Alternate Remittance Service / Hawala/ Hundi

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Alternate Remittance Service / Hawala/ Hundi



The case involves transfer of funds via cheques from and to the inter-connected accounts maintained in the border area branches by a network of individuals/entities. Moreover, a significant proportion of funds were moved from the accounts maintained at Bank A’s border town branches to accounts maintained at Bank A’s tribal area branch. The individuals involved were young and unlikely to have such large transactions. The movement of funds to the tribal region without any plausible justification made the transactions suspicious to hawala and other criminal activities including terrorism financing. Further, CTRs reported on the individuals indicated that the suspects also held accounts with other banks in the region as well. The case was reported to LEA for further investigation.



Multiple STRs were reported on foreign individuals residing in Pakistan suspected to be involved in activities related to hundi/hawala. Some foreign individuals maintained account with ABC Bank. Some of these accounts were personal accounts while others were Sole Proprietorship accounts. The transactional pattern in all these accounts did not match with the profile of the customers. The turnover was very high and very frequent transactions took place in the accounts. The transactions were also being carried out with unrelated counter-parties. All these individuals conducted inter-linked transactions in each other’s accounts. Most of these individuals were not registered with tax authorities.


During analysis of STRs, it was revealed that one of the suspects was already involved in hawala/hundi activities. Accordingly, the financial intelligence on all the connected individuals was forwarded to the LEA to assist them in apprehending the illegal network of hawala/hundi operators.



The accounts of D-Trading Company (person DK), S-Fruit Merchant (person SSK), K-Trading Company (persons KK and JK) and A-International Corporation (person AK) were reported by XYZ Bank. The accounts were either opened as proprietorship or partnership concerns. The accounts were reported to the FMU due to heavy turnover in the accounts and transactions with individuals / entities unrelated to the nature of business of the account holders.


During analysis, the accounts of D-Trading Company, S-Fruit Merchant, K-Trading Company and A-International Corporation were found to be linked by the transfer of funds. The accounts were being maintained in XYZ Bank at the same branch located in tax exempted region. An identical pattern of transactions was noticed in all these accounts. Additional accounts of suspects were identified via CTRs. Furthermore, different businesses were mentioned by the suspects in the accounts maintained at different banks and the suspects were not registered with tax authorities, except for AK.


From the activity in the accounts and the location of the accounts, it was suspected that the suspects were engaged in the business of illegal hawala/hundi. Therefore, the financial intelligence was disseminated to LEA for investigation.



A STR was reported on account of news aired on a local TV Channel. According to the news, a local businessman had received a threatening call from a foreign jurisdiction asking him to deposit an amount into an account maintained by person X in a local bank. A search of the FMU’s database revealed a link between the account numbers and other individuals maintaining accounts with the same and other banks.


Analysis of all the linked accounts identified a nexus of Hawaladars who were suspected to be facilitating the network. Analysis of statement of account reflected frequent transfers of funds from/to different accounts. The matter was thus referred to LEA for investigation.