Pakistan Guide

With Pakistan still in the grey-list following the last FATF plenary in October 2020 – I hope the publication of their Guide for the Effective Investigation and Prosecution of Money Laundering and Terrorist Financing – will contribute to their continuing efforts for FATF compliance.

The Guide was produced with the Research Society of International Law (RSIL) – a young and enthusiastic team with a real passion to build capacity and develop innovative training. I had an opportunity to visit the team and advise them on preparations for an immersive training programme in 2019, delivered across Pakistan to more than 200 investigators, prosecutors and judges, combining lectures and tablet based assessments. For more on the training see

AML:CFT Pakistan

The Guide was published in October 2020 and I was pleased to contribute to chapters on the Global Legal Framework, Compliance with the UN 1267 and 1373 regimes, Special Investigation Techniques, International Cooperation and model forms for use in practice.


The Guide will be an important tool to raise awareness on good practices and to provide practitioners with the confidence to investigate and prosecute money laundering and terrorist financing matters. Of course, a Guide is only as good as the efforts made to use it in practice. A major inhibitor has been the antiquated law in Pakistan and more needs to be done to equip practitioners with proportional and accountable powers to effectively investigate current and emerging threats.

Pakistan has outstanding areas for compliance in its 27-point FATF Action Plan and all eyes will be on the next Plenary – to witness the progress targeted training and legislative reform brings. For more see the excellent RSIL research paper:



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