Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Pakistan PK

Domains (D1–D6)
1
Sources
10
Role actions
8
Horizon <90d
1
Jurisdiction profile
CompliantTier BRisk: StableMixed

Pakistan operates under the Anti-Money Laundering Act 2010 (as amended), with the Financial Monitoring Unit (FMU) as FIU, State Bank of Pakistan and SECP as sectoral AML/CFT supervisors, and a 2025-created Pakistan Virtual Assets Regulatory Authority (PVARA) for crypto.

MoreDelisted from FATF grey list October 2022; remains in APG enhanced follow-up on residual technical-compliance gaps.

Key deficiencies
  • Unsupervised/under-supervised hawala-hundi sector used for cross-border value transfer with Afghanistan and Iran
  • Low ML investigation-to-prosecution conversion and limited use of financial intelligence by law enforcement agencies (LEAs)
  • Beneficial ownership information held by SECP disclosed largely on-request rather than via open, interconnected public registry
  • Nascent virtual-asset supervisory capacity (PVARA) relative to already-high informal/grassroots crypto adoption
  • Persistent terrorist-financing risk from groups historically based in or transiting Pakistan (LeT/JuD, TTP, Haqqani Network, ISIS-Khorasan) via hawala, NPO abuse, and cash smuggling
Recent developments (18m)
  • FATF February 2026 and June 2026 Plenaries confirm Pakistan remains off both the grey list and the high-risk call-for-action list
  • Pakistan Crypto Council formed March 2025; Pakistan Virtual Assets Regulatory Authority (PVARA) established July 2025 as the world's second dedicated VASP regulator after Dubai's VARA
  • Pakistan Crypto Council partnership with Trump family-linked World Liberty Financial announced May 2025, alongside plans for a Strategic Bitcoin Reserve
  • FMU-UNODC risk-scoring and STR-prioritisation modernisation workshops (December 2025, February 2026) supported by UK International Development funding
  • Pakistan launched its first National Action Plan to counter migrant smuggling (February 2026), formally engaging the national AML/CFT authority to disrupt smuggling-network finance
  • OFAC counter-terrorism designation (16 January 2026) named a Pakistani-national individual linked to a Houthi-connected petroleum trading network based in Dubai
Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

Pakistan enacted the Virtual Assets Act, 2026, converting the Pakistan Virtual Assets Regulatory Authority (PVARA) from a body first stood up by a July 2025 presidential ordinance into a permanent, statutory federal licensing and supervisory authority for virtual asset service providers. The Act carries criminal penalties for unlicensed operation and states an AML/CFT alignment objective, extending the designated-reporting perimeter to licensed VASPs. This is the most structurally significant financial-integrity development touching Pakistan this cycle: it closes what had been an unregulated crypto-laundering surface by establishing a licensing gate that did not previously exist. The gazetted statutory text of the Act was not directly retrieved this cycle, so the finding rests on PVARAs own published material and contemporaneous trade press rather than a primary legal text.

Alongside the new licensing authority, the State Bank of Pakistan issued BPRD Circular Letter No. 10 of 2026, permitting bank accounts for PVARA-licensed virtual asset service providers. This reverses SBPs prior blanket 2018 ban on banks servicing crypto firms, but only for the newly licensed cohort, which means the reversal is conditioned entirely on the new licensing gate functioning as intended.

Other Developments

Pakistan remains off both FATF lists. Pakistan exited the FATF grey list in October 2022 and remains off both the increased-monitoring list and the blacklist as of the 19 June 2026 plenary. This is a stable-architecture finding rather than a new development, and it forms the backdrop against which the new VASP perimeter should be read: the reporting-entity extension to licensed VASPs sits within an AML/CTF framework that FATF has not flagged for deficiencies since 2022.

A virtual-asset-zone designation remains only authorised, not exercised. The Virtual Assets Act, 2026 authorises PVARA to designate special virtual-asset zones intended to attract blockchain companies. As of the most recent secondary reporting available this cycle, no such zone has been designated. This is a forward-looking horizon item rather than an observed development, and its eventual exercise would extend Pakistans crypto-integrity perimeter further, in either a permissive or a more tightly supervised direction depending on how the zones are structured.

Cross-Monitor Connections

The crypto-perimeter closure under the Virtual Assets Act, 2026 is directly relevant to gambling-related illicit finance tracking: secondary commentary on the Act frames it explicitly as an instrument aimed in part at tracing illicit betting-linked crypto fund flows, rather than as any liberalisation of gambling policy, which remains prohibited under Pakistans separate gambling-prohibition framework. The SBP circular permitting bank access for licensed VASPs also bears on correspondent and domestic banking-sector exposure: banks that previously had no lawful channel to service crypto firms now have a conditional one, which shifts (without eliminating) the intermediation risk that had previously sat entirely outside the regulated banking perimeter.

Outlook

The near-term watch item is whether PVARA designates any virtual-asset zones, expected on current reporting around 2027-Q1, and whether the licensing regime under the new Act demonstrates operational capacity to actually license and supervise VASPs rather than existing only in statutory form. Pakistans stable FATF standing provides no near-term catalyst for renewed listing pressure, but the durability of the new VASP perimeters AML alignment claim has not been independently corroborated against a primary text this cycle, and that gap should be closed before the framework is treated as a settled compliance baseline.

weekly_brief_draft · JID PK
Domain intelligence (D1–D6)

D1 Sanctions

Not covered

Sanctions is not yet covered for this jurisdiction in this report.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions

Not covered

Enabler Jurisdictions is not yet covered for this jurisdiction in this report.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto / Digital Assets / Financial Innovation

Crypto / Digital Assets / Financial Innovation

Continue reading

Pakistans defining financial-integrity development this cycle is the enactment of the Virtual Assets Act, 2026, which converts the Pakistan Virtual Assets Regulatory Authority (PVARA) from a body first created by a July 2025 presidential ordinance into a permanent, statutory federal authority with licensing and supervisory power over virtual asset service providers. The Act attaches criminal penalties to unlicensed operation and states an objective of FATF-aligned AML/CFT coverage, formally extending the designated-reporting-entity perimeter to licensed VASPs. Read architecturally rather than as a single event, this is a perimeter-closing move: it takes what had been an unregulated space for virtual-asset activity in Pakistan and places a licensing gate in front of it, with the stated intention of bringing VASP activity inside the same reporting obligations that apply to other regulated financial actors. The gazetted statutory text was not directly retrieved this cycle; the finding rests on PVARAs own published material and contemporaneous trade press, which is a gap worth flagging for anyone treating the AML-alignment claim as independently verified rather than self-reported by the new authority.

A second, connected development reinforces the architectural reading: the State Bank of Pakistan issued BPRD Circular Letter No. 10 of 2026, permitting banks to open and maintain accounts for PVARA-licensed virtual asset service providers. This reverses SBPs prior blanket 2018 prohibition on banks servicing crypto firms, but the reversal is conditional and narrow, applying only to entities that hold a PVARA licence. The practical effect is that Pakistans banking sector now has a lawful channel to service crypto firms for the first time in seven years, but that channel runs entirely through the new licensing gate rather than around it, meaning the integrity of the licensing process itself becomes the load-bearing control for this entire segment of exposure. Separately, the Act authorises PVARA to designate special virtual-asset zones intended to attract blockchain companies; no such zone had been designated as of the most recent secondary reporting available this cycle, so this remains a forward-looking horizon item rather than an observed structural change, and its eventual design (permissive versus tightly supervised) will materially affect whether the zones expand or narrow the integrity perimeter just established.

Outlook

The principal watch item is whether PVARA exercises its zone-designation authority, on current reporting expected around 2027-Q1, and how any such zone is structured relative to the licensing and reporting obligations just established. A second watch item is whether the licensing regime demonstrates operational capacity, actual licensing decisions and supervisory activity, rather than remaining a statutory framework without visible enforcement. Corroboration of the Acts gazetted text against a primary source, rather than PVARAs own site and trade press, would materially strengthen confidence in the AML-alignment claim underpinning this entire assessment.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

Not covered

AML/CTF Regime is not yet covered for this jurisdiction in this report.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon
Proposed2027-Q1 · ±half_year

PVARA 'virtual asset zones' designation

Potential creation of designated low-friction operating zones for blockchain/VASP business, extending PK's crypto-integrity perimeter further.
1 dated · 3 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLRO

Pakistan formalised a statutory VASP licensing and AML-reporting perimeter under the Virtual Assets Act, 2026.

Virtual asset service providers licensed by PVARA are now designated reporting entities, and banks may open accounts for licensed VASPs under BPRD Circular Letter No. 10 of 2026. Any correspondent or client exposure touching Pakistani VASPs should be assessed against whether the counterparty holds a PVARA licence.

3 evidence refs
Compliance

A new licensing gate for Pakistani VASPs changes the risk basis for onboarding and ongoing due diligence.

PVARA licensure is now the determinative fact for whether a Pakistani virtual-asset counterparty can lawfully hold a bank account; compliance frameworks referencing Pakistan as a blanket-restricted VASP jurisdiction should be updated to reflect the licensed/unlicensed distinction.

2 evidence refs
Legal

No material change this cycle.

No material change for this persona this cycle

Board

Pakistan's FATF standing remains stable while its crypto sector moves from unregulated to licensed.

Pakistan remains off both FATF lists as of the June 2026 plenary, and the new statutory VASP framework is a structural risk-reduction move rather than an incident. Board-level financial-crime exposure tied to Pakistan is not currently elevated by this cycle's findings.

2 evidence refs
CTO

PVARA's licensing framework and prospective virtual-asset zones will shape technical integration requirements for any Pakistan-facing crypto product.

Systems servicing Pakistani VASP counterparties should be built to verify PVARA licence status as a gating control, and technical roadmaps should track the still-undesignated virtual-asset zones, which could later carry distinct technical or reporting requirements.

2 evidence refs
Risk

The unregulated-to-licensed transition in Pakistan's crypto sector reduces one exposure vector while creating a new dependency on licensing-process integrity.

Risk models treating all Pakistani virtual-asset activity as unregulated should be revised; the licensed cohort now sits inside a supervisory perimeter, but the reliability of that perimeter has not been independently corroborated against a primary statutory text this cycle.

2 evidence refs
Operations

No material change this cycle.

No material change for this persona this cycle

Audit

The AML-alignment claim underpinning Pakistan's new VASP framework rests on secondary sourcing, not a retrieved primary text.

The gazetted text of the Virtual Assets Act, 2026 was not directly retrieved this cycle; audit documentation relying on this framework's stated FATF alignment should note that the claim traces to PVARA's own site and trade press pending primary-source corroboration.

1 evidence refs
Decision lens
MLRO

Pakistan formalised a statutory VASP licensing and AML-reporting perimeter under the Virtual Assets Act, 2026.

Compliance

A new licensing gate for Pakistani VASPs changes the risk basis for onboarding and ongoing due diligence.

Legal

No material change this cycle.

Board

Pakistan's FATF standing remains stable while its crypto sector moves from unregulated to licensed.

CTO

PVARA's licensing framework and prospective virtual-asset zones will shape technical integration requirements for any Pakistan-facing crypto product.

Risk

The unregulated-to-licensed transition in Pakistan's crypto sector reduces one exposure vector while creating a new dependency on licensing-process integrity.

Operations

No material change this cycle.

Audit

The AML-alignment claim underpinning Pakistan's new VASP framework rests on secondary sourcing, not a retrieved primary text.

Shared evidence: 2 refs
Scenario sketches

Illustrative: EU AML Package / AMLA supervisory transition backdrop

Illustrative orientation only: as the AMLA Regulation (Reg (EU) 2024/1620) moves cross-border obliged entities within the EU toward direct or indirect AMLA-level supervision, alongside the directly-applicable AMLR (Reg 2024/1624) and per-state 6AMLD transposition, the structural balance between purely national AML supervision and a hybrid EU-level regime shifts. This is architecture-over-incident framing describing a possible structural mechanism at the EU level, not an observed fact about Pakistan, and not a prediction of how any specific evasion typology will respond.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Illustrative: licensing-gate integrity as the load-bearing control

Illustrative orientation only: where a jurisdiction converts an unregulated virtual-asset space into a licensed perimeter and simultaneously permits banking access conditioned on that licence, the integrity of the licensing process itself becomes the single point on which the wider AML control environment depends. A structural weakness in licensing diligence, rather than any single transaction, would be the mechanism by which risk re-enters the newly banked segment. This is illustrative structural reasoning, not an observed finding about PVARAs actual licensing practice.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_changeNo material PK-specific signal in Russian sanctions-evasion channels this cycle.
T2 · EU AML Package / AMLAno_changeNot applicable to PK (not EEA/EU).
T3 · FATF Grey Listno_changePakistan has remained off the FATF grey list since October 2022 through the February 2026 plenary per the most recent dated source found.
T4 · Beneficial-Ownership Register StatuswatchSECP continues to expand BO disclosure obligations but no centralised public UBO register exists; pre-window development carried forward as standing status.
T5 · Crypto & Digital-Asset IntegritywatchPVARA's licensing portal and 10-category VASP regime continue to be operationalised, with AML/CFT duties (KYC, travel rule, goAML reporting to FMU) attaching by licence category.
T6 · Sanctions Regime Divergenceno_changePakistan has no autonomous broad sanctions regime; it implements UN Security Council sanctions via Ministry of Foreign Affairs SROs and NACTA's Proscribed Persons List.
Registers

Enforcement actions

  • OFAC issued a Specially Designated Global Terrorist (SDGT) designation naming a Pakistani-national individual, based in Dubai, linked to a petroleum-trading network supporting Houthi (Ansarallah) financing, as part of a wider counter-terrorism designation package. 16 Jan 2026
  • FMU convened a two-day Risk Scoring and STR Prioritization workshop in Karachi to redesign risk-scoring frameworks and explore machine-learning-assisted analytics for suspicious transaction report triage, moving the FIU toward a more analysis-led, technology-enabled model. 10 Dec 2025
  • Pakistan launched its first National Action Plan to counter migrant smuggling, establishing a PM-chaired Task Force and sub-committee that formally engages the national Anti-Money Laundering and Counter Financing of Terrorism Authority and financial institutions to disrupt the financial lifelines of smuggling networks, alongside cooperation with INTERPOL, Europol and Frontex. 18 Feb 2026
  • APG's follow-up review process to Pakistan's 2019 Mutual Evaluation was updated in the current cycle (latest procedural update recorded December 2025), keeping Pakistan in enhanced follow-up reporting against outstanding technical-compliance recommendations rated partially/largely compliant. 1 Dec 2025

Sanctions changes

  • OFAC's 16 January 2026 counter-terrorism designation package added a Pakistani-national individual (Imran Asghar) and associated Dubai-based petroleum-trading entities to the SDN list under the Ansarallah/Houthi-linked network designation. 16 Jan 2026
  • The European Commission's December 2025 delegated regulations (EU 2026/46 and EU 2026/83) updating the high-risk third-country AML/CFT annex did not add Pakistan, consistent with its December 2022 delisting; Pakistan remains off both the EU HRTC annex and the FATF grey list as of the June 2026 FATF Plenary. 4 Dec 2025

Regulatory horizon (register)

  • PVARA VASP licensing rollout for global/local exchanges
  • Next FATF/APG Plenary review of Pakistan's follow-up status
  • Finalisation of Pakistan's National Strategy against Organized Crime

Active schemes

  • [HIGH] Afghanistan-Iran-Pakistan hawala/hundi and bulk-cash corridor
  • [CRITICAL] Militant group financing via hawala, NPOs and criminal proceeds
  • Rapid crypto embrace outpacing nascent VASP supervision
  • SECP beneficial-ownership disclosure gap for companies/LLPs
Sources
  1. Financial Action Task Force (FATF)
  2. Asia/Pacific Group on Money Laundering (APG) / FATF
  3. FATF / APG
  4. U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
  5. Securities and Exchange Commission of Pakistan (SECP), via UNCAC Secretariat/UNODC
  6. European Commission (DG FISMA)
  7. United Nations Office on Drugs and Crime (UNODC)
  8. TRM Labs
  9. Organized Crime and Corruption Reporting Project (OCCRP)
  10. UK HM Treasury / Home Office (National Risk Assessment)
Coverage gaps
Pakistan's law-enforcement agencies continue to show low con…
Pakistan's law-enforcement agencies continue to show low conversion of money-laundering investigations into prosecutions and limited operational use of FMU-generated financial intelligence, a deficiency identified in the 2019 APG Mutual Evaluation that remains unresolved in the December 2025 Follow-Up Report, which keeps Pakistan in enhanced follow-up with 38 Recommendations still rated only compliant/largely compliant.
The hawala/hundi sector operating across the Pakistan-Afghan…
The hawala/hundi sector operating across the Pakistan-Afghanistan-Iran corridor remains largely outside effective AML/CFT supervision, with bulk cash smuggling into Afghanistan estimated at millions of dollars daily, a structural vulnerability flagged by FATF/APG and reiterated in the UK's 2025 National Risk Assessment identifying Pakistan as a hawala source jurisdiction.
PVARA and the Pakistan Crypto Council were only established …
PVARA and the Pakistan Crypto Council were only established in 2025 and are still building licensing, supervisory and enforcement capability, while informal/grassroots crypto adoption in Pakistan is already among the highest globally relative to economic size.
No fresh (within the 18-month review window) OCCRP/ICIJ-docu…
No fresh (within the 18-month review window) OCCRP/ICIJ-documented major politically-exposed-person money-laundering enforcement action was identified for Pakistan; the most prominent recent precedent (the 2022 acquittal of PM Shehbaz Sharif and his son in a $200m money-laundering case) predates the window, leaving the current baseline unable to test whether elite-linked AML enforcement has changed direction.

Evidence

Confidence-tiered claims

Ten VASP licence categories (exchange, custody, broker-dealer, advisory, lending/borrowing, derivatives, asset management, transfer/settlement, issuance, mining-related), each with activity-specific AML/CFT requirements. SRC-fim-PK-009
Probable · 1 source
Anti-Money Laundering Act, 2010, s.6 establishes the FMU as Pakistan's FIU. SRC-fim-PK-004
Confirmed · 1 source
Off the FATF grey list since October 2022, through the February 2026 plenary. SRC-fim-PK-003
Probable · 1 source
S.R.O. 328(I)/2026 and S.R.O. 57(I)/2026 tighten BO declaration and filing timelines, including a 15-day filing deadline on any BO change. SRC-fim-PK-007
Probable · 1 source
Pakistan has no autonomous broad sanctions regime; it implements UN Security Council sanctions (1267/1988/1373) via Ministry of Foreign Affairs SROs and NACTA's Proscribed Persons List. SRC-fim-PK-005
Confirmed · 1 source
Transitional NOC deadline of 5 September 2026 under s.70; unlicensed continuation after that date is a statutory offence. SRC-fim-PK-001
Probable · 1 source