This page summarizes the legal and supervisory framework and the operational expectations for financial institutions evaluating AML software Pakistan, filing via goAML Pakistan, and implementing sanctions screening Pakistan.
Last Updated: 2025-09-06
Pakistan’s AML/CFT framework is anchored in AMLA 2010, FMU regulations/guidance, SBP/SECP rules, and FATF standards. FMU acts as the national FIU (STR/CTR intake and analysis), while SBP and SECP provide sectoral supervision. Institutions are expected to evidence both legal compliance and an effective risk-based approach (RBA) across the customer lifecycle—onboarding → monitoring → case management → reporting → audit—with traceable, audit-ready controls. Digitalization and higher volumes make manual processes insufficient; supervisory expectations emphasize dynamic, explainable controls, versioning, and management approval to demonstrate governance.
Immediately once reasonable grounds to suspect are formed—“without delay” under AMLA 2010 s.7(1). File through FMU goAML and avoid tipping-off.
At least ten (10) years under AMLA 2010 (and SBP rules for banks). Keep the report and all supporting documents accessible and secure.
Cash transactions ≥ PKR 2,000,000 in a single day trigger a CTR. Aggregate multiple same-day cash transactions for the same customer.
Screen customers and transactions against the UN Consolidated List and Pakistan’s domestic proscribed lists at onboarding and continuously. On a true hit, freeze without delay and report to FMU and the supervisor.
Obtain senior management approval and document Source of Wealth/Funds. Apply enhanced ongoing monitoring and maintain a PEP register.
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