The transactional activity in the account of Ms. KZ was reportedly suspicious as high value funds were transacted from the accounts which apparently did not align with her profile. Further, the source of funds and true beneficiary of funds were also unclear.
Reportedly, Ms. KZ was a salaried individual, a marketing manager for ABC (Pvt) Company. She was maintaining multiple local and foreign currency accounts at different banks wherein a high level of transactional activity was observed. A rapid surge in her transactional activity was noted when a significant amount of funds were deposited in her PKR account in the form of cash deposits during the month of June 2020.
Upon inquiry by the bank about the funds, Ms. KZ stated that the funds were the settlement amount received from her ex-in-laws after her divorce and she also benefited from the Tax Amnesty Scheme announced by the Government in 2020. However, the justification provided by her was not satisfactory to the bank. The funds were immediately withdrawn through cash withdrawals (to purchase foreign currency), issuance of pay orders (to purchase properties) and clearing of cheques (to her own account in another bank). The cash withdrawn from her account was used to purchase foreign currency which was afterwards deposited into her foreign currency account. The foreign currency that was deposited was finally remitted out of country. Further, the analysis revealed that Ms. KZ purchased properties and remitted a significant sum of foreign currency out of country from her own accounts.
During the analysis, it was found that Ms. KZ was the daughter of Mr. ZM, who was a senior level retired government official and now the CEO of ABC (Pvt) Limited and Ms. KZ was an employee of the company. It was ascertained from the asset declaration forms and tax returns of Ms. KZ that she declared assets of PKR 260 million (approx. USD 1,314,834) in the year APG Typologies Report 2022 100 2019-20. The declared assets decreased to PKR 150 million (approx. USD 758,558) in the year 2020-21 due to personal expenses of PKR 10,000,000 (approx. USD 50,570) and the gifting of PKR 100,000,000 (approx. USD 505,705), thus raising suspicion about the legitimacy of the funds and their beneficial ownership as declared in the Amnesty Scheme by Ms. KZ.
As the Amnesty Schemes did not provide immunity from the application of the Anti-money laundering Act (AMLA), 2010 in Pakistan, the financial intelligence was shared with an LEA to investigate the source and beneficiary of the funds declared by Ms. KZ in the Amnesty Scheme.