From June 2018 to now, a ghost has haunted Pakistan, in the form of the Financial Action Task Force (FATF). Ever since Pakistan was placed on FATF’s supposed “grey list”, respective governments have made countless efforts to comply with FATF guidelines. Being on this grey list is not sustainable for Pakistan; the economy has seen a decline of around $38 billion between 2008 and 2019. The grey list means a direct negative impact on imports, exports, remittances and limited access to international lending.

In the three years since 2018, when we were placed on the grey list, Pakistan has addressed 26 out of 27 items on the original action plan. The country has completed four of the seven items on the recent 2021 action plan, complying well within the timelines prescribed by the FATF.

Pakistan has taken a wide range of steps to comply with FATF, including introducing amendments in the Mutual Legal Assistance Act, 2020, AML/CFT, transparency of beneficial ownership information and implementation of targeted financial sanctions for proliferation finance by DNFBPs. This progress was appreciated by FATF itself, which in a statement, acknowledged Pakistan’s continued political commitment, recognising that it led to significant progress across a comprehensive CFT action plan.

However, despite all this effort, FATF has consistently disappointed in elevating Pakistan out of the grey list, with FATF officials commending Pakistan’s commitment to compliance, yet at the same time keeping the country on the monitoring list after every review.

The upcoming days, where FATF’s strategic direction for the next performance assessment of the countries on its watch list will be reviewed, are integral. There are positive indications that we might see the end of the grey list—as work done on this entails, we have exceeded far beyond anyone in history. This review comes conveniently at a time when a few weeks back, a court in Pakistan sentenced Hafiz Saeed, founder of Lashkar-e-Taiba,to prison; Saeed’s mobility was something that countries in the past used as a tool to ensure Pakistan remained in the grey list. With these favourable conditions, it seems fair that FATF will make a positive decision—yet past experiences of FATF reviews do not leave one with much hope.



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