Money Laundering from Corruption Offence

Money Laundering from Corruption Offence


During a bank’s ongoing review of an account holder, who declared himself as a landlord, was noticed to have received funds aggregating to PKR 8.6 Million in his account through online transfers in a month. Subsequently a sum of PKR 3.2 Million was withdrawn from the account without disclosing the purpose. Moreover, structured cash withdrawals were also observed in the account. On a query by the bank, the customer was reluctant to disclose the sources of funds credited in the account or to provide any documentary evidence to substantiate the credits/debits in the account.

During analysis, it was observed that the suspect had also previously served as a provincial legislator. The suspect’s account was credited with high value funds through online transfers. The funds were then withdrawn through cash and clearing. Average monthly turnover in the account was PKR 2.08 Million. During the period of 2.5 years PKR 56.22 Million was deposited in the account while PKR 54.88 Million was withdrawn. Most of the funds were transferred from the account of an individual maintaining account in a branch situated in an area adjacent to the suspect’s constituency.

Due to the high volume of funds credited in the personal account, it was suspected that he might be involved in abusing his authority as a legislator. Therefore, the financial intelligence was shared with LEA for investigation in the matter.


ML by a Government Official laundered through an integrated scheme involving winning prize bonds, Term Deposit Receipts, Running Finance Facility, and Asset Acquisition. Person A, a Government Official, opened a savings account in XYZ Bank in 2015. Two high value transfers were made by the suspect from his own account maintained in PQR Bank, out of which, half of the amount was placed Term Deposit Receipts (TDRs). Later on, the suspect received prize money which was cleared via cheque and also placed in TDR. The prize money remained invested in TDRs for five months.

The suspect also got a Running Finance facility (loan) from XYZ Bank against security of term deposits. The suspect was issued a high value demand draft in favour of person D from his running financing facility. After 10 months of utilizing running financing facility, the entire bank’s loan liability was paid off in one go through liquidation of TDRs.

This appeared a typical ML arrangement for routing of apparently illegitimate funds through acquisition of winning prize bonds, investing in TDRs, seeking running finance facility, and asset acquisition. The illegitimate funds were suspected to be kickbacks or embezzled public funds, since the suspect was holding a government office entrusted with district management powers. The suspicious transaction was shared with LEA for further proceedings.