Between 4th-20th November 2019, FMU in collaboration with SECP and UNODC has conducted multiple AML/CFT awareness sessions for SECP regulated Reporting Entities which include AMCs, Securities Brokers, Life and General Insurance/Takaful Companies, NBFIs, Commodities Brokers, etc in Karachi, Islamabad and Lahore. Total 15 awareness sessions were conducted at Marriot Hotel-Karachi, Serena Hotel-Islamabad and Four Season Sheraton Hotel-Lahore.

During these sessions, the participants of the training were initially briefed regarding ML/TF and its context in light of FATF recommendations &/or domestic laws and regulations. The session was concluded with imparting detailed training to the participants with respect to registration process on goAML and reporting of STRs/CTRs through goAML. The risks associated with this sector in light of findings of National Risk Assessment on ML of Pakistan were communicated.

The participants raised various questions with respect to laws and regulations in Pakistan. The implementation of UNSCRs, specifically UNSCR 1267 & UNSCR 1373, was widely discussed and questions related to identification of individuals/entities listed under UNSCRs or domestic laws were addressed.

The major focus of the questions raised by the participants was the ‘source of funds’ and the scenarios for reporting of STRs to FMU. Some of the participants were also of the concern whether the relationship with the client be continued after the reporting of suspicions to FMU or else the relationship may be terminated. The matter was well explained for decision making in this regard in relation to the level of risks posed by their client. Multiple, STR reporting scenarios for SECP regulated reporting were also discussed with the participants.”