On 18 October, Regulation Asia reported that the FATF-style regional body, the Asia-Pacific Group, says that Pakistan has been re-rated for technical compliance from ‘partially compliant’ to ‘compliant’ on FATF Recommendation 29 (FIU), due to improvements in information-sharing in the country, and is said to have made progress on FATF Recommendations 1 (assessing risks and applying a risk assessment approach).  Pakistan had requested re-ratings for Recommendations 1, 6, and 29, all rated ‘partially compliant’ in the mutual evaluation report published in October 2019.  Commenting on Pakistan’s terrorism financing risk assessment, the APG says that the assessments of risks associated with DNFBP and legal persons and legal arrangements are “very general in nature and appear to be based on limited data”, adding that it does not consider in detail known instances of terrorist organisations acquiring real estate and using it to raise funds.  Pakistan has raised a disagreement with the process, analysis and rating for Recommendation 6 (targeted financial sanctions related to terrorism and terrorist financing), but is said to be ‘compliant’ on just 2 FATF Recommendations, ‘largely compliant’ on 9, ‘partially compliant’ on 25, and ‘non-compliant’ on 4; and will remain in enhanced follow-up.


I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at https://www.buymeacoffee.com/KoIvM842y

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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