The transactional activity in the accounts of Mr. DWK and his family members was reportedly suspicious as a high value of funds was transacted from their accounts which apparently did not align with their profiles. The individuals were also transacting with unrelated counterparties located in remote areas of the country. The suspicion was raised that the individuals were probably involved in Hawala/Hundi.
Mr. DWK was involved in the business of selling raw materials for building constructions. Mr. DWK maintained multiple personal and business accounts at different banks and his transactional activity was unusual comprising of home remittances, online transfers, clearing of cheques, cash deposits and withdrawals. The transactions were conducted with various unrelated counterparties including clearing/forwarding agents, jewellers, car dealers, real estate dealers, overseas Pakistanis etc. A few counterparties were identified to be involved in illegal foreign exchange businesses which strengthened the suspicion of the involvement of Mr. DWK in Hawala/Hundi. During analysis, STRs were also found on the family members of Mr. DWK including 1) Mr. RWK (brother), 2) Mr. TWK (brother), 3) Mr. AUK (brother), 4) Mr. YK (son), 5) Mr. AK (son), whereby similar transactional activity was identified and suspicions were reported. Some of the family members were residing in Country A and involved in businesses related to transport, while a few of them were living in Pakistan and involved in trading businesses.
Flow of Funds: During the analysis, a large number of individuals and their family members were found who were working in country A and they received home remittances from Country A in their accounts maintained in Pakistan. The remittances were subsequently transferred to the accounts of Mr. DWK and family members or withdrawn in cash by the family members of Mr. DWK. The family members also sent/ received funds from unrelated counterparties in Pakistan such as clearing forwarding agents, car dealers/drivers, a gold dealer, property dealers and an import-export business located in remote areas.
Hawala/Hundi: The pattern of transactions, nature of counterparties and rapid movement of funds indicated that the individuals were probably involved in Hawala/Hundi. Furthermore, one of the family members, Mr. TWK, was already under investigation by a law enforcement agency (LEA) for his involvement in Hawala/Hundi. Therefore, it was suspected that the family members were operating a group of Hawala/Hundi in the Buner district, Pakistan.
Gold Smuggling: During analysis, Mr. DWK was found to be under investigation by a law enforcement agency (LEA) in Pakistan for his involvement in the smuggling of gold. The individual was apprehended for smuggling of gold from the airport. The LEA informed that the individual managed to import artificial jewellery against the export of pure gold, which is APG Typologies Report 2022 44 in violation of the Procedure for Export of Gold Jewellery and Precious / Semi-Precious Stones and Import Facility.
Car Smuggling: The reporting entity informed that the family members living in Pakistan collect passports from different persons for the clearing of imported cars from customs. Moreover, frequent transactions with car dealers/drivers and clearing forwarding agents were observed. It appeared that these agents apparently provided funds to non-resident individuals, retrieved the funds by remittance via a remitter’s own account and obtained a Proceed Realization Certificate (PRC) to use it for vehicle import and to obtain a tax benefit on behalf of the remitter. A Proceed Realization Certificate is also known as an encashment certificate which is issued by the bank to the beneficiary customer at the time of handing over the remittance funds in Pakistani Rupees. Therefore, it was suspected that the individuals were also involved in the unauthorized import of cars. Based on analysis, it was determined that the group of individuals were suspected of operating a Hawala/ Hundi network in Pakistan and were facilitating the smuggling of different kinds of goods like gold smuggling and the unauthorised import of cars. The financial intelligence was shared with LEAs for the investigation of Hawala and for probing matters related to smuggling.