Pakistan’s monthly TBML-related suspicious transactions volume increased by an average of 398% after the Asian Development Bank (ADB) in collaboration with the United Nations Office on Drugs and Crime implemented a pilot project to create suspicious transaction reports tailored to trade transactions, deliver extensive TBML training, and advance collaboration between agencies and countries in fighting TBML.
Based on data provided by Pakistan’s Financial Monitoring Unit (FMU). From July 2023 to June 2024, the FMU recorded a monthly average of 191 reports related to suspicious trade transactions, whereas the monthly average pre-pilot was just 38.
Ten of the largest banks in Pakistan participated in the pilot. The pilot numbers are still conservative given that only 10 out of the 40 banks in Pakistan were included in the pilot.
The FMU observed that during the pilot, banks provided more detailed reasons for reporting each TBML-related STR, which suggests that they conducted closer scrutiny of trade documents.
The pilot provided greater ease for banks in Pakistan to choose from a dropdown selection of TBML indicators. With the enhancements in goAML data elements and the STR format, Pakistan’s FMU saw increased filing of TBML-related STRs by banks and other reporting entities. Furthermore, the FMU received more information requests from law enforcement agencies in Pakistan to collect cross-border data to aid TBML investigations.
Pakistan’s FMU identified the types of goods commonly linked to suspicious trade as follows: solar panels, textile, chemicals, rice, and industrial equipment (Table 5). The FMU found that TBML could be used by criminals to move contraband, such as illegal drugs, across borders, but that activity is commonly disguised as other goods linked to legitimate trade. From pilot data, the FMU saw how criminals resort to “underinvoicing” to evade customs duties and taxes while settling remaining balances through accounts maintained abroad.
According to the FMU, banks provided overwhelmingly positive feedback on the enhanced functionality and related processes, citing the ease of reporting trade-related suspicions through the new STR-TBML data elements. The law enforcement agencies also praised how the initiative has enabled them to utilize the financial intelligence, which aids in the detection and prevention of illicit financial activities.