative source for VASP licensing mechanics and this monitor as the authoritative source for the AML/CFT and sanctions-compliance reading of the same underlying statute. #### Outlook The near-term question for the crypto and digital-assets domain is whether PVARA's transition from NOC-stage acceptance to full exchange licensing proceeds on a timeline consistent with this cycle's finding, and whether the AML/CFT and sanctions-compliance powers granted on the statute's face translate into an operating supervisory practice rather than remaining a dormant statutory capability. For beneficial ownership, the outlook hinges on whether the 2026 SRO 57(I) amendments and the stated Corporate UBO Registry produce an actual, publicly searchable interface. Absent that, the disclosure-versus-accessibility gap identified this cycle should be read as a standing structural weakness rather than a one-cycle anomaly, and it is the kind of gap that would only be resolved by a future T1 SECP statement on register operational status — precisely the kind of primary-source confirmation this cycle lacks. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Pakistan this cycle presents a country that clears every standing country-level sanctions and grey-list threshold while continuing to generate friction at the level of individual actors and unsupervised value-transfer corridors. Reading the position through a three-level sanctions-architecture lens, at the country level Pakistan remains off both the FATF grey list and the FATF high-risk call-for-action list as of the June 2026 Plenary, having exited the grey list in October 2022, and delegated regulations issued by the European Commission in December 2025 updating the high-risk third-country annex, Regulations (EU) 2026/46 and (EU) 2026/83, again confirm that Pakistan has not been re-added. Both signals point toward a jurisdiction judged, at the level of formal listing, to have addressed the technical deficiencies that once triggered enhanced monitoring. Continue reading At the scheme level, a different picture holds. On 16 January 2026 the U.S. Treasury Office of Foreign Assets Control added Pakistani national Imran Asghar, together with associated Dubai-based petroleum-trading entities, to the Specially Designated Nationals list under an Ansarallah, or Houthi-linked, network designation. The action targeted an individual and a corporate network operating through a Gulf trade hub rather than the jurisdiction itself, demonstrating that clean country-level status coexists with continuing exposure at the level of individual actors and cross-border trade-finance relationships tied to correspondent banking. At the architecture level, the persistent vulnerability remains the Pakistan-Afghanistan-Iran hawala and hundi corridor, an unsupervised value-transfer channel through which bulk cash smuggling into Afghanistan has been reported at up to several million US dollars per day. This finding is corroborated across a FATF and APG technical assessment, financial-press reporting, and the 2025 National Risk Assessment published by the United Kingdom, giving it a durable, structural character rather than the profile of a one-off event. It is this architecture, not any single designation, that keeps the country a live sanctions-evasion concern despite its clean formal status. Reading these three levels together, the strategic consequence is a divergence pattern in which enforcement targets nationals, networks and unsupervised corridors rather than the jurisdiction as a whole, which suggests that the country-clean status functions as a floor rather than a ceiling on financial-integrity risk. Firms with correspondent-banking or trade-finance exposure to Pakistan-linked flows face a picture in which the absence of a grey-list or high-risk-third-country designation does not remove the practical case for enhanced due diligence around individual counterparties, Gulf trade-hub intermediaries and the regional cash-based corridor. The obligation architecture already reflects this: the EU high-risk-third-country framework and OFAC screening obligations under Executive Order 13224 as amended operate as parallel, not substitute, layers of control, and a firm satisfying one does not thereby satisfy the other. This cycle also establishes, as a baseline finding, that Pakistan plays only a minimal and peripheral role in Russian sanctions-evasion architecture, with no evidence identified this cycle of Pakistan-based intermediaries materially servicing evasion beyond occasional discounted-crude interest and a yuan-settlement angle connected to Chinese intermediation. This negative finding is useful for calibrating relative risk: the sanctions-architecture concern specific to Pakistan is concentrated in the counter-terrorism-designation and hawala-corridor findings above, not in a Russia-facing evasion role. #### Outlook The next formal checkpoint is the October 2026 FATF Plenary, the scheduled review point for the residual technical-compliance ratings of Pakistan under APG enhanced follow-up; this is a monitoring-status checkpoint rather than a firm-specific event, and its outcome remains uncertain at this stage. Absent a fresh triggering event, the country-clean, individual-designated divergence pattern established this cycle is assessed as likely to persist as the baseline description of the sanctions-architecture posture of Pakistan into the second half of 2026, with the hawala and hundi corridor remaining the structural condition most likely to generate further individual-level designations of the kind seen in January 2026. The sanctions-regime-divergence pattern documented here is expected to remain the defining sanctions-architecture signal for this jurisdiction absent a change in either the FATF and EU country-level assessment or a materially different individual-designation pattern. Judgment: No material PK-specific sanctions-evasion signal identified this cycle; TBML/digital-hawala indicators in the FIA case are classified under D1 for the enforcement element. Uncertain #### Beneficial Ownership and Corporate Transparency Pakistan sits outside the direct perimeter of the EU AML Package, and the developments most directly relevant to its own beneficial-ownership and corporate-transparency exposure are domestic rather than European. The Securities and Exchange Commission of Pakistan administers beneficial-ownership information for companies and limited liability partnerships under a 25-percent-shareholding-or-effective-control definition, but discloses that information to foreign counterparts on a case-by-case basis through international-cooperation channels rather than through an open, interconnected public register. This is a structural transparency gap rather than an episodic lapse: it rests on a submission made directly by Pakistan to the UNCAC Secretariat in response to the questionnaire on beneficial-ownership and trust regimes, and no movement toward interconnection has been identified this cycle. Continue reading Layered onto that structural gap is an evidentiary gap at the enforcement layer. No fresh, independently verified senior-politically-exposed-person money-laundering enforcement action was identified for Pakistan within the eighteen-month review window; the most prominent precedent, the 2022 acquittal of Prime Minister Shehbaz Sharif and his son, predates that window. This is an absence-of-evidence finding rather than a positive determination, and it rests on a single secondary source, but it raises rather than resolves the question of whether elite-linked money-laundering enforcement functions as intended in Pakistan, a question that bears directly on the state-capture filter applied across this monitor coverage. For financial institutions and professional service firms handling Pakistan-linked corporate or fund structures, the request-driven beneficial-ownership disclosure model translates into a practical due-diligence burden: verification of ultimate beneficial ownership for Pakistani companies, limited liability partnerships and fund structures cannot rely on an interconnected public register and instead depends on the international-cooperation channel operated by the Securities and Exchange Commission of Pakistan on a case-by-case basis. This affects cross-sector and investment-firm exposure to Pakistani corporate and fund structures, and it compounds the same-jurisdiction gap in politically-exposed-person enforcement outcomes: a firm relying on both beneficial-ownership verification and adverse-media or enforcement-history screening currently has only a partial picture from either channel. Globally, the EU AML Package sets the structural direction against which beneficial-ownership regimes elsewhere are increasingly measured, even where it does not apply directly. The package now comprises three distinct instruments: the directly applicable AML Regulation, Regulation (EU) 2024/1624, which will apply from 2027; the sixth AML Directive, transposed on a per-Member-State basis; and the AMLA Regulation, Regulation (EU) 2024/1620, which establishes the Anti-Money Laundering Authority and shifts supervision of the highest-risk cross-border obliged entities from purely national authorities toward a hybrid EU-level regime of direct and indirect supervision. Pakistan, as a non-European-Economic-Area third country, sits outside this direct and indirect supervision perimeter, and 6AMLD per-Member-State transposition tracking is not applicable to it. Its only structural touchpoint with the European framework remains the EU high-risk third-country annex, from which it was removed in December 2022 and on which it remains absent through the December 2025 delegated-regulation updates. This backdrop is worth naming precisely because it illustrates the direction other jurisdictions are moving toward interconnected, supervised beneficial-ownership regimes, a direction against which the request-driven, non-public Pakistani model reads as comparatively opaque. Analysts should note that both structural findings in this domain rest on differing source strength: the beneficial-ownership disclosure model is drawn directly from the national submission of Pakistan to the UNCAC Secretariat, a national-primary source, while the enforcement-absence finding rests on a single secondary-tier report and should be read as raising, not settling, the underlying question. #### Outlook No dedicated Pakistan-specific beneficial-ownership reform was identified on the near-term regulatory horizon this cycle. The most relevant near-term checkpoint remains institutional rather than legislative: a National Strategy against Organized Crime, expected to be finalised in the second half of 2026, is described as covering money laundering alongside cybercrime and human smuggling, and its finalisation may shape the institutional coordination through which beneficial-ownership and enforcement gaps are eventually addressed. Absent a fresh senior-politically-exposed-person enforcement test case or a primary-source indication of movement toward an open beneficial-ownership register, the state-capture question flagged this cycle is assessed as remaining open rather than resolved into the next cycle. Judgment: No PK-specific beneficial-ownership development identified this cycle. Uncertain #### Enabler Jurisdictions The signal in this domain this cycle is not a classic enabler-jurisdiction finding of professional facilitators or corporate-service providers abroad, but a domestic channel that functioned in an enabling role: mobile-wallet aggregator onboarding gaps allowed offshore gambling-linked flows to move through corporate wallet accounts largely undetected until the Federal Investigation Agency traced more than Rs119.93 billion in transactions connected to gambling applications. The response so far has been remedial -- an investigation and a first information report against eight individuals and eleven shell companies -- rather than preventive, and no structural tightening of aggregator onboarding standards has been confirmed via primary source this cycle. Continue reading Sources close to the investigation flagged digital hawala/hundi indicators and possible use of USDT or other crypto channels as part of the fund movement, though these elements remain source-flagged rather than substantiated by a retrieved charge sheet. If accurate, this would describe a layering pattern in which informal value-transfer and digital-asset channels sit alongside regulated mobile-wallet rails as alternate routes for the same underlying flows -- a structurally significant pattern regardless of whether any single node is itself an offshore jurisdiction. #### Outlook The open question is whether the shell-company network named in the first information report has cross-border beneficial-ownership links that would bring a genuine foreign-enabler dimension into view, or whether the facilitation was purely domestic. No primary case document has yet been retrieved that would resolve this, and the gap is recorded as such rather than inferred. Judgment: No PK-specific enabler-jurisdiction development identified this cycle. Uncertain #### Conflict Finance and Extractive-Industry Integrity This cycle carries no dedicated Pakistan-specific extractive-industry or war-economy finding. The only conflict-finance-relevant material identified is a cross-reference from this monitor D3 enabler-jurisdiction and counter-terrorist-financing analysis: the financing of Lashkar-e-Tayyiba and its affiliate Jamaat-ud-Dawa, the Tehrik-i-Taliban Pakistan, the Haqqani Network and ISIS-Khorasan through hawala and hundi channels, non-profit-organisation abuse and criminal proceeds sustains armed-group activity along the Afghanistan-Pakistan frontier. That finding is classified primarily as a D3 and counter-terrorist-financing matter, corroborated by the UN 1267 Committee listing of Lashkar-e-Tayyiba and FATF terrorist-financing risk reporting, and it is surfaced here under the conflict-finance filter because the same financing channels that enable militant operational capability also sustain frontier armed-group activity more broadly. Continue reading Where this cross-reference is useful is in connecting the financial-integrity posture of Pakistan to conflict-finance monitoring focused on the broader Afghanistan-Pakistan frontier, in which the same informal value-transfer and non-profit-organisation-abuse channels described under the enabler-jurisdiction domain are the mechanism by which frontier armed-group financing is believed to occur, rather than a formal banking-sector or extractive-industry channel. No Pakistan-specific extractive-industry integrity finding, whether relating to mining, gemstones or other commodity-linked revenue streams, was identified this cycle. This is an honest coverage gap rather than a negative finding: it reflects the scope of research coverage this cycle rather than a determination that no such exposure exists. #### Outlook No dedicated Pakistan-specific conflict-finance or extractive-industry regulatory horizon item was identified this cycle. The domain will continue to be populated primarily through the conflict-adjacent cross-reference from the D3 militant-financing finding until a Pakistan-specific extractive-industry or war-economy finding is independently identified. Analysts using this brief for conflict-finance purposes should treat this domain, for Pakistan, as a cross-reference to D3 rather than a standalone assessment. Judgment: No PK-specific conflict-finance development identified this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Pakistan's crypto-regulatory architecture moved forward on 27 October 2026, when the National Executive Committee on AML-CFT approved adding the Pakistan Virtual Assets Regulatory Authority to Schedule IV of the Anti-Money Laundering Act, 2010, designating it an AML/CFT regulator for virtual-asset service providers. The approval remains pending statutory notification; no primary gazette text has been retrieved confirming legal effect as of this record, so the obligation should be read as adopted-in-principle rather than currently binding on VASPs. Once notified, the amendment would make virtual-asset service providers reporting entities under the Act, extending suspicious-transaction and related AML/CFT reporting obligations to the sector for the first time in a formal statutory sense. Continue reading This institutional step sits alongside operational groundwork already laid by the State Bank of Pakistan, whose circulars require strict segregation between client money accounts and other account types held by virtual-asset service providers, and introduce a dedicated foreign-exchange framework through a new paragraph inserted into the Foreign Exchange Manual. Separately, industry reporting describes a ten-category VASP licensing structure with minimum capital requirements under PVARA's regulatory framework, though this detail derives from a lower-tier secondary source rather than a primary instrument and should be weighted accordingly. The same cycle also produced a crypto-adjacent enforcement signal from a different direction: the Federal Investigation Agency's case against payment aggregators allegedly channelling gambling-linked funds to offshore platforms flagged possible use of USDT or other crypto channels alongside digital hawala activity. This is not a VASP-sector enforcement action as such, since the named respondents are payment aggregators rather than licensed or unlicensed virtual-asset businesses, but it illustrates the kind of flow that a notified PVARA AML/CFT perimeter is intended to bring into reporting scope. No primary FIA case document corroborates the crypto-channel element beyond secondary reporting. #### Outlook The central marker to watch is whether the Finance Division formally gazettes the AMLA Schedule IV amendment naming PVARA, which would convert committee-level approval into a binding reporting-entity obligation for virtual-asset service providers. Absent that notification, the current position is one of announced direction rather than operative law, and VASPs operating in or serving Pakistan have not yet acquired formal AML/CFT reporting-entity status. A secondary marker is whether any primary PVARA licensing text becomes available to confirm or correct the ten-category capital-requirement structure currently resting on a single lower-tier source. Judgment: NEC approval of PVARA's inclusion in AMLA Schedule IV extends AML/CFT reporting-entity status to virtual-asset service providers once notified. Probable #### Compliance Technology and Active Defence The financial-intelligence apparatus of Pakistan shows the clearest positive-trajectory signal in this brief this cycle. The Financial Monitoring Unit convened workshops in December 2025 and February 2026, with support from UNODC and the United Kingdom International Development programme, to redesign risk-scoring frameworks and explore machine-learning-assisted prioritisation of suspicious-transaction reports. This represents a move by the national financial-intelligence unit toward a more analysis-led, technology-enabled posture for suspicious-transaction-report triage, rather than a reliance on volume-based or purely rules-based screening. Continue reading The finding is held at an assessed rather than high confidence level: the underlying source is a UNODC programme narrative rather than a primary Financial Monitoring Unit publication, and while the workshops are corroborated as having occurred, the operational outcome, whether machine-learning-assisted risk scoring has been deployed into live suspicious-transaction-report triage, is not yet independently documented. This is an honest evidentiary distinction rather than a downgrade of the underlying significance: institutional intent and pilot activity are documented; operational deployment is not yet confirmed. This compliance-technology development sits in useful contrast to the digital-asset domain addressed separately in this brief, where the supervisory trajectory is assessed as worsening. Here, the trajectory is assessed as improving, reflecting institutional investment in analytical capability rather than a widening capacity gap. The two trajectories are not directly linked: the Financial Monitoring Unit risk-scoring pilot addresses suspicious-transaction-report triage generally, across all reporting sectors, rather than the specific virtual-asset-service-provider supervisory gap described under the crypto domain. More broadly, this development illustrates a pattern relevant across enabler-jurisdiction assessments generally: technology-enabled suptech and regtech adoption by a financial-intelligence unit can improve the analytical capacity of a jurisdiction faster than it can close underlying structural gaps, such as the hawala-corridor and beneficial-ownership-disclosure gaps documented elsewhere in this brief for Pakistan. The Financial Monitoring Unit pilot should therefore be read as a capability-building signal operating in parallel with, rather than as a resolution to, the structural enabler-jurisdiction and beneficial-ownership findings addressed under the other domains in this brief. The development also has cross-monitor relevance beyond this brief: the adoption of machine-learning-assisted risk scoring by a national financial-intelligence unit is a relevant data point for monitoring of artificial-intelligence governance in public-sector deployment, given the agentic and machine-learning dimension of the risk-scoring redesign described in the underlying source material. The pilot is relevant across the cross-sector and banking-sector reporting population that files suspicious-transaction reports with the Financial Monitoring Unit, since any recalibration of risk-scoring methodology affects which reports are prioritised for downstream investigative attention, with corresponding implications for the internal risk-scoring alignment of reporting entities over time. #### Outlook No independently verified operational deployment date or primary Financial Monitoring Unit publication describing the machine-learning-assisted risk-scoring framework was identified this cycle, and this remains the principal gap constraining a higher confidence assessment. The most relevant near-term development to watch is whether a primary regulatory or Financial Monitoring Unit source documents actual deployment of the redesigned risk-scoring framework into live suspicious-transaction-report triage, which would allow this finding to be upgraded from assessed to high confidence. Absent that, the improving trajectory identified this cycle should be read as institutional intent and pilot-stage activity rather than a completed capability upgrade. Firms with suspicious-transaction-reporting obligations in Pakistan should treat the current pilot as an early-stage signal rather than a settled methodology change, and should not yet assume that reporting thresholds or triage priorities have shifted in practice. Judgment: No PK-specific RegTech/compliance-technology development identified this cycle. Uncertain #### AML/CTF Regime Pakistan's National Executive Committee on AML-CFT approved, on 27 October 2026, two amendments to the Anti-Money Laundering Act, 2010: raising the currency transaction report threshold reported by banks and other reporting entities to the Financial Monitoring Unit from PKR 2 million to PKR 3 million, and adding Section 28 of the Pakistan Maritime Zones Act 2023, concerning maritime piracy, to Schedule I as a new predicate offence. Both changes await formal gazette notification before taking legal effect; no primary Finance Division notification text was retrieved confirming that step has occurred, so the current status is committee-level approval rather than operative law. The same approval package included the Schedule IV inclusion of the virtual-asset regulator PVARA as a designated AML/CFT regulator, addressed in full under the digital-assets reading of this cycle's signal. Continue reading Against this institutional-strengthening backdrop, a live Federal Investigation Agency case illustrates the kind of flow the regime is designed to catch. The FIA's Faisalabad Composite Circle registered a First Information Report against eight individuals and eleven shell companies over approximately PKR 119.93 billion in transactions allegedly routed through JazzCash and Easypaisa corporate wallet accounts to six named offshore gambling platforms. The FIR cites the Foreign Exchange Regulation Act, 1947, and investigators have identified patterns consistent with digital hawala activity and possible USDT or other crypto-channel use. The architectural significance of this case for the AML/CFT regime lies less in its gambling subject matter than in its typology: it is a trade- or payment-based laundering pattern using mainstream domestic payment rails to move substantial value to offshore destinations, surfacing precisely the kind of exposure that a raised reporting threshold and an expanded predicate-offence list are meant to address from the regulatory side, even as the specific case proceeds independently through criminal process. On the standing international-standing marker, Pakistan remains outside the FATF grey list, having been removed in October 2022; no primary confirmation of the October 2026 plenary outcome for Pakistan was retrieved this cycle, so this status is carried forward rather than freshly verified this cycle. #### Outlook The principal near-term marker is formal gazette notification of the CTR-threshold increase and the Schedule I predicate-offence addition, which would convert committee approval into binding reporting obligations for banks and other reporting entities. A secondary marker is whether the FIA case produces a primary charge-sheet or court filing substantiating the digital-hawala and crypto-channel allegations, which currently rest on consistent but secondary reporting rather than a primary instrument. Judgment: CTR reporting threshold raised 50% (PKR 2m to 3m) and a new predicate offence (maritime piracy) added to AMLA Schedule I; both pending gazette notification. Probable Judgment: No commercial transaction involving a financial-integrity-infrastructure firm in Pakistan was evidenced this cycle. Uncertain Regulatory horizon Proposed 2026-Q4 · ±quarter ### FATF October 2026 plenary decision on Pakistan's monitoring status If India's push succeeds, Pakistan would return to FATF increased monitoring, with associated correspondent-banking de-risking implications reported historically. [Financial Action Task Force (FATF) Source](https://lawstreet.co/international/india-to-push-fatf-to-grey-list-pakistan-again-at-october-plenary) Adopted 2026-Q4 · ±quarter ### AMLA amendment: PVARA added to Schedule IV; CTR threshold raised to Rs3m; Maritime Zones Act s.28 added to Schedule I Once notified, PVARA becomes a designated AML/CFT regulator, VASPs become reporting entities, and the general CTR threshold rises 50% to PKR 3 million. [Source](https://www.dawn.com/news/2040341/ceiling-for-reporting-suspicious-bank-transactions-raised-to-rs3m) Proposed 2027-Q1 · ±half_year ### PVARA 'virtual asset zones' designation Potential creation of designated low-friction operating zones for blockchain/VASP business, extending PK's crypto-integrity perimeter further. [PVARA Source](https://www.theblock.co/post/392665/pakistan-parliament-passes-virtual-assets-act-formalizing-crypto-regulatory-authority) 3 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### A live FIA case and a pending AMLA amendment both touch payment and virtual-asset reporting exposure. The FIA case against payment aggregators flags digital hawala and crypto-channel indicators within a probable-confidence structured finding, while the pending PVARA Schedule IV inclusion and CTR threshold increase would, once notified, extend formal reporting-entity obligations to virtual-asset service providers and raise the currency-transaction reporting bar for existing reporting entities. 3 evidence refs Compliance ### Reporting-entity perimeter for virtual-asset service providers is approved but not yet notified. The Schedule IV amendment naming PVARA and the CTR threshold increase have cleared committee-level approval but await gazette notification; policy functions should track whether this converts to a binding obligation rather than treating it as currently in force. 2 evidence refs Legal ### The FIA case cites the Foreign Exchange Regulation Act 1947 as the statutory basis for aggregator liability. Counsel assessing exposure for payment intermediaries with Pakistan-linked flows should note the FIR's accessory-liability framing under the Foreign Exchange Regulation Act 1947, and that no primary case document has yet been retrieved to confirm the full scope of charges. 1 evidence refs Board ### A payment-rail disruption affecting Pakistan's two largest mobile-wallet providers is material to any Pakistan-linked payment exposure. JazzCash and Easypaisa, which together dominate domestic payment settlement, have both been disrupted following FIA scrutiny, with no restoration date announced; this is a market-infrastructure event with potential relevance beyond the specific gambling-linked case that triggered it. 1 evidence refs CTO ### Virtual-asset infrastructure in Pakistan faces a prospective formal AML/CFT reporting perimeter. Technical teams supporting virtual-asset operations with Pakistan exposure should track the pending PVARA Schedule IV notification, which would impose reporting-entity obligations, alongside existing State Bank of Pakistan segregation requirements for client money accounts. 1 evidence refs Risk ### A trade/payment-based laundering typology using mainstream mobile-wallet rails to reach offshore platforms is now evidenced at scale. The FIA case, involving roughly PKR 119.93 billion in alleged flows, exemplifies a typology risk functions should weigh when assessing exposure concentration in Pakistan-linked payment corridors, particularly given the flagged digital hawala and crypto-channel indicators. 1 evidence refs Operations ### Aggregator account closures and merchant settlement delays affect operational processing through JazzCash and Easypaisa. Operations teams relying on JazzCash or Easypaisa settlement should account for over one hundred aggregator account closures and ongoing merchant settlement delays with no announced restoration date. 1 evidence refs Audit ### Evidentiary gaps remain on both the enforcement case and the AML-regime amendments. No primary FIA case document and no primary Finance Division gazette notification have been retrieved this cycle; audit scope should note that current reporting on both threads rests on secondary sources pending primary-instrument confirmation. 3 evidence refs Scenario sketches ### Notification consolidates the AML perimeter around virtual assets In this illustrative sketch, the Finance Division gazettes the AMLA Schedule IV, CTR-threshold and Schedule I amendments within the current quarter. Virtual-asset service providers operating in or toward Pakistan acquire formal reporting-entity status, and the raised CTR threshold and broadened predicate-offence list take effect across the banking sector. Payment aggregators, already under scrutiny from the live FIA case, face a compounding compliance burden as both the payments-enforcement and virtual-asset-AML tracks converge on the same underlying typology of value moving offshore through domestic rails. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No material PK-specific signal this cycle. T2 · EU AML Package / AMLA no_change Not applicable to PK (non-EEA). T3 · FATF Grey List no_change Pakistan remains off the FATF grey list (removed Oct 2022); Oct 2026 plenary outcome for PK not confirmed via primary source this cycle. T4 · Beneficial-Ownership Register Status no_change No PK-specific BO registry development identified this cycle. T5 · Crypto & Digital-Asset Integrity material_change PVARA's prospective inclusion in AMLA Schedule IV extends AML/CFT reporting-entity status to VASPs, pending notification. T6 · Sanctions Regime Divergence no_change No PK-specific sanctions-divergence signal identified this cycle. Registers ### Enforcement actions - 16 Jan 2026 - 10 Dec 2025 - 18 Feb 2026 - 1 Dec 2025 - 25 Sep 2026 - 9 Oct 2026 - 9 Oct 2026 - OFAC issued a Specially Designated Global Terrorist (SDGT) designation naming a Pakistani-national individual, based in Dubai, linked to a petroleum-trading network supporting Houthi (Ansarallah) financing, as part of a wider counter-terrorism designation package. 16 Jan 2026 - FMU convened a two-day Risk Scoring and STR Prioritization workshop in Karachi to redesign risk-scoring frameworks and explore machine-learning-assisted analytics for suspicious transaction report triage, moving the FIU toward a more analysis-led, technology-enabled model. 10 Dec 2025 - Pakistan launched its first National Action Plan to counter migrant smuggling, establishing a PM-chaired Task Force and sub-committee that formally engages the national Anti-Money Laundering and Counter Financing of Terrorism Authority and financial institutions to disrupt the financial lifelines of smuggling networks, alongside cooperation with INTERPOL, Europol and Frontex. 18 Feb 2026 - APG's follow-up review process to Pakistan's 2019 Mutual Evaluation was updated in the current cycle (latest procedural update recorded December 2025), keeping Pakistan in enhanced follow-up reporting against outstanding technical-compliance recommendations rated partially/largely compliant. 1 Dec 2025 ### Sanctions changes - 16 Jan 2026 - 4 Dec 2025 - OFAC's 16 January 2026 counter-terrorism designation package added a Pakistani-national individual (Imran Asghar) and associated Dubai-based petroleum-trading entities to the SDN list under the Ansarallah/Houthi-linked network designation. 16 Jan 2026 - The European Commission's December 2025 delegated regulations (EU 2026/46 and EU 2026/83) updating the high-risk third-country AML/CFT annex did not add Pakistan, consistent with its December 2022 delisting; Pakistan remains off both the EU HRTC annex and the FATF grey list as of the June 2026 FATF Plenary. 4 Dec 2025 ### Regulatory horizon (register) - UK ECCTA 2023 failure-to-prevent-fraud offence — standing horizon watch - UK ECCTA 2023 failure-to-prevent-fraud offence — standing horizon watch - PVARA 'virtual asset zones' designation - PVARA VASP licensing regime in force - PVARA full VASP licensing (beyond transitional NOCs) - FATF October 2026 plenary decision on Pakistan's monitoring status - FATF October 2026 Plenary review of Pakistan - AMLA amendment: PVARA to Schedule IV, CTR threshold to Rs3m - AMLA amendment: PVARA added to Schedule IV; CTR threshold raised to Rs3m; Maritime Zones Act s.28 added to Schedule I - PVARA VASP licensing rollout for global/local exchanges - Next FATF/APG Plenary review of Pakistan's follow-up status - Finalisation of Pakistan's National Strategy against Organized Crime ### Active schemes - [HIGH] Afghanistan-Iran-Pakistan hawala/hundi and bulk-cash corridor - [CRITICAL] Militant group financing via hawala, NPOs and criminal proceeds - Rapid crypto embrace outpacing nascent VASP supervision - SECP beneficial-ownership disclosure gap for companies/LLPs Sources - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofpakistan.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofpakistan.html) - [https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [https://www.mondaq.com/money-laundering/1808758/out-of-the-shadows-but-watching-the-fatf-horizon-pakistan-fatf-and-the-ever-present-risk-of-the-grey-list](https://www.mondaq.com/money-laundering/1808758/out-of-the-shadows-but-watching-the-fatf-horizon-pakistan-fatf-and-the-ever-present-risk-of-the-grey-list) - [https://www.knowyourcountry.com/country-reports/pakistan/](https://www.knowyourcountry.com/country-reports/pakistan/) - [https://pvara.gov.pk/](https://pvara.gov.pk/) - [https://www.theblock.co/post/392665/pakistan-parliament-passes-virtual-assets-act-formalizing-crypto-regulatory-authority](https://www.theblock.co/post/392665/pakistan-parliament-passes-virtual-assets-act-formalizing-crypto-regulatory-authority) - [https://www.nation.com.pk/12-Jan-2026/secp-s-reforms-boost-company-registrations-enhance-business-transparency](https://www.nation.com.pk/12-Jan-2026/secp-s-reforms-boost-company-registrations-enhance-business-transparency) - [https://globallawexperts.com/secp-amendments-pakistan/](https://globallawexperts.com/secp-amendments-pakistan/) - [https://www.businessdataguide.com/blog/jurisdictions/pakistan-company-search-guide](https://www.businessdataguide.com/blog/jurisdictions/pakistan-company-search-guide) - [https://citadel365.com/blogs/fatf-june-2026-update-grey-list-and-black-list-changes/](https://citadel365.com/blogs/fatf-june-2026-update-grey-list-and-black-list-changes/) - [https://sigma.world/news/cambodia-anti-gambling-drive-fatf-grey-list/](https://sigma.world/news/cambodia-anti-gambling-drive-fatf-grey-list/) - [https://fincrimecentral.com/pakistan-imf-anti-money-laundering-reform-2026/](https://fincrimecentral.com/pakistan-imf-anti-money-laundering-reform-2026/) - [https://www.pvara.gov.pk/about](https://www.pvara.gov.pk/about) - [https://www.coindesk.com/policy/2026/04/15/pakistan-lifts-seven-year-ban-allowing-banks-to-service-virtual-asset-providers](https://www.coindesk.com/policy/2026/04/15/pakistan-lifts-seven-year-ban-allowing-banks-to-service-virtual-asset-providers) - [https://mofa.gov.pk/pakistan-exits-fatfs-grey-list](https://mofa.gov.pk/pakistan-exits-fatfs-grey-list) - [https://na.gov.pk/uploads/documents/69aae92ebf61c_955.pdf](https://na.gov.pk/uploads/documents/69aae92ebf61c_955.pdf) - [https://www.fmu.gov.pk/laws/](https://www.fmu.gov.pk/laws/) - [https://www.fbr.gov.pk/Targeted-financial-sanctions-screening/152366/152886](https://www.fbr.gov.pk/Targeted-financial-sanctions-screening/152366/152886) - [https://www.nation.com.pk/23-Aug-2026/pvara-launches-virtual-asset-licensing-regime](https://www.nation.com.pk/23-Aug-2026/pvara-launches-virtual-asset-licensing-regime) - [https://www.fatf-gafi.org/en/countries/detail/Pakistan.html](https://www.fatf-gafi.org/en/countries/detail/Pakistan.html) - [https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [https://www.mofa.gov.pk/anti-money-laundering-counter-terrorism](https://www.mofa.gov.pk/anti-money-laundering-counter-terrorism) - [https://pvara.gov.pk/licensing](https://pvara.gov.pk/licensing) - [https://www.dawn.com/news/2032406](https://www.dawn.com/news/2032406) - [https://lawstreet.co/international/india-to-push-fatf-to-grey-list-pakistan-again-at-october-plenary](https://lawstreet.co/international/india-to-push-fatf-to-grey-list-pakistan-again-at-october-plenary) - [https://www.nation.com.pk/04-Sep-2026/secp-issues-show-cause-notices-28-761-companies](https://www.nation.com.pk/04-Sep-2026/secp-issues-show-cause-notices-28-761-companies) - [https://www.secp.gov.pk/wp-content/uploads/2026/04/Press-Release-21-April-_compressed.pdf](https://www.secp.gov.pk/wp-content/uploads/2026/04/Press-Release-21-April-_compressed.pdf) - [https://www.techjuice.pk/pakistan-regulates-virtual-assets-in-15-months-pvara-briefs-pm/](https://www.techjuice.pk/pakistan-regulates-virtual-assets-in-15-months-pvara-briefs-pm/) - [https://profit.pakistantoday.com.pk/2026/10/03/sbp-launches-second-regulatory-sandbox-cohort-for-ai-payments-innovations](https://profit.pakistantoday.com.pk/2026/10/03/sbp-launches-second-regulatory-sandbox-cohort-for-ai-payments-innovations) - [https://namescan.io/coverages/pakistan](https://namescan.io/coverages/pakistan) - [https://www.fmu.gov.pk/docs/FrequentlyAskedQuestions-CTR.pdf](https://www.fmu.gov.pk/docs/FrequentlyAskedQuestions-CTR.pdf) - [https://www.cryptoverselawyers.io/pvara-post-licensing-compliance/](https://www.cryptoverselawyers.io/pvara-post-licensing-compliance/) - [https://outlookindia.com/international/pakistan-lists-masood-azhar-as-most-wanted-terrorist-in-2026-red-book-in-bid-to-avoid-fatf-grey-list](https://outlookindia.com/international/pakistan-lists-masood-azhar-as-most-wanted-terrorist-in-2026-red-book-in-bid-to-avoid-fatf-grey-list) - [https://propakistani.pk/2026/10/08/fia-intensifies-crackdown-on-online-gambling-and-digital-payments/](https://propakistani.pk/2026/10/08/fia-intensifies-crackdown-on-online-gambling-and-digital-payments/) - [https://license.aiying.cc/en/global-compliance/pakistan-pvara-september-5-vasp-licensing-deadline-2026/](https://license.aiying.cc/en/global-compliance/pakistan-pvara-september-5-vasp-licensing-deadline-2026/) - [Dawn](https://www.dawn.com/news/2040341/ceiling-for-reporting-suspicious-bank-transactions-raised-to-rs3m) - [ProPakistani](https://propakistani.pk/2026/10/27/pakistan-gets-new-power-to-block-crypto-linked-terror-financing/) - [The Express Tribune](https://tribune.com.pk/story/2637966/expanding-aml-powers-promise-and-pitfalls) - [Profit by Pakistan Today](https://profit.pakistantoday.com.pk/2026/10/28/pakistan-approves-revised-cash-transaction-reporting-thresholds-brings-pvara-under-anti-money-laundering-framework) - [Mondaq](https://www.mondaq.com/money-laundering/1808758/out-of-the-shadows-but-watching-the-fatf-horizon-pakistan-fatf-and-the-ever-present-risk-of-the-grey-list) - [ProPakistani](https://propakistani.pk/2026/10/08/fia-intensifies-crackdown-on-online-gambling-and-digital-payments/) - [Dawn](https://www.dawn.com/news/2032406) - [State Bank of Pakistan](https://www.sbp.org.pk/circulars/bprd-circular-letter-no-10) - [FPM AML Check](https://fpmamlcheck.com/vasp/pvara-regulations/) - [State Bank of Pakistan](https://www.sbp.org.pk/circulars/fe-circular-no-01-of-2026) - [https://www.dawn.com/news/2040341/ceiling-for-reporting-suspicious-bank-transactions-raised-to-rs3m](https://www.dawn.com/news/2040341/ceiling-for-reporting-suspicious-bank-transactions-raised-to-rs3m) - [https://propakistani.pk/2026/10/27/pakistan-gets-new-power-to-block-crypto-linked-terror-financing/](https://propakistani.pk/2026/10/27/pakistan-gets-new-power-to-block-crypto-linked-terror-financing/) - [https://tribune.com.pk/story/2637966/expanding-aml-powers-promise-and-pitfalls](https://tribune.com.pk/story/2637966/expanding-aml-powers-promise-and-pitfalls) - [https://profit.pakistantoday.com.pk/2026/10/28/pakistan-approves-revised-cash-transaction-reporting-thresholds-brings-pvara-under-anti-money-laundering-framework](https://profit.pakistantoday.com.pk/2026/10/28/pakistan-approves-revised-cash-transaction-reporting-thresholds-brings-pvara-under-anti-money-laundering-framework) - [Pakistan](https://www.fatf-gafi.org/en/countries/detail/Pakistan.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Countries / Jurisdictions](http://www.fatf-gafi.org/countries/#Pakistan) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [FATF](https://www.fatf-gafi.org/en/home.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Jurisdictions under Increased Monitoring - 21 February 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html) - [Mutual Evaluation of Pakistan](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofpakistan.html) - [News](https://www.fatf-gafi.org/en/the-fatf/news.html) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Home | Office of Foreign Assets Control](https://ofac.treasury.gov/) - [Counter Terrorism Designations and Designation Update | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260116) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions) - [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service) - [FinCEN Alert on the Use of Front Companies...](https://www.fincen.gov/system/files/2026-05/FinCEN-Alert-IRGC.pdf) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Key Changes in FinCEN’s Proposed Rule to Refocus AML/CFT Programs on](https://www.fincen.gov/system/files/2026-04/Key-Changes-Program-NPRM.pdf) - [Mutual Evaluation of Pakistan](https://www.fatf-gafi.org/en/documents/documents/mutualevaluationofpakistan.html) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Countering the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-3) - [Advisory on the FATF–Identified Jurisdictions with AML/CFT Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/advisory-fatf-identified-jurisdictions-amlcft-deficiencies) - [FinCEN Proposes Rule to Fundamentally Reform Financial Institution Programs Designed to Fight Illicit Finance | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-proposes-rule-fundamentally-reform-financial-institution-programs) - [Pakistan's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/fur-pakistan-2022.html) - [FATF publishes new Guidance on Financial Inclusion and Anti-Money Laundering and Terrorist Financing Measures](https://www.fatf-gafi.org/en/publications/Financialinclusionandnpoissues/guidance-financial-inclusion-aml-tf-measures.html) - [2025 Crypto Adoption and Stablecoin Usage Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2025-crypto-adoption-and-stablecoin-usage-report) - [Pakistan Plans to Legalize Crypto in Bid for Foreign Investment - Bloomberg](https://www.bloomberg.com/news/articles/2025-03-20/pakistan-plans-to-legalize-crypto-in-bid-for-foreign-investment) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [PWG Report on Digital Assets: Building Crypto’s Future Together](https://www.chainalysis.com/blog/pwg-report-digital-assets-building-the-future-of-crypto-july-2025/) - [2025年暗号資産規制総まとめ](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up-japanese/) - [Crypto Adoption Accelerates in APAC Region](https://www.chainalysis.com/blog/asia-pacific-crypto-adoption-2025/) - [Virtual Assets](https://www.fatf-gafi.org/en/topics/virtual-assets.html) - [FATF urges stronger global action to address Illicit Finance Risks in Virtual Assets](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2025.html) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Elliptic's 2026 regulatory and policy outlook: 5 crypto trends to expect in 2026](https://www.elliptic.co/blog/regulatory-and-policy-crypto-trends-to-except-in-2026) - [LASHKAR-E-TAYYIBA | Security Council](https://main.un.org/securitycouncil/en/sanctions/1267/aq_sanctions_list/summaries/entity/lashkar-e-tayyiba) - [The role of Hawala and other similar service providers in money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Role-hawalas-in-ml-tf.html) - [fatf REPORT THE ROLE OF HAWALA AND OTHER SIMILAR SERVICE PROVIDERS](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Role-of-hawala-and-similar-in-ml-tf.pdf) - [Comprehensive Update on Terrorist Financing Risks FATF REPORT July 2025](https://www.fatf-gafi.org/content/dam/fatf-gafi/publications/Comprehensive-Update-on-Terrorist-Financing-Risks-2025.pdf.coredownload.inline.pdf) - [APG-Mutual-Evaluation-Report-Pakistan-October 2019. ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/APG-Mutual-Evaluation-Report-Pakistan-October%202019.pdf.coredownload.inline.pdf) - [CTED Trends Tracker Evolving Trends in the Financing of Foreign Terrorist](https://www.un.org/securitycouncil/ctc/sites/www.un.org.securitycouncil.ctc/files/cted_trends_tracker_evolving_trends_in_the_financing_of_foreign_terrorist_fighters_activity_2014_-_2024.pdf) - [Fatf-gafi](https://www.fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/APG-Mutual-Evaluation-Report-Pakistan-October%202019.pdf) - [FATF report highlights evolving terrorist financing risks and warns of gaps in global understanding of the threats](https://www.fatf-gafi.org/en/publications/Methodsandtrends/comprehensive-update-terrorist-financing-risks-2025.html) - [1 BY OPIATE TRAFFICKERS AND MIGRANT SMUGGLERS The Hawala System](https://www.unodc.org/documents/data-and-analysis/AOTP/Hawala_Digital.pdf) - [July 2025 National Risk Assessment of Money Laundering and](https://assets.publishing.service.gov.uk/media/6877be59760bf6cedaf5bd4f/National_Risk_Assessment_of_Money_Laundering_and_Terrorist_Financing_2025_FINAL.pdf) - [Pakistan's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-pakistan-2022.html) - [Pakistan Advances National Strategy against Organized Crime](https://www.unodc.org/copak/en/PR/pakistan-advances-national-strategy-against-organized-crime.html) - [Pakistani PM and Son Acquitted From Money Laundering Case | OCCRP](https://www.occrp.org/en/news/pakistani-pm-and-son-acquitted-from-money-laundering-case) - [Pakistan's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-pakistan-2019.html) - [High-Risk Jurisdictions subject to a Call for Action - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-october-2025.html) - [Dollars Smuggled From Pakistan Provide Lifeline for the Taliban - Bloomberg](https://www.bloomberg.com/news/articles/2023-02-06/dollars-smuggled-from-pakistan-provide-lifeline-for-the-taliban) - [Understanding illicit financial flows in migrant smuggling](https://www.unodc.org/unodc/en/frontpage/2025/December/understanding-illicit-financial-flows-in-migrant-smuggling.html) - [Afghanistan](https://www.fatf-gafi.org/en/countries/detail/Afghanistan.html) - [FATF REPORT Financial flows linked to the production and trafficking of](https://fatf-gafi.org/media/fatf/documents/reports/Financial-flows-linked-to-production-and-trafficking-of-afghan-opiates.pdf) - [1 UNODC Roadmap for Afghanistan and Neighbouring Countries 2025 - 2027](https://www.unodc.org/coafg/uploads/documents/UNODC_Roadmap_for_Afghanistan_2025-2027_endorsed.pdf) - [FATF REPORT Money Laundering and Terrorist Financing Risks Arising from](https://www.fatf-gafi.org/content/dam/fatf/documents/ML-TF-Risks-Arising-from-Migrant-Smuggling.pdf) - [International Narcotics Control Strategy Report Volume II Money Laundering](https://syntheticdrugs.unodc.org/uploads/syntheticdrugs/res/library/cybercrime_html/US_International_Narcotics_Control_Strategy_Report_Money_Laundering.pdf) - [Pakistan launches first National Action Plan to counter migrant smuggling](https://www.unodc.org/unodc/en/news/2026/February/pakistan-launches-first-national-action-plan-to-counter-migrant-smuggling.html) - [Tracking illicit financial flows linked to human trafficking and migrant smuggling](https://www.unodc.org/unodc/human-trafficking/Webstories2023/tracking-illicit-financial-flows-linked-to-human-trafficking-and-migrant-smuggling.html) - [PAKISTAN’S INPUT ON UNCAC QUESTIONNAIRE ON BENEFICIAL OWNERSHIP INFORMATION](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2022-November-7-11/Pakistan_Responses_to_Questionnaire_on_BOT_Regimes_EN.pdf) - [Guidance on Beneficial Ownership and Transparency of Legal Arrangements](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html) - [Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/) - [TRANSPARENCY INTERNATIONAL - PAKISTAN](https://assets.publishing.service.gov.uk/media/57a08cbbe5274a31e00013de/8350-par.pdf) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Guidance on Transparency and Beneficial Ownership](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Transparency-and-beneficial-ownership.html) - [Explainer: removing the veil of secrecy and understanding beneficial ownership transparency](https://www.unodc.org/unodc/en/frontpage/2024/September/explainer_-removing-the-veil-of-secrecy-and-understanding-beneficial-ownership-transparency.html) - [Financial Crimes Enforcement Network U.S. Department of the Treasury](https://www.fincen.gov/system/files/shared/BOI_Small_Compliance_Guide.v1.1-FINAL.pdf) - [FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us?twclid=2-5rnrr590r1kru5w3p1iak11ok) - [Strengthening Financial Intelligence and Legal Cooperation to Combat Terrorism](https://www.unodc.org/copak/en/Stories/SP4/strengthening-financial-intelligence-and-legal-cooperation-to-combat-terrorism.html) - [Strengthening Pakistan’s financial monitoring through robust risk analysis](https://www.unodc.org/copak/en/Stories/SP2/strengthening-pakistans-financial-monitoring-through-robust-risk-analysis.html) - [Conference on Navigating the Future of AML: Sustaining Solutions for Financial Integrity'](https://www.unodc.org/copak/en/Stories/SP2/conference-on-navigating-the-future-of-aml_-sustaining-solutions-for-financial-integrity.html) - [UNPDF | Strengthening Counter-Terrorism Efforts through Mutual Legal Assistance, International Cooperation, and Financial Intelligence | United Nations](https://www.un.org/en/unpdf/strengthening-counter-terrorism-efforts-through-mutual-legal-assistance--international-cooperation--and-financial-intelligence) - [The Financial Monitoring Unit launches a new Data Center to tackle money laundering and terrorism financing](https://www.unodc.org/copak/en/Stories/SP2/the-financial-monitoring-unit-launches-a-new-data-center-to-tackle-money-laundering-and-terrorism-financing.html) - [` 3rd Follow-Up Report Mutual Evaluation of Pakistan July 2021](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/APG-3rd-Follow-Up-Report-Pakistan-2021.pdf.coredownload.inline.pdf) - [Enhancing the Use of Financial Intelligence and Law Enforcement Feedback](https://www.unodc.org/copak/en/Stories/SP2/enhancing-the-use-of-financial-intelligence-and-law-enforcement-feedback.html) - [GUIDANCE FOR A RISK-BASED APPROACH EFFECTIVE SUPERVISION AND ENFORCEMENT BY](https://www.fatf-gafi.org/media/fatf/documents/reports/RBA-Effective-supervision-and-enforcement.pdf) - [1 The Financial Crimes Enforcement Network (FinCEN) is](https://www.fincen.gov/system/files/advisory/2020-11-06/FATF%20October%202020%20Advisory%20FINAL%20508.pdf) - [Office of Foreign Assets Control - Sanctions Programs and Information | Office of Foreign Assets Control](https://ofac.treasury.gov/office-of-foreign-assets-control-sanctions-programs-and-information) - [Non-Proliferation Designations and Designation Update | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251001) - [Non-Proliferation Designations; Iran-related Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250514) - [1 DEPARTMENT OF STATE DEPARTMENT OF THE TREASURY DEPARTMENT OF COMMERCE](https://ofac.treasury.gov/media/47751/download) - [Counter Terrorism Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20180731) - [Sanctions List Search Tool | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-search-tool) - [Archive of Changes to OFAC's Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/specially-designated-nationals-list-sdn-list/archive-of-changes-to-the-sdn-list) - [Iran Ballistic Missile Procurement Advisory](https://ofac.treasury.gov/media/932206/download?inline=) - [United Nations Security Council Consolidated List | Security Council](https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Crypto regulatory affairs: US Crypto Week delivers as GENIUS Act becomes law, CLARITY Act moves to Senate](https://www.elliptic.co/blog/crypto-regulatory-affairs-us-crypto-week-delivers-as-genius-act-becomes-law-clarity-act-moves-to-senate) - [Anti-money laundering: Council adopts rules which will make crypto-asset transfers traceable - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2023/05/16/anti-money-laundering-council-adopts-rules-which-will-make-crypto-asset-transfers-traceable/) - [Watch Pakistan Aims to be Crypto Capital of South Asia - Bloomberg](https://www.bloomberg.com/news/videos/2025-03-20/pakistan-aims-to-be-crypto-capital-of-south-asia-video) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [Landmark cryptocurrency legislation passes US House, to be signed into law by President Trump - ICIJ](https://www.icij.org/news/2025/07/landmark-cryptocurrency-legislation-passes-u-s-house-to-be-signed-into-law-by-president-trump/) - [Pakistan Keen to Pay for Russian Crude Oil Imports With Chinese Yuan - Bloomberg](https://www.bloomberg.com/news/articles/2023-05-10/pakistan-keen-to-pay-for-russian-crude-oil-imports-with-chinese-yuan) - [Chinese Independent Refiner Buys Russian Oil at Deep Discount After Sanctions](https://www.bloomberg.com/news/articles/2025-12-15/chinese-teapot-buys-russian-oil-at-deep-discount-after-sanctions) - [Watch India Confirms It Lost Fighter Jets in Recent Pakistan Conflict - Bloomberg](https://www.bloomberg.com/news/videos/2025-05-31/india-confirms-it-lost-fighter-jets-in-pakistan-conflict-video) - [EU agrees to permanently stop Russian gas imports and phase out Russian oil - European Commission Representation in Cyprus](https://cyprus.representation.ec.europa.eu/news/eu-agrees-permanently-stop-russian-gas-imports-and-phase-out-russian-oil-2025-12-03_en) - [Russia’s Oil Plunges to $34 as US Sanctions Spark Huge Discounts - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-22/russia-s-oil-plunges-to-34-as-us-sanctions-spark-huge-discounts) - [Estimating the impact of sanctions on Russia’s war efforts - GOV.UK](https://www.gov.uk/government/publications/estimating-the-impact-of-sanctions-on-russias-war-efforts/estimating-the-impact-of-sanctions-on-russias-war-efforts) - [Russian Oil Supply to India Set to Fall to near Zero After US Sanctions: Sources - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-23/russian-oil-supply-to-india-set-to-fall-to-near-zero-sources) - [Russia Oil Prices to India Dip on Sanctions, Threats, Kpler Says - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-07/russia-oil-prices-to-india-dip-on-sanctions-threats-kpler-says) - [Russian Oil Offered to India at Deep Discount After US Sanctions](https://www.bloomberg.com/news/articles/2025-11-24/russian-oil-offered-to-india-at-deep-discount-after-us-sanctions) - [Frequently Asked Questions - Newly Added | Office of Foreign Assets Control](https://ofac.treasury.gov/faqs/added/2025-01-10) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [Anti-money laundering: the Commission updates its list of high-risk third-country jurisdictions to strengthen the international fight against financial crime - Finance](https://finance.ec.europa.eu/news/anti-money-laundering-commission-updates-its-list-high-risk-third-country-jurisdictions-strengthen-2022-12-20_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council by identifying high-risk third countries with strategic deficiencies (Text with EEA relevance) (c. 1675)](https://www.legislation.gov.uk/eur/2016/1675/2020-07-09/data.xht?view=snippet&wrap=true) - [Commission Delegated Regulation (EU) 2018/1467 of 27 July 2018 amending Delegated Regulation (EU) 2016/1675 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council, as regards adding Pakistan to the table in point I of the Annex (Text with EEA relevance) (c. 1467)](https://www.legislation.gov.uk/eur/2018/1467/data.xht?view=snippet&wrap=true) - [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/en/countries/detail/Pakistan.html) - [Asia/Pacific Group on Money Laundering (APG) / FATF](https://www.fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/APG-Mutual-Evaluation-Report-Pakistan-October%202019.pdf) - [FATF / APG](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-pakistan-2022.html) - [U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)](https://ofac.treasury.gov/recent-actions/20260116) - [Securities and Exchange Commission of Pakistan (SECP), via UNCAC Secretariat/UNODC](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2022-November-7-11/Pakistan_Responses_to_Questionnaire_on_BOT_Regimes_EN.pdf) - [European Commission (DG FISMA)](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [United Nations Office on Drugs and Crime (UNODC)](https://www.unodc.org/unodc/en/news/2026/February/pakistan-launches-first-national-action-plan-to-counter-migrant-smuggling.html) - [TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2025-crypto-adoption-and-stablecoin-usage-report) - [Organized Crime and Corruption Reporting Project (OCCRP)](https://www.occrp.org/en/news/pakistani-pm-and-son-acquitted-from-money-laundering-case) - [UK HM Treasury / Home Office (National Risk Assessment)](https://assets.publishing.service.gov.uk/media/6877be59760bf6cedaf5bd4f/National_Risk_Assessment_of_Money_Laundering_and_Terrorist_Financing_2025_FINAL.pdf) Coverage gaps fim-int-2026-07-05-G001: No independently-verified fifth-rou… fim-int-2026-07-05-G001: No independently-verified fifth-round FATF Mutual Evaluation (with virtual-asset effectiveness scope) has yet been scheduled for Pakistan, limiting assessment of whether APG enhanced follow-up will conclude or extend. [resolved] fim-int-2026-07-05-G002: No dedicated UK gov.uk HRTC notice … fim-int-2026-07-05-G002: No dedicated UK gov.uk HRTC notice for Pakistan was independently re-verified this cycle; the assumption that the UK MLR list mirrors the EU/FATF non-listing rests on inference rather than a primary UK source. [resolved] fim-int-2026-07-05-G003: No fresh OCCRP/ICIJ-documented seni… fim-int-2026-07-05-G003: No fresh OCCRP/ICIJ-documented senior-PEP AML enforcement action was identified for Pakistan within the 18-month window, preventing assessment of whether elite-linked AML enforcement has changed direction since the 2022 Sharif acquittal. [resolved] fim-int-2026-07-05-G004: PVARA's licensing pipeline (applica… fim-int-2026-07-05-G004: PVARA's licensing pipeline (applications received, licences issued, enforcement against unlicensed exchangers) has not yet been documented by a primary regulatory source, limiting assessment of the pace of the D5 supervisory build-out. [resolved] fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No PK-specific D3 (enabler jurisdiction) finding located this cycle; awaiting primary source. [resolved] fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No PK-specific D4 (conflict finance) finding located this cycle; awaiting primary source. [resolved] fim-int-2026-08-20-G003: Tier D watch jurisdictions Laos, Me… fim-int-2026-08-20-G003: Tier D watch jurisdictions Laos, Mexico, Colombia returned no fresh cycle-specific material and require priority search next cycle. [resolved] fim-int-2026-08-20-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G004 ({'scheme': 'financial_integrity', 'value': 'D6'}): SBP-linked AI transaction-flagging claim for D6 is unverified at T1/T2; only cited by trade press this cycle. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1 (sanctions-evasion architecture) was not researched this PK-bound cycle; no sourced finding exists to confirm no-change. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2 (beneficial ownership register status) was not researched this PK-bound cycle. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 (enabler jurisdictions) and D4 (conflict finance) were not researched this PK-bound cycle. [resolved] fim-int-2026-09-28-G004: Tier D watch jurisdictions (KH, LA,… fim-int-2026-09-28-G004: Tier D watch jurisdictions (KH, LA, MX, CO) were not checked this cycle as part of the standing mandatory sweep. [resolved] fim-int-2026-09-28-G005 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G005 ({'scheme': 'financial_integrity', 'value': 'D5'}): The gazetted statutory text of the Virtual Assets Act, 2026 was not directly retrieved; reliance is on PVARA's own site and trade press. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No T1 text of PVARA's implementing AML/CFT regulations under the Virtual Assets Act 2026 was retrieved; licence-category AML detail rests on T2/T3 commentary only. [resolved] fim-int-2026-10-04-G002: Tier D watch jurisdictions (KH/LA/M… fim-int-2026-10-04-G002: Tier D watch jurisdictions (KH/LA/MX/CO) were not separately re-swept this cycle; pooled research budget was allocated to bound JID PK. [resolved] fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Tier-1 SECP gazette text was retrieved for the beneficial-ownership S.R.O.s themselves; sourced from Tier-3 commentary only. [resolved] fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No FIA press release, charge-sheet or gazette notice was retrieved for the Faisalabad betting-network case; confidence capped at Probable pending primary-source verification. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1 sanctions-architecture, D2 beneficial-ownership and D3 enabler-jurisdiction dated developments within the Oct 4-11 window were not located given the search budget available; D3 flagged awaiting_primary_source rather than asserted stable. [resolved] fim-int-2026-10-11-G003: Tier D jurisdiction searches (KH/LA… fim-int-2026-10-11-G003: Tier D jurisdiction searches (KH/LA/MX/CO) were out of scope for this single-JID Pakistan dispatch and were not reached. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No FATF primary plenary statement for October 2026 was retrievable as of dispatch date; the re-listing push finding rests on T2/T3 press reporting only. [resolved] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No PVARA primary-source (pvara.gov.pk) text was directly retrieved; findings on licensing timelines and capital requirements rest on secondary T3 law-firm/press reporting. [resolved] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No FIA/SBP primary notice or gazette instrument was retrieved to corroborate the PKR119.93bn payment-aggregator figure; all reporting rests on T2/T3 press. [resolved] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): FATF October 2026 plenary outcome for Pakistan is not confirmed; D1/D3/D4/D6 show thin coverage this cycle for this jurisdiction. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No primary Finance Division notification or gazette text was retrieved confirming the AMLA Schedule IV/CTR threshold amendments have taken legal effect. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): No primary FIA case document (charge sheet) was retrieved confirming the TBML/digital-hawala and crypto-channel elements of the gambling-payments enforcement case. [open] fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): Tier D jurisdiction coverage (KH/LA/MX/CO) and the FATF October 2026 plenary outcome for Pakistan were not researched this cycle because the dispatch was scope-bound to Pakistan alone. [open] FIM-GAP-001 (D3): Pakistan's law-enforcement agencies contin… FIM-GAP-001 (D3): Pakistan's law-enforcement agencies continue to show low conversion of money-laundering investigations into prosecutions and limited operational use of FMU-generated financial intelligence, a deficiency identified in the 2019 APG Mutual Evaluation that remains unresolved in the December 2025 Follow-Up Report, which keeps Pakistan in enhanced follow-up with 38 Recommendations still rated only compliant/largely compliant. FIM-GAP-002 (D1): The hawala/hundi sector operating across t… FIM-GAP-002 (D1): The hawala/hundi sector operating across the Pakistan-Afghanistan-Iran corridor remains largely outside effective AML/CFT supervision, with bulk cash smuggling into Afghanistan estimated at millions of dollars daily, a structural vulnerability flagged by FATF/APG and reiterated in the UK's 2025 National Risk Assessment identifying Pakistan as a hawala source jurisdiction. FIM-GAP-003 (D5): PVARA and the Pakistan Crypto Council were… FIM-GAP-003 (D5): PVARA and the Pakistan Crypto Council were only established in 2025 and are still building licensing, supervisory and enforcement capability, while informal/grassroots crypto adoption in Pakistan is already among the highest globally relative to economic size. FIM-GAP-004 (D2): No fresh (within the 18-month review windo… FIM-GAP-004 (D2): No fresh (within the 18-month review window) OCCRP/ICIJ-documented major politically-exposed-person money-laundering enforcement action was identified for Pakistan; the most prominent recent precedent (the 2022 acquittal of PM Shehbaz Sharif and his son in a $200m money-laundering case) predates the window, leaving the current baseline unable to test whether elite-linked AML enforcement has changed direction. ## Evidence #### Confidence-tiered claims Ten VASP licence categories (exchange, custody, broker-dealer, advisory, lending/borrowing, derivatives, asset management, transfer/settlement, issuance, mining-related), each with activity-specific AML/CFT requirements. [[Source 1]](#sec-sources) Probable · 1 source Anti-Money Laundering Act, 2010, s.6 establishes the FMU as Pakistan's FIU. [[Source 1]](#sec-sources) Probable · 1 source Off the FATF grey list since October 2022, through the February 2026 plenary. [[Source 1]](#sec-sources) Probable · 1 source S.R.O. 328(I)/2026 and S.R.O. 57(I)/2026 tighten BO declaration and filing timelines, including a 15-day filing deadline on any BO change. [[Source 1]](#sec-sources) Probable · 1 source Pakistan has no autonomous broad sanctions regime; it implements UN Security Council sanctions (1267/1988/1373) via Ministry of Foreign Affairs SROs and NACTA's Proscribed Persons List. [[Source 1]](#sec-sources) Probable · 1 source Transitional NOC deadline of 5 September 2026 under s.70; unlicensed continuation after that date is a statutory offence. [[Source 1]](#sec-sources) Probable · 1 source PVARA Virtual Asset Services Regulations, 2026 and Activity-Specific Regulations, 2026 entered force on 21 August 2026 (gazette notification date), establishing licensing, prudential, conduct, technology and AML/CFT/CPF standards for VASPs under Virtual Assets Act, 2026 s.68. [[Source 1]](#sec-sources) Probable · 1 source FIA registered a case against 8 suspects alleging an unlicensed online-gambling network with PKR 119.93 billion credit turnover across 11 single-member companies, using bank, wallet and crypto/USDT channels and possible digital hawala/hundi layering, under the Foreign Exchange Regulation Act and Pakistan Penal Code. [[Source 1]](#sec-sources) Probable · 1 source Pakistan's AML/CFT regime rests on the Anti-Money Laundering Act, 2010 (as amended), with the Financial Monitoring Unit (FMU) as the designated FIU under s.6, jointly supervised with SBP and SECP. Pakistan exited the FATF increased-monitoring list on 21 October 2022 and is not named in FATF's 19 June 2026 list, nor in the EU's consolidated high-risk third-country list as amended by Delegated Regulations (EU) 2026/46 and (EU) 2026/83. [[Source 1]](#sec-sources) Probable · 1 source India reported to seek Pakistan's return to FATF increased monitoring at October 2026 plenary [[Source 1]](#sec-sources) Probable · 1 source Show-cause notices issued to 28,761 companies for failure to file Form-19 UBO declarations [[Source 1]](#sec-sources) Probable · 1 source PVARA expects to issue first full VASP licences in Q4 2026, moving beyond transitional NOCs [[Source 1]](#sec-sources) Probable · 1 source Travel Rule threshold set at PKR equivalent of USD 1,000 under Regulation 100 [[Source 1]](#sec-sources) Uncertain · 1 source SBP launched second Regulatory Sandbox cohort on 2 October 2026 covering AI in financial services, payments, remittances, and next-generation financial services, applications open to 30 November 2026 [[Source 1]](#sec-sources) Probable · 1 source CTR reporting threshold set at PKR 2 million under SRO 73(I)/2015 [[Source 1]](#sec-sources) Probable · 1 source PKR 119.93 billion traced in gambling-app-linked transactions via payment aggregators; JazzCash closed 100+ (press reports up to 300+) aggregator accounts; Easypaisa settlements delayed [[Source 1]](#sec-sources) Probable · 1 source FIR against eight suspects over online gambling platforms (U7777 Game, TD777, Game89, EPIWIN, B9 Game, S9 Game) using bank transfers, mobile wallets and USDT; evidence of layering and digital hawala/hundi activity [[Source 1]](#sec-sources) Probable · 1 source Pakistan remains off the FATF grey list as of the June 2026 published list; India has signalled intent to press for re-listing at the October 2026 plenary; no confirmed outcome located [[Source 1]](#sec-sources) Uncertain · 1 source Virtual Asset Services Regulations 2026 (S.R.O. 1419(I)/2026) and Activity Specific Regulations 2026 (S.R.O. 1420(I)/2026) in force since 21 August 2026; transitional NOC deadline (5 September 2026) passed; non-compliant pre-existing VASPs required to have ceased under s.70 [[Source 1]](#sec-sources) Probable · 1 source NEC approved adding PVARA to AMLA Schedule IV as an AML/CFT regulator for virtual-asset service providers, pending statutory notification. [[Source 1]](#sec-sources) Probable · 1 source CTR threshold reported by banks and other reporting entities to the FMU raised from PKR 2 million to PKR 3 million. [[Source 1]](#sec-sources) Probable · 1 source FIA traced ~Rs119.93bn in transactions routed through JazzCash/Easypaisa corporate wallets to six offshore gambling platforms; TBML/digital-hawala and possible USDT/crypto-channel indicators flagged; FIR registered against 8 individuals/11 shell companies. [[Source 1]](#sec-sources) Probable · 1 source NEC approved (27 Oct 2026) adding PVARA to AMLA Schedule IV as AML/CFT regulator for VASPs; pending statutory notification [[Source 1]](#sec-sources) Probable · 1 source CTR threshold raised from PKR 2 million to PKR 3 million; Pakistan Maritime Zones Act 2023 s.28 (maritime piracy) added to AMLA Schedule I as predicate offence [[Source 1]](#sec-sources) Probable · 1 source FIR against 8 individuals/11 shell companies over Rs119.93bn allegedly routed via JazzCash/Easypaisa to six offshore gambling platforms; digital-hawala and possible USDT/crypto-channel indicators flagged [[Source 1]](#sec-sources) Probable · 1 source