10 highest risk agencies: NAB to lead action plans to mitigate vulnerabilities

ISLAMABAD: Based on an institutional-level risk assessment, the National Accountability Bureau will lead and coordinate the development of action plans to mitigate vulnerabilities in the 10 agencies identified as having the highest risks (new end-October 2026 Structural Benchmark).

This was noted in the second review report under the Extended Fund Facility (EFF) programme and the first review of the Resilience and Sustainability Facility (RSF) on 11th December 2025.

This correspondent requested the names of the identified 10 agencies; however, there was no response from either the Ministry of Finance/ Law Ministry or the International Monetary Fund’s (IMF) Islamabad office till the filing of this report.

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The IMF’s second EFF documents further noted that United Nations Convention Against Corruption (UNCAC) Country Review Report of Pakistan was available on the Ministry of Law and Justice website in July 2025. Pakistan signed UNCAC in December 2003 and ratified it in August 2007.

After repeated failed attempts to access the report this correspondent attempted to contact the Law Ministry but failed despite repeated attempts. A request was then sent to the Resident Representative of the IMF in Islamabad on 18th December on WhatsApp but no response was received. However late 21st December 2025 the report was available on the Law Ministry website and the IMF Resident Representative shared the report with this correspondent at 10 pm Sunday night.

The UNAC report does not identify the 10 agencies referred to in the IMF’s report though it maintained that Pakistan has built an extensive legal and institutional framework to prevent corruption, but gaps in enforcement, independence, and oversight continue to raise concerns.

The report noted that treaties are not self-executing in Pakistan and must be incorporated into domestic law. While Pakistan has enacted a wide range of legislation — including constitutional provisions, the National Accountability Ordinance (NAO), the Anti-Money Laundering Act, and public procurement laws — implementation remains inconsistent.

The review raised concerns over the lack of a formal monitoring and reporting mechanism for the national anti-corruption strategy and related policies.

They also highlighted issues regarding the independence, appointment and removal procedures, and resourcing of the National Accountability Bureau (NAB) and other anti-corruption bodies.

The report recommended Pakistan to strengthen institutional independence of NAB and preventive bodies; ensure adequate financial and human resources; identify corruption-prone public positions and introduce rotation, screening and training systems; improve conflict-of-interest management across public institutions; establish verification mechanisms for asset declarations by civil servants, judges and prosecutors.

Regarding public procurement the report urged Pakistan to review and strengthen procurement laws, establish an effective appeal system, and enhance oversight by providing sufficient resources to the Public Procurement Regulatory Authority and NAB.

The report also calls for greater judicial and prosecutorial independence, improved access to information, periodic corruption risk assessments in public administration, and enhanced public participation in decision-making.

On asset recovery, the review acknowledges that Pakistan has a comprehensive legal framework under the Mutual Legal Assistance (Criminal Matters) Act, the Code of Criminal Procedure, the Anti-Money Laundering Act, and the NAO. NAB acts as the central authority for corruption-related mutual legal assistance.

Pakistan can cooperate on asset recovery even in the absence of treaties, on the basis of reciprocity, and allows foreign states to initiate civil action in Pakistani courts — identified as a good practice under UNCAC. However, the report notes that international cooperation and asset recovery mechanisms are not being fully utilised, despite some successful recoveries in recent years.

The review assessed Pakistan’s anti-money laundering and counter-terrorism financing framework, citing customer due diligence requirements, beneficial ownership identification, enhanced scrutiny of politically exposed persons, suspicious transaction reporting to the Financial Monitoring Unit, and sanctions for non-compliance.

The reviewers urged Pakistan to increase the use of international asset recovery mechanisms; modernise and digitalise the asset declaration system, expand its scope to spouses, and strengthen verification; Introduce non-conviction-based confiscation in appropriate corruption cases; recognise UNCAC as a sufficient legal basis for enforcing foreign confiscation orders; clearly regulate the return and disposal of recovered assets in line with UNCAC provisions.

The report noted that while Pakistan has laid down an extensive legal foundation to counter corruption, institutional weaknesses and enforcement gaps continue to undermine effective implementation of the Convention.

Copyright Business Recorder, 2025