Pakistan
Overview
Pakistan’s current AML/CFT framework is anchored in the Anti-Money Laundering Act 2010, supported by sectoral rules, the National Anti-Money Laundering and Counter Financing of Terrorism Authority Act 2023 and the Virtual Assets Act 2026. On 21 August 2026 PVARA notified the final Virtual Asset Services Regulations and Activity Specific Regulations, replacing the earlier interim NOC-stage regulatory gap with the operative VASP regulatory framework.
Beneficial-ownership obligations are implemented through AML CDD requirements, corporate/legal-person transparency rules and sectoral supervision. PVARA’s final 2026 VASP regulations sit alongside these duties and require licensed VASPs to operate within a full AML/CFT/CPF control framework, including customer identification and ongoing due diligence.
FMU receives, analyses and disseminates suspicious transaction and currency transaction reports under the AML framework. PVARA’s final 2026 VASP framework additionally requires licensed VASPs to monitor transactions, retain customer/transaction records for at least 10 years and report suspicious activity to FMU immediately.
Compliance Calendar4
Requirement
Currency Transaction Report (CTR)
Authority / Report toFinancial Monitoring Unit (FMU)
Deadline / triggerImmediately, but not later than 7 working days after the transaction.
Requirement
- Subject scope
- Reporting entities subject to the currency transaction reporting regime.
- Trigger
- Cash transaction at or above the threshold specified under the applicable AML reporting framework.
- Filing channel
- goAML / prescribed FMU reporting mechanism.
Impact
- Consequences of non-compliance
- Late/non-reporting can lead to AML regulatory sanctions; threshold amount should be taken from the operative current rule/configuration applicable to the reporter.
- Enforcement authority
- FMU / relevant supervisor
- Operational impact
- Cash monitoring should preserve transaction date and apply the operative threshold while enforcing the seven-working-day outer limit.
Requirement
Suspicious Transaction Report (STR)
Authority / Report toFinancial Monitoring Unit (FMU)
Deadline / triggerPromptly after suspicion is formed.
Requirement
- Subject scope
- Reporting entities under the AML Act and Suspicious Transaction / Currency Transaction Reporting Regulations 2025.
- Trigger
- Suspicion is formed after internal review under the applicable reporting-entity process.
- Filing channel
- goAML / FMU reporting mechanism prescribed by the 2025 Regulations.
Impact
- Consequences of non-compliance
- Non-compliance can lead to sanctions under the AML Act/regulatory framework; consequence depends on the entity and breach.
- Enforcement authority
- FMU / relevant AML supervisory authority
- Operational impact
- Escalation must be designed to prevent unnecessary delay after the reporting decision is reached.
Requirement
Virtual Assets / VASP
Licensed VASP AML/CFT/CPF programme
Authority / Report toPakistan Virtual Assets Regulatory Authority (PVARA) / Financial Monitoring Unit (FMU)
Deadline / triggerOngoing CDD and transaction monitoring; retain customer and transaction records for at least 10 years; report suspicious transactions or activities to FMU immediately.
Requirement
- Sector scope
- Virtual Assets / VASP
- Subject scope
- Virtual Asset Service Providers licensed by the Pakistan Virtual Assets Regulatory Authority (PVARA).
- Trigger
- Continuous while carrying on licensed virtual-asset services; suspicious activity creates an immediate reporting trigger.
- Filing channel
- Maintain the VASP AML/CFT/CPF control framework and records; submit suspicious-activity reports to FMU through the applicable reporting mechanism.
Impact
- Consequences of non-compliance
- Breach can trigger supervisory or enforcement action under the Virtual Assets Act, PVARA regulations and applicable AML framework.
- Enforcement authority
- PVARA / FMU / other competent AML authorities
- Operational impact
- VASP compliance programmes should combine onboarding KYC, ongoing due diligence, real-time transaction monitoring, sanctions screening, ten-year record retention and immediate suspicious-activity escalation.
Requirement
Risk-based reporting controls and AML programme
Authority / Report toRelevant AML supervisor / FMU for intelligence reports
Deadline / triggerOngoing; no single filing date.
Requirement
- Subject scope
- Reporting entities under the AML Act and sector regulations.
- Trigger
- Continuous regulated activity.
- Filing channel
- Internal policies, controls, monitoring and governance.
Impact
- Consequences of non-compliance
- Control failures may lead to supervisory and AML Act sanctions.
- Enforcement authority
- Relevant AML supervisor
- Operational impact
- Maintain documented risk-based transaction monitoring, escalation and reporting governance.
Authorities & FIU1
FATF Assessment
Measures how fully the jurisdiction has implemented FATF’s technical requirements. It does not measure practical effectiveness.
Measures whether the AML/CFT system achieves its intended results in practice. Follow-up reports do not normally replace these ratings.
Explore 40 FATF RecommendationsSee every Technical Compliance rating and what it means.+
Explore 11 Immediate OutcomesSee how FATF rates whether the AML/CFT system works in practice.+
Regulatory Timeline40
PVARA notified S.R.O. 1419(I)/2026 and S.R.O. 1420(I)/2026 on 21 August 2026. The final VASP framework supplements the Virtual Assets Act 2026 and includes AML/CFT/CPF controls for licensed VASPs, including customer due diligence, transaction monitoring, recordkeeping, suspicious-activity reporting and sanctions screening.
The Virtual Assets Act 2026 (Act XIII of 2026), promulgated on 4 March 2026, created a dedicated statutory framework for virtual assets and VASPs under PVARA, including a licensing requirement.
FATF revised Recommendation 16 to standardise payment information and strengthen fraud/error controls in cross-border payments.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendation 1 and related interpretive material to strengthen proportionality and simplified measures under the risk-based approach.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF revised Recommendations 4, 30, 31 and 38 and related interpretive material to make asset recovery a stronger operational priority, expand tools to trace and confiscate criminal property and improve domestic and international cooperation.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The National Anti-Money Laundering and Counter Financing of Terrorism Authority Act 2023 was promulgated on 7 August 2023, creating a statutory national coordination authority.
At its February 2023 Plenary FATF revised Recommendation 25 and its Interpretive Note to strengthen transparency and beneficial-ownership requirements for trusts and similar legal arrangements, complementing the 2022 strengthening of Recommendation 24 for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF removed Pakistan from its jurisdictions under increased monitoring.
FATF strengthened Recommendation 24 on beneficial ownership transparency for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendations 1 and 2 and their Interpretive Notes so countries and covered private-sector entities must identify, assess and mitigate risks of breaches, non-implementation or evasion of proliferation-related targeted financial sanctions.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee revised its ML/TF risk-management guidelines to add principles for information exchange and cooperation between prudential and AML/CFT supervisors in authorisation, ongoing supervision and enforcement.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted detailed implementation requirements for virtual assets and VASPs in June 2019, including the application of wire-transfer information requirements commonly described as the Travel Rule. This operationalised the virtual-asset perimeter introduced through the 2018 Recommendation 15 revision.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗In October 2018 FATF revised Recommendation 15 and added the definitions of virtual asset and virtual asset service provider, formally bringing virtual-asset activity into the global AML/CFT standards architecture. Detailed implementation requirements followed in 2019.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF identified Pakistan in its on-going global AML/CFT compliance process.
FATF removed Pakistan from its on-going global AML/CFT compliance monitoring process.
The Basel Committee issued Sound management of risks related to money laundering and financing of terrorism, superseding its 2001 CDD and 2004 consolidated KYC papers and integrating ML/TF risk management with prudential supervisory expectations.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted a consolidated revised set of 40 Recommendations integrating AML, CFT and proliferation-financing safeguards.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF identified Pakistan in its on-going global AML/CFT compliance process.
The Anti-Money Laundering Act 2010 (Act VII of 2010), promulgated on 27 March 2010, became the central statutory AML framework and basis for FMU functions.
FATF publicly identified AML/CFT risks or deficiencies concerning Pakistan in its 28 February 2008 statement.
Pakistan established the Financial Monitoring Unit in October 2007 as the country’s central financial intelligence unit under the then AML Ordinance framework.
Resolution 1737 imposed binding measures concerning Iran’s proliferation-sensitive nuclear activities, including an asset freeze on designated individuals and entities. Together with the DPRK regime, it forms a foundational UN counter-proliferation targeted-financial-sanctions architecture.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗Following the DPRK nuclear test, Resolution 1718 imposed binding sanctions including an asset freeze on designated persons and entities connected to the nuclear programme. It became a central UN targeted-financial-sanctions pillar for counter-proliferation financing.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗FATF added a ninth Special Recommendation addressing cash couriers and cross-border movement of currency.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1540 requires all States to adopt and enforce laws and domestic controls to prevent non-State actors from acquiring or using weapons of mass destruction and related materials. It forms a binding global legal pillar of the proliferation-financing control environment later reflected in FATF CPF standards.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The UN General Assembly adopted the United Nations Convention against Corruption on 31 October 2003. UNCAC addresses prevention of money laundering, laundering of corruption proceeds, confiscation and a dedicated asset-recovery framework; the Convention entered into force globally on 14 December 2005.
Current UN depositary relationship to 2003 UN Convention against Corruption. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗FATF comprehensively revised its AML/CFT Recommendations, strengthening preventive measures and extending coverage.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee issued Customer due diligence for banks, setting minimum supervisory expectations for customer acceptance, identification, ongoing monitoring and risk management. It became an influential global banking KYC/CDD benchmark and was later reflected in FATF standards.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF expanded its standards to terrorist financing through eight Special Recommendations.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1373 requires all States to prevent and suppress terrorist financing, criminalise the provision or collection of funds for terrorist acts, freeze terrorist assets without delay and prohibit making funds or financial services available to terrorists and related entities.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The Palermo Convention was adopted on 15 November 2000 and broadened the international money-laundering framework beyond drug proceeds through criminalisation and preventive measures tied to transnational organised crime. It entered into force globally on 29 September 2003.
Current UN depositary relationship to 2000 Palermo Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗Pakistan joined the Asia/Pacific Group on Money Laundering in May 2000.
The UN General Assembly adopted the International Convention for the Suppression of the Financing of Terrorism on 9 December 1999, creating the treaty framework for criminalising terrorist financing and international cooperation. It entered into force globally on 10 April 2002.
Current UN depositary relationship to 1999 Terrorist Financing Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗Resolution 1267 imposed an assets freeze and other targeted sanctions in the Taliban context and created the Security Council committee that became the foundation of the UN 1267 sanctions architecture. It is a key global precursor to modern terrorist-financing targeted financial sanctions.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗FATF revised the Forty Recommendations to reflect evolving money-laundering methods and countermeasures.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Representatives of 13 financial intelligence units met in Brussels on 9 June 1995 and founded what became the Egmont Group. The milestone created the operational global network for FIU-to-FIU cooperation and exchange of financial intelligence.
No Egmont member FIU is recorded in the current profile. The 1995 GLOBAL milestone is therefore context, not a membership claim.
Egmont Group · Member FIUs ↗FATF issued its original Forty Recommendations, establishing the first global AML standard framework.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The G7 established FATF in 1989 to examine and develop measures to combat money laundering. FATF became the central global standard-setting body whose recommendations are implemented through national and regional AML/CFT frameworks.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Vienna Convention was adopted on 20 December 1988 and created the first treaty-level international obligation to criminalise laundering conduct linked to drug-trafficking proceeds, alongside confiscation and international-cooperation measures. It entered into force globally on 11 November 1990.
Current UN depositary relationship to 1988 Vienna Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗The Basel Committee published a Statement of Principles for banks aimed at reducing the risk that banking institutions would be used by criminals or as channels for money laundering. This helped establish the preventive and supervisory side of AML alongside the emerging criminal-law framework.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗