Full Language from FATF 20-25 June 2021.
Pakistan
Since June 2018, when Pakistan made a high-level political commitment to work with the FATF and APG to strengthen its AML/CFT regime and to address its strategic counter terrorist financing-related deficiencies, Pakistan’s continued political commitment has led to significant progress across a comprehensive CFT action plan. The FATF recognizes Pakistan’s progress and efforts to address these CFT action plan items and notes that
since February 2021, Pakistan has made progress to complete two of the three remaining action items on demonstrating that effective, proportionate and dissuasive sanctions are imposed for TF convictions and that Pakistan’s targeted financial sanctions regime was being used effectively to targeted terrorist assets.
Pakistan has now completed 26 of the 27 action items in its 2018 action plan. The FATF encourages Pakistan to continue to make progress to address as soon as possible the one remaining CFT-related item by demonstrating that TF investigations and prosecutions target senior leaders and commanders of UN designated terrorist groups.
In response to
additional deficiencies later identified in Pakistan’s 2019 APG Mutual Evaluation Report (MER), Pakistan has made progress to address a number of the recommended actions in the MER and provided further high-level commitment in June 2021 to address these strategic deficiencies pursuant to a new action plan that primarily focuses on combating money laundering.
Pakistan should continue to work to address its strategically important AML/CFT deficiencies, namely by:
(1) enhancing
international cooperation by amending the MLA law;
(2) demonstrating that assistance is being sought from foreign countries in
implementing UNSCR 1373 designations;
(3) demonstrating that supervisors are
conducting both on-site and off-site supervision commensurate with specific risks associated with DNFBPs, including applying appropriate sanctions where necessary;
(4) demonstrating that
proportionate and dissuasive sanctions are applied consistently to all legal persons and legal arrangements for non-compliance with beneficial ownership requirements;
(5) demonstrating an
increase in ML investigations and prosecutions and that proceeds of crime continue to be restrained and confiscated in line with Pakistan’s risk profile, including working with foreign counterparts to trace, freeze, and confiscate assets; and
(6) demonstrating that
DNFBPs are being monitored for compliance with proliferation financing requirements and that sanctions are being imposed for non-compliance.
https://www.fatf-gafi.org/publications/ ... l#pakistan
So, it is not just one remaining issue that needs to be implemented (which the bakis have ask for a year to implement). There are six more.
Acronyms used:
Money Laundering (ML)
Terrorist Financing (TF)
Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT)
Designated Non-Financial Businesses and Professions (DNFBP)
UN Resolution 1373 (2001) requires that
all States shall:
(a) Prevent and suppress the financing of terrorist acts;
(b) Criminalize the wilful provision or collection, by any means, directly or indirectly, of funds by their nationals or in their territories with the intention that the funds should be used, or in the knowledge that they are to be used, in order to carry out terrorist acts;
(c) Freeze without delay funds and other financial assets or economic resources of persons who commit, or attempt to commit, terrorist acts or participate in or facilitate the commission of terrorist acts; of entities owned or controlled directly or indirectly by such persons; and of persons and entities acting on behalf of, or at the direction of such persons and entities, including funds derived or generated from property owned or controlled directly or indirectly by such persons and associated persons and entities;
(d) Prohibit their nationals or any persons and entities within their territories from making any funds, financial assets or economic resources or financial or other related services available, directly or indirectly, for the benefit of persons who commit or attempt to commit or facilitate or participate in the commission of terrorist acts, of entities owned or controlled, directly or indirectly, by such persons and of persons and entities acting on behalf of or at the direction of such persons;
I would not be out of line to state that bakistan has failed the UNSCR 1373 requirements.