Since June 2018, Pakistan has been subject to “enhanced monitoring” by the Financial Action Task Force (FATF), which is the global watchdog for counter-financing of terrorism (CFT) and anti-money laundering (AML) issues, working in cooperation with its regional chapters and affiliates. Four years on, Pakistan has made tangible progress to get off the so-called ‘grey list,’ as a result of high-level political commitment to address ‘strategic deficiencies’ in its AML and CFT regimes.

As the latest FATF plenary is under way in Berlin this week, there seems to be more than the usual amount of optimism being aired in Pakistan, about the country finally being let off the FATF hook. Several news reports have indicated that a fresh diplomatic push by the new government, with both traditional allies and friendly Western countries, has been in the works for over a month. The aim is to assist Pakistan in getting a clean bill of health at FATF, at a time when its economy could use some good news.

The optimism may not be entirely misplaced, as Pakistan’s profile has technically improved vastly over these years. And FATF itself has recently acknowledged progress on the dual action plans that were handed over to Pakistan to address systemic deficiencies in going after offences related to terrorism financing and money laundering. Both on the 27-point CFT action plan and the 7-point AML action plan, there is now just one thing left to be done by Pakistan’s authorities as per FATF’s satisfaction.

But that last point on both action plans – the requirement for Pakistan’s law enforcement authorities to demonstrate a sustained trend in pursuing CFT and AML-related investigations and prosecution – is something that may take some time to address. It isn’t clear what timeframe and objective criteria FATF has in mind to certify the existence of such a trend. This ambiguity has been there for many months now, and it should serve to adequately deflate the optimism that is currently in the air.

FATF apparently needs Pakistan to have its recent legal amendments in the AML and CFT frameworks to translate into proactive monitoring, investigation, prosecution and sanctions for relevant offences, besides matching volume of investigations to country risk profile. However, considering the capacity, speed and effectiveness of Pakistan’s prosecutorial and judicial systems, it would be naïve to expect rapid results. Besides, it would be unfair to hustle the judicial system into giving verdicts, as it undermines due process.

Where does that leave Pakistan’s case at FATF? A much-improved technical scorecard on its AML and CFT frameworks than 2018! And gradual progress being made in ‘last-mile delivery’ of prosecuting and sanctioning money launderers and terrorism financiers! This is why the government is keen to capitalize on technical progress by soliciting required geopolitical support and get on the other side of the grey zone. That outcome will obtain when FATF becomes satisfied with the pace of judicial outcomes. It might come as soon as this week; it could take a few months; or even another year or two. FATF has the time.


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