Adnan Thesis

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Prevalenceof Anti Money laundering in financial

Institutions of Pakistan

____________

A thesis

Presented to

the faculty of

Management Sciences

Bahria University

_______

In Partial Fulfillment

of the Requirements for the

Degree Master in Business Administration

____________

By1

Muhammad Adnan Israr

Registration # 11561


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BAHRIA UNIVERSITY

INSTITUTE OF MANAGEMENT AND COMPUTER SCIENCES

KARACHI

RECOMMENDATION FOR ORAL EXAMINATION

This project/thesis here to attached, entitled, Prevalence of Anti Money laundering in financial

Institutions of Pakistan , prepared and submitted by MuhammadAdnan Israr, in partial

fulfillment of the requirements for the degree MASTER IN BUSINESS ADMINISTRATION, is

hereby recommended for appropriate action.

Date:____________ _________________

Advisor

Name:__________________

PROJECT/ THESIS COMMITTEE

In partial fulfillment of the requirements for the degree of MASTER IN BUSINESS

ADMINSTRATION, this thesis entitled, Prevalence of Anti Money laundering in financial

Institutions of Pakistan, is hereby recommended for Oral Examination.

___________________________

Examiner

Name: __________________

_____________________ ____________________

Examiner Advisor

Name: _________________ Name: ______________

Date: __________________


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BAHRIA UNIVERSITY

INSTITUTE OF MANAGEMENT AND COMPUTER SCIENCES, KARACHI

Project/Thesis:Prevalence of Anti Money laundering in financial Institutions of Pakistan.

Date: ____________

Time: ____________

PANEL OF ORAL EXAMINERS ACTION

_________________________

___________Examiner

Name: _________________

____________________________ ____________

Examiner

Name: _________________

_____________________________

Advisor

Name: _______________

____________________________

Advisor

Name:_____________


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BAHRIAUNIVERSITY

INSTITUTE OF MANAGEMENT AND COMPUTER SCIENCES, KARACHI

APPROVAL SHEET

This Project/ thesis entitled, Prevalence of Anti Money laundering in financial Institutions ofPakistan, prepared and submitted by Muhammad Adnan Israr, in partial fulfillment of therequirements for the degree of MASTER IN BUSINESS ADMINISTRATION has beenexamined and recommended for acceptance and approval.

THESIS COMMITTEE

____________________________

Examiner

Name:_________________

___________________ ____________________

Examiner Advisor

Name:____________ Name:____________

PANEL OF EXAMINERS

Approved by the Committee on Oral Examination with a Grade of __________

____________________________

Examiner

Name:_______________

____________ ______________

Examiner Advisor

Name:_____________ Name:_____________

____________________________________________

Head of the Department Management Sciences


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\\\\\\

ACKNOWLEDEMENT


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ACKNOWLEDGMENT

With great reverence, I wish to express deep gratitude towards Al-Mighty ALLAH who has

blessed me with all that I have done. I also want to thanks Mrs. Ahsan Rizvi, Department of

Management Sciences, Bahria University, under whose dynamic supervision this report has been

completed.

Hope that the knowledge gained through this Research Report will help in the future

endeavors.


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DEDICATION


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DEDICATION

I would like to dedicate my thesis to my Parents, Teachers and Friends.


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TABLE OF CONTENTS

Table of Content

_Toc385139093ABSTRACT .................................................................................................................. 12

CHAPTER 1 ........................................................................................................................................... 14

BACKGROUND & STATEMENT ...................................................................................................... 14

OF PROBLEM ....................................................................................................................................... 15

1. INTRODUCTION .......................................................................................................................... 15

1.1. BACKGROUND OF THE RESEARCH.................................................................................... 15

1.1.1. DEFINITION OF MONEY LAUNDERING......................................................................... 16

1.1.2. THE SCALE OF THE PROBLEM ........................................................................................ 16

1.1.3. ORIGIN OF MONEY LAUNDERING.................................................................................. 17

1.1.4. BACK GROUND HISTORY ................................................................................................. 17


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1.1.5. PROCESS OF MONEY LAUNDERING .............................................................................. 17

1.1.5.1. PLACEMENT ..................................................................................................................... 18

1.1.5.2. LAYERING ........................................................................................................................ 18

1.1.5.3. INTERGRATION ............................................................................................................... 18

1.2. PROBLEM STATEMENT ......................................................................................................... 19

1.3. OBJECTIVE OF THE RESEARCH........................................................................................... 19

1.4. LIMITATION ............................................................................................................................. 19

1.6. SCOPE ........................................................................................................................................ 19

1.7. ASSUMPTIONS ......................................................................................................................... 20

CHAPTER 2 ........................................................................................................................................... 21

LITERATURE REVIEW & ................................................................................................................... 21

STUDIES ................................................................................................................................................ 21

2. LITERATURE REVIEWS ............................................................................................................. 21

2.1. THE BANKING SECTOR ......................................................................................................... 22

2.1.1. SMURFING/ STRUCTURING .............................................................................................. 22

2.1.2. SHELL COMPANIES ............................................................................................................ 23

2.1.3. TELEPHONIC TRANSFER................................................................................................... 23

2.1.4. MONEY EXCHANGER ........................................................................................................ 23

2.1.5. REMITTANCES ..................................................................................................................... 23

2.1.6. HUNDI .................................................................................................................................... 23

2.2. MONEY LAUNDERING IN PAKISTAN................................................................................. 24

2.2.1. METHODS USE IN PAKISTAN FOR MONEY LAUNDERING....................................... 24

2.2.1.1. FORMAL METHODS ........................................................................................................ 24

2.2.1.2. NON FORMAL METHOD ................................................................................................ 24

2.2.1.3. PRIZE BONDS ................................................................................................................... 25

2.2.1.4. REAL ESTAE SCHAMES ................................................................................................. 25

2.2.1.5. RETAIL BUSINESSES/HOTELS BUSINESSES............................................................. 25

2.3. BANK FACE LOSSES BY MONEY LAUNDERING ............................................................. 25

CHAPTER 3 ........................................................................................................................................... 25

RESEARCH METHODOLOGY & PROCEDURE............................................................................. 26

3. RESEARCH METHODOLOY & PROCEDURE.......................................................................... 26

3.1. RESEARCH DESIGN ................................................................................................................ 26


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3.2. PROCEDURE ............................................................................................................................. 26

3.2.1. STAGE 1 ................................................................................................................................. 27

3.2.2. STAGE 2 ................................................................................................................................. 27

3.2.3. STAGE 3 ................................................................................................................................. 27

3.3. DATA COLLECTION METHOD ............................................................................................. 27

3.4. POPULATION ........................................................................................................................... 27

3.5. SAMPLING ................................................................................................................................ 27

3.6. MEASUREMENT ...................................................................................................................... 28

3.7. TIME FRAME ............................................................................................................................ 28

CHAPTER 4 ........................................................................................................................................... 28

PRESENTATION ANALYSIS & .......................................................................................................... 28

FINDINGS ............................................................................................................................................. 29

4. RESULT ANALYSIS AND FINDINGS ....................................................................................... 29

4.1. INTERVIEW ANALYSIS .......................................................................................................... 29

4.1.1. INTERNAL ARRANGEMENT TO CHECK MONEY LAUNDERING............................. 29

4.1.1.1. AUTOMATED SYSTEM OF PRODUCING REPORTS.................................................. 29

4.1.1.2. TRAINING ......................................................................................................................... 30

4.1.1.3. RECORD KEEPING .......................................................................................................... 30

4.1.1.4. DORMANT ACCOUNTS .................................................................................................. 30

4.1.1.5. REMITTANCES ................................................................................................................. 30

4.1.1.6. CASH TRANSACTIONS................................................................................................... 31

4.2. DIFFERENT IMPACT OF MONEY LAUNDERING.............................................................. 31

4.2.1. SOCIAL IMPACT OF MONEY LAUNDERING ................................................................. 31

4.2.2. MACRO ECONOMIC IMPACT OF MONEY LAUNDERING........................................... 31

4.3. LAW RELATING TO MONEY LAUNDERING ..................................................................... 32

4.4. ANALYSIS OF QUESTIONNAIRE.......................................................................................... 33

CHAPTER 5 ........................................................................................................................................... 36

CONCLUSION& ................................................................................................................................... 37

RECOMMENDATION ......................................................................................................................... 37

5. CONCLUSION AND RECOMMENDATIONS............................................................................ 37

5.1. CONCLUSION ........................................................................................................................... 37


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ABSTRACT


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ABSTRACT

The basic objective of this research is to identify and discuss the methods of money laundering used in

Pakistan. Money laundering by using banking channels is not a new thing in Pakistan, after 9/11, the

consequences of money laundering have seen internationally, especially with perspective of Pakistan,

being a Muslim country. In all over the world, the importance of money laundering have seen in last

decade, therefore all banks from all over the work must have develop a confidential unit name is

compliance, who continuously looking and working on the customer suspicious activities through

banking channels.

Pakistan also in the category of high risk jurisdiction, due to fail to implement FTAF recommendations

and tighten the AML/CFT policies through parliament. Pakistan needs to enact AML/CFT act through

parliament.

There are diverse ways that are in practice for money laundering in commercial banks similar to

placement, layering, and integration. The money laundering on one hand creates the social problem like


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concentration of wealth in few hands and on the other hand, from commercial banks point of view it

results in the unbalanced increase in deposit of the banks. The phenomenon of money laundering was not

so much famous before the 9/11. The incidence of 9/11 opened the eyes of financial institutions and the

regulatory bodies specially in the USA because before 9/11 there were many shell banks (fugue banks)

which used to transact with huge funds without any source of origin of these funds, which resulted in the

disaster like 9/11.Money laundering exists in Pakistan, and money launders normally using banking

channels and hundi, hawala system to launder money from one place to other place, detail analysis have

done in this research.

All banks must be focus on KYC process at the time of account opening and ongoing basis; Know your

customer is very crucial part to prevent banks from money laundering.

In this study, researcher define the process of money laundering, and how it works and how Pakistani

banking channels is being used for money laundering, researcher also describe the facts and figures of

money laundering and its impact on country, as a social and as a political. Researcher conducted

interviews, fills up questionnaires from different bankers, reviewed prior history and then researched to

conclude this research with recommendations.

Key words: Money laundering, FATA, AML/CFT, KYC

CHAPTER 1BACKGROUND & STATEMENT


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OF PROBLEM

1. INTRODUCTION1.1.BACKGROUND OF THE RESEARCH

The basic purpose of this research is to find out the process and techniques of money laundering used in

Pakistan with perspective of International arena. In this research we will cover all areas of money

laundering with the help of Banking systems and process in Pakistan. In this research we will also discuss

Pakistan Standing in International prevent money laundering and terrorist financing. After 9/11 the

department of compliance to safeguard banks from money laundering was established and working

efficiently day by day. Pakistan not so far away to stop terrorist financing.SBP AML Regulations quite

enough to strengthen the financial institution from money laundering, but the money launders knows

more ways to convert black money into white money.

Pakistan also passed an ordinance of money laundering AMLO 2007, in which SPB clearly mentioned

thats every step of ML fall in predicate offences. Normally Financial institution is being used by Money

launders as a channel to convert ill-gotten money to legal money. There are many processes to convert

back money into white money.


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There are many ways in practice for money launders to hide true source of income, normally three

processes in banking sectors is being used for money laundering, start with placement, they layering and

finally integration. The money launder on one hand creates intense social issues, like compiling wealth in

few people.

The Phenomenon of money ML was not quite famous before incident of 9/11. Incident of 9/1, opened

eyes of every one, especially for regulatory bodies and financial institutions in USA or outside of the

USA, because before this incident, there were many shell banks or shell financial institutions which were

used to transact hue amount of funds without any source of origin, resulted terrorists finance begins.

After incident of 9/11, there are definite rules and regulations were established at international level to

safeguard money laundering like Money Laundering Act 1986 USA, Criminal of terrorism Act UK.

Money laundering and financial crimes strategy Act 1998, USA.

The SBP took many steps to control the money laundering in banking sectors. In this regard, The SBP has

provided Anti Money Laundering regulations. In the last point, researcher concluded this research that the

money laundering is present in various ways and it is affecting the financial system in Pakistan.

Approximately USD $ 1 billion yearly money laundering arises in Pakistan. In the last researcher

suggested that the Pakistan banks or regulatory authority should take necessary actions to prevent

Pakistani baking systems from money laundering.

1.1.1. DEFINITION OF MONEY LAUNDERINGMoney laundering is basically the concept of converting black money into white money (FATF

Recommendations), Money launderers do to hide true source of funds, Money laundering is basically use

to hide illicit money from its true source.

The conversion of illicit money into legal money is called money laundering. Money launders usually use

banking channels to hide the true source of money.

Money laundering is the process by which hue amount of funds earned by illegally i.e drug trafficking,

terrorist activities or other offenses define by FATF, is given the appearance of having originated from a

legitimate source.

1.1.2. THE SCALE OF THE PROBLEMIn the decade of 1990s, the money laundering was estimated through drug trade by IMF approximately

8% of the world trade equivalent to 2-5 % Global GDP and exceeding $ 100 billion on annual basis. In

2006, IMF estimate money laundering annually amount between 800 to 2 trillion US Dollars in todays

term.


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Many financial institutions were fined due to engaged in the money laundering activities or due to week

process of anti money laundering. In 2004, Riggs Bank of Washington also fined and engaged in the

scandal of money laundering. They were failed to conduct due diligence of huge amount of fund flows

into accounts. They faced $25million of penalty. In 2005, ABN AMRO penalties $ 80million for giving

chance of individuals from Russia and other nations to move more than $ 32billion to shell companies in

USA.

1.1.3. ORIGIN OF MONEY LAUNDERINGThe origination of money laundering is United States; it comes from Mafia Ownership of launders in the

United States, Gangsters, were earning hue amount of cash through gambling, prostitution, extortion, and

then they need to show illegitimate of money as a legitimate source of money. For this conversion, they

were used banking channels.

1.1.4. BACK GROUND HISTORYIn 1920, the term money laundering was emerged, when US Gangster needs to hide their illicit money.

They tried to find a way to hid true source of their income.

In 1980, Money Laundering arises as a crime, essentially, within drug trafficking, terrorism, and high

jacking was also the main reason of money laundering and creates the awareness of the commercial banks

and developed nation regarding the issue of money laundering.

The Process of money ML was not quite famous before incident of 9/11. Incident of 9/11, opened eyes of

every one, especially for regulatory bodies and financial institutions in USA or outside of the USA,

because before this incident, there were many shell banks or shell financial institutions which were used

to transact hue amount of funds without any source of origin, resulted terrorists finance begins.

1.1.5. PROCESS OF MONEY LAUNDERINGThere are three stages or process of money laundering.

Placement Layering Integrating


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1.1.5.1.PLACEMENT

Placement is first stage of the money laundering; this is the initial point when the money launders place

their criminal money into banks.

1.1.5.2.LAYERING

After placement of criminal fund in the bank, money launders creates the complex networks of

transactions among different banks and same banks but different branches and transfer money from one

bank to other bank, that hide the true source of fund and difficult to trace.

1.1.5.3.INTERGRATION

Integration is the third stages of the money laundering in which money launders, buy luxury goods i.eluxury cars, watches, gold, diamonds etc, through illicit money and integrate illegitimate money in the

economy of the country.


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1.2. PROBLEM STATEMENTThe basic purpose and objective of this research is to prevalence of money laundering and its

consequences in banking industry in Pakistan. This research will find out the process of money

laundering and terrorist financing by using banking channel.

1.3. OBJECTIVE OF THE RESEARCHThe main objective of this research is to comprehend the problem that arises due to money laundering, i.e

unbalanced growth in the deposit in banking industry. Following are the some objective that will address

in this research:

To understand the money laundering process and its implication. To find out the risk that associated with money laundering. To find out the current trend of money laundering. To highlights the laws and regulations to prevent banks from money laundering. To highlights the level of satisfaction of Pakistani regulations to prevent money laundering.

1.4. LIMITATIONThe topic is very broad and controversial, and banks are restricted to disclose polices and procedures to

control the money laundering. This research is based on secondary as well as primary source like

interviews and questionnaires thats why its not easy for research to conduct interview from allAML/CFT Analyst, MLRO or CCO of the financial institutions, randomly interviews being conducted to

analyze the current trend of money laundering in Pakistan, and its perspective as well as the role of

compliance in the banking sectors to control the money laundering.

1.5. JUSTIFICATIONThis research study will beneficial for the researcher as well as bankers to analyze the money laundering

and its impact on the banking industry. Bankers will analyze the banking channels and banking that

money launders is using

1.6. SCOPE Due to lack of time, research frame work only limited to Karachi, and sampling also have done

through telephonic conversation with the branches outside of the Karachi.


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Sample size is only limited to banking sectors. Money laundering though other financialinstitution does not part of this research.

1.7. ASSUMPTIONS This research only focus pattern, methods and techniques of money laundering and its impact on

banks instead of actual amount of money launders through banking channels.

No specific name of any bank would be disclose in this research for money laundering No Specific name of any group disclose in this research, who are involved in Money Laundering

by using Banks.


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CHAPTER 2

LITERATURE REVIEW &

STUDIES

2. LITERATURE REVIEWSThe basic purpose of this research is to find out the process and techniques of money laundering used in

Pakistan with perspective of International arena. In this research we will cover all areas of money

laundering with the help of Banking systems and process in Pakistan. In this research we will also discuss

Pakistan Standing in International prevent money laundering and terrorist financing. After 9/11 the

department of compliance to safeguard banks from money laundering was established and working

efficiently day by day. Pakistan not so far away to stop terrorist financing.SBP AML Regulations quite

enough to strengthen the financial institution from money laundering, but the money launders knows

more ways to convert black money into white money.


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Pakistan also passed an ordinance of money laundering AMLO 2007, in which SPB clearly mentioned

thats every step of ML fall in predicate offences. Normally Financial institution is being used by Money

launders as a channel to convert ill-gotten money to legal money. There are many processes to convert

back money into white money.

There are many ways in practice for money launders to hide true source of income, normally three

processes in banking sectors is being used for money laundering, start with placement, they layering and

finally integration. The money launder on one hand creates intense social issues, like compiling wealth in

few people.

The Phenomenon of money ML was not quite famous before incident of 9/11. Incident of 9/1, opened

eyes of every one, especially for regulatory bodies and financial institutions in USA or outside of the

USA, because before this incident, there were many shell banks or shell financial institutions which were

used to transact hue amount of funds without any source of origin, resulted terrorists finance begins.

After incident of 9/11, there are definite rules and regulations were established at international level to

safeguard money laundering like Money Laundering Act 1986 USA, Criminal of terrorism Act UK.

Money laundering and financial crimes strategy Act 1998, USA.

The SBP took many steps to control the money laundering in banking sectors. In this regard, The SBP has

provided Anti Money Laundering regulations. In the last point, researcher concluded this research that the

money laundering is present in various ways and it is affecting the financial system in Pakistan.

Approximately USD $ 1 billion yearly money laundering arises in Pakistan. In the last researcher

suggested that the Pakistan banks or regulatory authority should take necessary actions to prevent

Pakistani baking systems from money laundering.

2.1.THE BANKING SECTOR

Banking sectors s one of the important part of the money laundering, illicit money is being deposited in

their bank accounts followed by withdrawal in different modes like transfers, online and cash withdrawal

etc. Despite of using banking channels, money launders have some issue they have some arguments i.e

banks report to regulatory authorities like FIU, FIA or other law and enforcement agencies, after

withdrawal or deposits huge cash. There are many ways of money laundering. Followings are the terms

that familiarize term money laundering.

2.1.1. SMURFING/ STRUCTURINGStructuring or Smurfing is the techniques that usually money launderers are using. Smurfing or

structuring means breakup of large amount of fund into small numbers that avoiding the threshold of

reporting CTR (Currency transaction reporting) that is $ 10,000 and above, money launders deposits cash


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in structured form followed by withdrawal in transfer form into different accounts or wire transfer

through remittances.

2.1.2. SHELL COMPANIESShell companies also playing a very vital role in money laundering. It is being used in both banking and

non banking sectors. In shell companies, there is no physical place of the business. All transactions are

conducting by professionals on the behalf of beneficial owner. Through the Shell banking, we can not

identify the true beneficial owner of the fund. It is taken by highly professionals, lawyers, accountants,

thats why the real beneficial owner is remain hidden. These professional manage secrecy of the

transactions, they helps for placement of funds and in the last stages integration stage by using fund in

other countries.

2.1.3. TELEPHONIC TRANSFERTelephonic transfers are very common techniques for money laundering and main tool for all stages

because this is very quick transactions methods. It is very difficult for law and enforcement agencies to

trace quickly.

2.1.4. MONEY EXCHANGERMoney exchange companies are main source of money laundering, they are dealing in cash, and cash

mode of transactions one of the suspicious mode and way of money laundering. They are dealing in

different currencies. A wide range of currencies they are offered along with small denomination banks

notes to larger ones and replacing techniques like money orders, etc.

2.1.5. REMITTANCESRemittance is very important tool of money laundering. In remittances, there is less regulatory

requirement than institutions and banks, which provide corresponding service. Money launderers are

using this method to launder money from one country to other country.

2.1.6. HUNDIHundi or Hawala system one of the important process of money laundering, in which a group involved in

money laundering from one place to other place. This system of money laundering is mostly associated

with Asia. This systems is called Underground banking and usually use in Asian Countries. This system

reduces remittances through banks and results a country lose foreign currency. If the country has shortage

of foreign currency then they loses their currency values.


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Hundi or Hawala system is very common in money laundering; they are using banking channels for

routing the money from one place to other places in the transferring mode.

2.2.MONEY LAUNDERING IN PAKISTAN

Pakistan needs to endorse an anti-money laundering laws and regulations, recently parliament has

approved Anti money laundering bill. In current scenario Pakistan is facing intense pressure from internal

agencies against money laundering. After 9/11 incident, Pakistan on the top of the list, after 9/11 incident

Pakistan is facing severe behavior from all of the world, On the Risk rating Pakistan fall in high risk

country, and this is very big challenge for Pakistan to face and especially for trade purposes. As per

FATF, Pakistans policies towards money laundering are not stronger than other countries.

The basic causes of money laundering in Pakistan is cash base economy, there is no proper

documentation in our country thats why we are facing money laundering instances in Pakistan. Hawaland Hundi system is vey lucrative business in Pakistan and its being used to remit fund fro Pakistan to

other countries and from other countries to Pakistan without any resistance. State Bank of Pakistan has

also took many actions to control money laundering by using banking or financial institution. SBP also

supporting global agencies to establish well anti money laundering infra structured, they are established

an independent unit that is working independently along with SBP with the help of international

Agencies. SBP established six regulations to control the money laundering from banking sector.

2.2.1. METHODS USE IN PAKISTAN FOR MONEY LAUNDERINGThere are two methods of money laundering in Pakistan, money launderers are using both methods formal

or informal.

2.2.1.1.FORMAL METHODS

In formal methods, money lauders are sing banking channels, by open an account by fraudulently in

banks then the are use that account for money laundering purposes, other money laundering methods

including Credit Cards, Travelling cheques etc, but these are not common in use or prevailing of money

laundering in Pakistan, due to magnitude of fund.

2.2.1.2.NON FORMAL METHOD

The non formal methods is being used for money laundering is very old method, under the name of Hundi

or Hawal system. His is very common in Pakistan. This is very simple of un traceable method because

cash is being paid from one point and received by other person in other point, without any documentation.


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RESEARCH METHODOLOGY &

PROCEDURE

3. RESEARCH METHODOLOY & PROCEDURE3.1.RESEARCH DESIGN

The major part of this research is based on Primary data. The methodology of the research is descriptive.

Questionnaire is designed to substantiate the results and opinion of the analyst, researchers, bankers and

anti money laundering specialist.

Descriptive method is used for this research, due to its flexibility. Descriptive type of research is to

gathered data in present active form and emphasis on explaining the scenarios instead of judging or

interpreting. Descriptive study is convenient, quick and flexible approach that provides ease to the

researcher; furthermore, researcher can easily do amendment if any new issues or scenario comes during

the research.

3.2.PROCEDURE

The strategy of the research is divided into three different stages.


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3.2.1. STAGE 1In the first stage, data is gathered through different secondary sources, especially, SBP regulations, 40

recommendation of FATF (Financial Action Task Force), different articles, different reviews already

done by different researchers, AML Specialist and AML Analyst. This is detailed and thoroughly study

and takes a-lot concentrations.

3.2.2. STAGE 2In the second stage, a focus group and interviews with different bankers and AML Specialist were

conducted, to indentify the factors of money laundering by using banking channels.

3.2.3. STAGE 3In the third stage, a detailed questionnaire was distributed among the different bankers, and AML

specialist. This stage is very important for analysis, questionnaire was designed very carefully and each

and every question has some worth and values, with the perspective of ML (Money Laundering).

3.3.DATA COLLECTION METHOD

Data collected for this research from two sources, primary and secondary. The data collected trough

Primary source i.e Interviews, focus group, surveys and questionnaire. The data collected through

secondary source i.e SBP regulations, forty recommendations of FATF, AML journals, articles, and

research papers.

3.4.POPULATION

The population of the research depends on all banks operating in Pakistan. The compliance division is

responsible for Money laundering, and implementation of SBP regulations. The focus of this research is

prevalence of money laundering by using banking channels, thats why compliance division is authorize

department to work as a Anti money laundering, so all compliance department of the banks are consider

as a population.

3.5.SAMPLING

The sampling method in the research is used as per our convenience. The respondents of the research

were focus group, interviews were conducted with different AML Analyst, and surveys and

questionnaire were distributed among different bankers.


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The sample size of the focus groups was 6 to 8 money laundering specialist. Some other online interviews

also conducted through out the world.

Standard size questionnaire was selected; total 200 questionnaires were distributed as per our

convenience. Out of 200, only 171 questionnaires were returned.

3.6.MEASUREMENT

This research is measured with the following tools:

Interviews Focus group Questionnaire

3.7. TIME FRAME

The time frame of this research is 12 weeks.

CHAPTER 4

PRESENTATION ANALYSIS &


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FINDINGS

4. RESULT ANALYSIS AND FINDINGS4.1.INTERVIEW ANALYSIS

Detailed interviews were conducted with different bankers, AML specialist; each and every person

provides very effective information. After discussion with them I concluded there remarks with yinterpretation, they highlighted main areas of money laundering and given tips to overcome money

laundering issues. Following are the key factors that minimize the chances of money laundering through

banking channels.

4.1.1. INTERNAL ARRANGEMENT TO CHECK MONEY LAUNDERINGAll banks /DFIs must need to establish well internal control system to reduce the chance of money

laundering. Following are the key concepts that reduce the probability of money laundering.

4.1.1.1.AUTOMATED SYSTEM OF PRODUCING REPORTS

All banks needs to acquired electronic data processing system within the bank through banking

softwares that generate automated reports of transactions for review purposes. Now a days very

advanced level of technologies are using for transactions monitoring that reduces chances of money

laundering.


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4.1.1.2.TRAINING

Staff training is very important part of any job. Banks should develop training centre for branch level,

branches must have to train their relationship managers to know about Anti money laundering, if RM

understand AML procedure then they will use their knowledge to prevent Bank for money laundering.

Being a compliance officer, AML training is basic necessity of their day to day work assignment.

As per AML/CFT regulations R-6, all commercial banks should train their compliance officer at optimum

level to understand the phenomenon of money laundering, thats why they instruct every bank to develop

training centre and train every employees regarding Money laundering and how we protect bank from

money laundering.

4.1.1.3.RECORD KEEPING

Record keeping is very crucial part of any organization, especially for the banks, as per SBP AML/CFT

regulation R-6 all banks/DFIs should keep all record up to 10 years in both form hard as well as soft form.

Complete record of inward and outward remittances and other remittances must be store in safe area.

Record keeping also helps banks to trace any customer with his previous track record in the nutshell,

record keeping helps to prevent banks from money laundering.

4.1.1.4.DORMANT ACCOUNTS

Sudden activity in dormant account seems suspicious and unusual activity in the account and compliance

officer must go trough sudden activity in dormant account and report to higher management to trace and

identify and take corrective measures. All dormant accounts must be active in front of Branch managers

ad account holder himself present in the branch and submit an application to active his dormant account.

Sudden activity in dormant accounts also red flag and one way of placing ill-gotten funds into bank. All

compliance officers must give additional attention to transactions that would happen in dormant accounts.

4.1.1.5.REMITTANCES

One of the ways of money laundering is remittance; it is the easiest way of transfer ill-gotten money fromone place to other place. All compliance officers must pay additional attention in remittance; Money

launders provide false information to remit the fund from one place to other place. All bankers must

identify the actual source of fund before remit the fund. Many instances have seen in remittances that

huge amount of fund transferred abroad without knowing the actual source of fund, and few banks were

penalized.


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All banks are using advance level of system that protects them from money laundering by using

remittance mode of transfer. OFAC, and European Union and other countries have developed list of black

people who are involved in terrorist activities and money laundering, all banks are using good systems

that screen out that list then release any payment, that decrease the chance of money laundering.

4.1.1.6.CASH TRANSACTIONS

Cash transactions is very common pattern of money laundering, banks have to give extra attention in all

cash transactions and they have to report all cash transactions that above 2.5M single transactions. All

bankers must have to understand the importance of money laundering through cash transactions and give

special attention to cash transactions.

4.2.DIFFERENT IMPACT OF MONEY LAUNDERING

There are many impact of Money laundering, some impacts are:

4.2.1. SOCIAL IMPACT OF MONEY LAUNDERINGMoney laundering creates both impacts social and political. Costs of social and political of money

laundering are extremely large, political involvement prevalence the money laundering by using their

political power. Money launders loaded the criminal money into banks and business spoil the social

environment. Illicit money move in the economy and that create bad impact on the economy. Social

environments very affected by money laundering.

4.2.2. MACRO ECONOMIC IMPACT OF MONEY LAUNDERINGThe large flow of illicit money creates the distortions in macroeconomics factors and giving rising trend

in unemployment and stops the economic activities and become cause of money laundering haven. Large

flow of illicit money place in banking industry and thereafter they use illicit money in the economy. The

banking standard also affected by money laundering. The impact of money laundering as a

macroeconomic summarized as under:

Dispute normal business activities and public policy decision making Create distorts in the allocation of financial and banking resources Discourages the inflow of foreign investment Damages the country image and its people Abet corruption in the country Create bad impact on the country currency


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4.3.LAW RELATING TO MONEY LAUNDERING

Following are the laws associated with money laundering that helps to control the money laundering:

Money laundering Act 1986 (USA) Money laundering control Act 1986 (USA) Financial transactions reports Act 1988 (AUS) Criminal of terrorism Act (UK) Money laundering Regulations 1993 (UK) Drug trafficking Act 1994 (UK) Money laundering suppression (USA) Criminal Justice Act 1995 (SCOT)

Proceed of Crime Act 1995 (SCOT) Money laundering and financial crimes strategy Act 1998 (USA) Control of Narcotics substances Ordinance 1995 (PAK)

Mechanism of preventing Banks from Money Laundering


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4.4. ANALYSIS OF QUESTIONNAIRE

When researcher asked this question, does the money laundering exist in Pakistan, then 97% respondent

said yes it exist and it increasing day by day, we need to improve our systems and need to implementAML/CFT measures in all over Pakistan. Money launders usually use banking channels to launder money

over here.

In the above question, respondent said in Pakistan, money laundering usually done by hundi, smurfing, and

money changers. 36% respondent said in Pakistan, money laundering done by using Hundi and 31%respondent said by Banking channels and 16% respondent said by money changer, and 17% respondent

said they are using Smurfing.

97%

3%

Money Laundering Exist in Pakistan

Yes No

Hundi

36%

Smurfing

17%

Banking products

31%

Money Changer

16%

If yes, which Source is used fr money laundering


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When researcher asked the question what level of money laundering exist in Pakistan, 36% respondent said

50% level of money laundering exist and 30% respondent said 75% exist and 19% respondent said 100%

level of money laundering exist in Pakistan.

When the most important question asked with the respondent what is the level of cash transactions, 100%

respondent said there is no limits of cash transaction in the banking sector, and this is very serious issues

and no one giving so much interest if the financial institution give attention in this area then we can stop

money laundering.

0% - 25%

15%

25% - 50%

36%

50%- 75%

30%

75% - 100%

19%

Level of Money Laundering Exist in Pakistan

0%0%

100%

Banks allow Cash Transactions deposits at a

time.

1M - 10 M 10M - 20M No Limits


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When researcher asked this question, does AML and KYC goes hand to hand, the 57% respondent said

yes, there is directly link between AML and KYC, if you know your customer then you can easily

categorize them according to their risk, KYC is vey important part of the customer profiling. 31%

respondent said they dont know and 1% respondent said no, both are separately goes, money launder are

very cleaver and they are hiding them self and no one can judge easily.

Does a bank use KYC as a on going process? 63% respondent said yes it is on going process and banks

revised customer KYC as per customer profile, and 37% respondent said they use KYC only at the time

of account opening.

Yes

57%

No

12%

Dont Know

31%

Does Anti Money Laundering and KYC go hand in

hand

Ongoing process

63%

At the time of

account opening

37%

Do Banks use KYC as


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Page | 36

Staff training is very important part of AML/CFT unit. If the analyst not well educated to related filed

then how can he analyze complex situations, 36% respondent said they get trained only annual basis, and42% respondent said they get training on every six months and only 22% compliance officers said they

get training on quarterly basis. As per SBP AML/CFT regulations point no 6, every banks must trained

their compliance officers at least once a year. Its is mandatory requirement for every banks.

CHAPTER 5

22%

42%

36%

Staff Training

Quarterly Semiannually Annually


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Page | 37

CONCLUSION&

RECOMMENDATION

5. CONCLUSION AND RECOMMENDATIONS5.1.CONCLUSION

The basic objective of this research is to identify and discuss the methods of money laundering used in

Pakistan. Money laundering by using banking channels is not a new thing in Pakistan, after 9/11, the

consequences of money laundering have seen internationally, especially with perspective of Pakistan,

being a Muslim country. In all over the world, the importance of money laundering have seen in last

decade, therefore all banks from all over the work must have develop a confidential unit name is

compliance, who continuously looking and working on the customer suspicious activities through

banking channels.

Pakistan also in the category of high risk jurisdiction, due to fail to implement FTAF recommendations

and tighten the AML/CFT policies through parliament. Pakistan needs to enact AML/CFT act through

parliament.


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There are diverse ways that are in practice for money laundering in commercial banks similar to

placement, layering, and integration. The money laundering on one hand creates the social problem like

concentration of wealth in few hands and on the other hand, from commercial banks point of view it

results in the unbalanced increase in deposit of the banks. The phenomenon of money laundering was not

so much famous before the 9/11. The incidence of 9/11 opened the eyes of financial institutions and the

regulatory bodies specially in the USA because before 9/11 there were many shell banks (fugue banks)

which used to transact with huge funds without any source of origin of these funds, which resulted in the

disaster like 9/11.Money laundering exists in Pakistan, and money launders normally using banking

channels and hundi, hawala system to launder money from one place to other place, detail analysis have

done in this research.

To prevent the banks from money laundering, USA and other countries have develop some laws and

ACTs to prevent banks from money laundering. USA is very active member in this field. Financial

Action Task force is doing excellent work in to prevent financial institution from money laundering.

In this study, researcher define the process of money laundering, and how it works and how Pakistani

banking channels is being used for money laundering, researcher also describe the facts and figures of

money laundering and its impact on country, as a social and as a political. Researcher conducted

interviews, fills up questionnaires from different bankers, reviewed prior history and then researched to

conclude this research with recommendations.

5.2.RECOMMENDATION

On the basis of findings, analysis and review interviews and literature reviews, researchers recommended

following few things that would be beneficial to prevent the banking sector from money laundering.

Banks should attempt sensible efforts to focus the customer identification, and must verify and dothe effective measures for checking the bonafides of new customer.

Banks/DFIs must be participation with law implementation orgs. With any obligations forced byprinciples identifying with client privately, banks should collaborate completely with national law

implementation orgs including, where there are sensible reason for suspecting cash washing,

taking suitable measures which are steady with the law.

Banks/DFIs must need to enhance due diligence to manage suspicious and unusual or un-economic transactions. They must need to investigate the suspicious transactions with advance

level of monitoring system.

All banks/DFIs must follow SBP regulation to prevent Banks from money laundering.


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All banks must need to develop or establish their own AML/ KYC policy to prevent bank from

money laundering.

They must need to establish proper handling suspicious transactions. They must file suspicious transactions report to FMU. They must develop Compliance department to strengthen the banking system. Pakistan must need to develop the national anti money laundering database and keeping safely

information submitted by financial institutions.

Pakistan must need to implement World wide recommendations ad must establish their policy onthe basis of FATA 40 Recommendations

By implementation of above mentioned recommendations, the relevant authorities should further

reinforce the battle against the cash launderer and demonstrate to them that there is no spot to cover

up.

Finally, Commercial banks are urged to create programs against money laundering that negligibly

would see the advancement of strategies and methods and the contribution of administration all the

while. On going representative, preparing projects and review checks of the framework are likewise

proposed.


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Page | 40

REFERENCES

1. Andreas, Peter, and Ethan, 2006 Origins and transformation of international crime control,Oxford university press

2. Arjauo, Ricardo Azevedo and Moreira, Tito Belchior, 2005 Inter-Temporal Model of DirtyMoney, Journal of money laundering control

3. Bell. R.E, 2001 Discreation and Decision Making in Money laundering Prosecutions:. Journal ofMoney Laundering Control, Vol 5 No 1.

4. Khan Nawz Gul 2002, Anti Money Laundering measures, The Institute ofBankers Pakistan.5. Wolfsburg AML Principles6. Norgren C. 2004. The control of risks associated with crime, terror and subversion, Journal of

money laundering control, 7(3).


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7. Warren, M.E. 2006, Political Corruption as duplicitous Exclusion. PS Political science andPoliticcs, 37 (4).

8. Asian development banks 2003, Enhancing the sian development Banks role in CombatingMoney Laundering and the financing of terrorism.

9. SB regulations AML/CFT10.Risk based approach (RBA)11.FATF Recommendations


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Page | 42

APPENDIX A: QUESTIONNAIRE

RESEARCH THESIS

Prevalence of money laundering & its compliance in commercial Banks of

Lahore.

Name of the Bank__________1. Does money laundering exist in Pakistan?

o Yeso Noo Do not know2. If yes, which source is used for money laundering in Pakistan?o Shall Bankso Hundio Commercial Bankso Money Changerso Smuarfingo Hundi and Money Changerso Any other3. To what extent money laundering exist in Pakistan?

o 0% - 25%o 26%- 50%o 51% - 75%o 75% -100%o To certain extent________Prevalence of money launder ing in Commercial Bank of Pakistan 944. To what extent bank allow the money to be deposit by the customer at onetime?o Rs.100Rs.1 laco Rs.2 lac10 laco Rs.1millionRs.10milliono Rs.10millionRs.20 million

o To certain extent_________5. To what extent bank allow the depositor, to deposit money over the countertransaction?o Rs.100Rs.1 laco Rs.2 lac10 laco Rs.1millionRs.10milliono Rs.10millionRs.20 milliono To certain extent_________6. What is the maximum interest rate on deposit, when deposit is greater then 1million?o 0% - 10%o 11% - 20%

o 21% - 30%o 31% - 40%o To certain extent_________7. Does bank allow the depositor to transfer money from one bank to another bankor other country banks?o Yeso No

Prevalence of money launder ing in Commercial Bank of Pakistan 958. If yes, then what effect on the performance of the bank?


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o Increase the performance.o Decrease the performance.o Decrease the deposit.o No effect.9. To what extent (minimum to maximum) permission is granted to the customerby the bank to transfer money from on bank to another bank or from one

country to another country?o Rs.1000 - Rs. 1 Laco Rs. 1Lac - Rs. 1 milliono Rs. 1 million - Rs. 10 milliono Rs.10 millionRs. 20 milliono To certain extent_________10. Does bank allow the non-account holder to transfer money to the other bank orto another branch of the same bank, or from other country bank?o Yeso No11. To what extent the bank allow the non-account holder to transfer the money atone time?

o Rs 1000Rs. 10000o Rs. 10000Rs. 1 Laco Rs. 1 LacRs.5 Laco Rs. 5 LacRs 10 Laco To certain extent________12. To what extent the bank allow the non account holder to transfer amount to his

Prevalence of money launder ing in Commercial Bank of Pakistan 96own account?o Rs 1000- Rs 10000o Rs 10000Rs. 1 Laco Rs. 1 LacRs. 5 Laco To certain extent________

13. To what extent (minimum to maximum) transfer fee is charged by the bankwhen the amount is transferred from one destination to another destination?o 0% -10%o 11% -20%o 21% -30%o 31% - 40%o To certain extent______14. Does anti-money laundering and KYC go hand in hand?o Yeso Noo Does not know15. Which identifying bank systems will you introduce as a result of KYC?

o Customer informationo Customer nature of businesso Customer source of incomeo All of the above16. Do Banks use KYC as?o Ongoing processo It done when bank need informationo When SBP advice the Banks.o To be conducted at the time when bank entering into a formal


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relationship with Customer.Prevalence of money launder ing in Commercial Bank of Pakistan 97o All of above17. How can bank recognize the customer which has never been seen before?o Introductiono ID card

o Referenceo All of above18. Which elements are used to manage the money laundering risk in the bank?o Senior management oversighto Well defined organizational structure and staffingo Independent monitoring and assessmento Ongoing interaction with audit and risk review and other controlfunctions.o All of the above19. Which Customers must be identified by the bank?o Worthy customerso High risk customers

o Non resident customerso Resident customerso All of the above20. How money laundering effect the bank?o Unbalanced growth in deposit.o Provide liquidity position.o Performance increase.o Risk Increase.o Deposit increase.

Prevalence of money launder ing in Commercial Bank of Pakistan 98o All of above.21. If money laundering effect on the bank then which type of risk create money

laundering for the bank.o Reputation risko Credit risko Operational risko Compliance risko All of above22. Does the bank take steps to understand the normal and expected transactions ofits customers based on its risk assessment of its customers?o Yeso No23. Which prudential regulation is implemented by the bank to identify thecustomer?

o KYCo Anti money Launderingo both24. How frequently are your staffs trained on KYC processes?o Quarterlyo Semiannuallyo Annuallyo Both25. Do you have any suggestion about the anti money laundering?


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Page | 45

Prevalence of money launder ing in Commercial Bank of Pakistan 99

APPENDI X B: Glossary

Money launderingThe process by which the proceeds of crime are converted into assets which appear tohave a legitimate origin.

Anti money laundering

Anti money laundering, the process by which efforts. are made to prevent and, detectmoney laundering

ComplianceThe process complying with laws, regulations and guidance.

Base lThe Basel Committee formulates broad supervisory standards and guidelines andrecommends statements of best practice for banking supervisory authorities toimplement in ways best suited to their own national systems.

Basel IIThe Basel committee of banking supervisions. Basel II helped to strengthen thesoundness and stability of the international banking system as a result of the highercapital rations it required.

Know Your Customer (KYC)The requirement that financial institutions understand who their customers are, whichincludes obtaining documentation to verify identity, address source of Income.

Non-Bank institutionNon-Banking Financial Institutions By law or regulation, the jurisdiction requires nonbank financial institutions to meet the same customer identification standards andadhere to the same reporting requirements that it imposes on banks.

Data ProtectionThe regulation of the use of personal data held by businesses, covering the way suchInformation is handled and the rights of individuals to gain access to information heldabout them.

Dormant Accounts

These are bank accounts where there have been no transactions (deposits orwithdrawals for a period of time (usually at least a year) and where the account holderhas made no contact with the bank during the period or following attempts made bythe bank to make contact with the account holder.

Terrorist FinancingThe financing of terrorist acts, terrorists, and terrorist organizations

Financial Action Task Force (FATF)Financial action task force is an inter-governmental body; its Secretariat is based at theOrganization for Economic Co-operation and Development (OECD). FATFs purposeis to develop and promote policies to combat money laundering and terrorist financing.It currently has 29 member countries.

Prevalence of money launder ing in Commercial Bank of Pakistan 100

Transaction Monitoring: Monitoring customer transactions for indications ofsuspicious activity report to be filed.


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Page | 46

APPENDIX-A


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Page | 47

QUESTIONNAIRERESEARCH THESIS

Name of the Bank__________1. Does money laundering exist in Pakistan?o Yes

o Noo Do not know

2. If yes, which source is used for money laundering in Pakistan?o Shall Bankso Hundio Commercial Bankso Money Changerso Smuarfingo Hundi and Money Changerso Any other

3. To what extent money laundering exist in Pakistan?o 0% - 25%o 26%- 50%o 51% - 75%o 75% -100%o To certain extent________

4. To what extent bank allow the money to be deposit by the customer at one time?o Rs.100Rs.1 laco Rs.2 lac10 laco Rs.1millionRs.10milliono Rs.10millionRs.20 million

o To certain extent_________

5. To what extent bank allow the depositor, to deposit money over the counter transaction?o Rs.100Rs.1 laco Rs.2 lac10 laco Rs.1millionRs.10milliono Rs.10millionRs.20 milliono To certain extent_________

6. Does bank allow the depositor to transfer money from one bank to another bank or other countrybanks?o Yes

o No

7. If yes, then what effect on the performance of the bank?o Increase the performance.o Decrease the performance.o Decrease the deposit.o No effect.


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Page | 48

8. To what extent (minimum to maximum) permission is granted to the customer by the bank to transfermoney from on bank to another bank or from one country to another country?o Rs.1000 - Rs. 1 Laco Rs. 1Lac - Rs. 1 milliono Rs. 1 million - Rs. 10 milliono Rs.10 millionRs. 20 million

o To certain extent_________

9. Does bank allow the non-account holder to transfer money to the other bank or to another branch of thesame bank, or from other country bank?o Yeso No

10. To what extent the bank allow the non-account holder to transfer the money at one time?o Rs 1000Rs. 10000o Rs. 10000Rs. 1 Laco Rs. 1 LacRs.5 Laco Rs. 5 LacRs 10 Lac

o To certain extent________

11. To what extent the bank allow the non account holder to transfer amount to his own account?o Rs 1000- Rs 10000o Rs 10000Rs. 1 Laco Rs. 1 LacRs. 5 Laco To certain extent________

12. To what extent (minimum to maximum) transfer fee is charged by the bank when the amount istransferred from one destination to another destination?o 0% -10%o 11% -20%

o 21% -30%o 31% - 40%o To certain extent______

13. Does anti-money laundering and KYC go hand in hand?o Yeso Noo Does not know

14. Which identifying bank systems will you introduce as a result of KYC?o Customer informationo Customer nature of business

o Customer source of incomeo All of the above

15. Do Banks use KYC as?o Ongoing processo It done when bank need informationo When SBP advice the Banks.o To be conducted at the time when bank entering into a formal relationship with Customer.o All of above


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Page | 49

16. How can bank recognize the customer which has never been seen before?o Introductiono ID cardo Referenceo All of above

17. Which elements are used to manage the money laundering risk in the bank?o Senior management oversighto Well defined organizational structure and staffingo Independent monitoring and assessmento Ongoing interaction with audit and risk review and other control functions.o All of the above

18. Which Customers must be identified by the bank?o Worthy customerso High risk customerso Non resident customerso Resident customers

o All of the above

19. If money laundering effect on the bank then which type of risk create money laundering for the bank.o Reputation risko Credit risko Operational risko Compliance risko All of above

20. Which prudential regulation is implemented by the bank to identify the customer?o KYC

o Anti money Launderingo both

21. How frequently are your staffs trained on KYC processes?o Quarterlyo Semiannuallyo Annuallyo Both


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Page | 50

APPENDIX-B


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Page | 51

Glossary

Money laundering

The process by which the proceeds of crime are converted into assets which appear tohave a legitimate origin.

Anti money laundering

Anti money laundering, the process by which efforts. are made to prevent and, detectmoney laundering

ComplianceThe process complying with laws, regulations and guidance.

Base lThe Basel Committee formulates broad supervisory standards and guidelines andrecommends statements of best practice for banking supervisory authorities toimplement in ways best suited to their own national systems.

Basel IIThe Basel committee of banking supervisions. Basel II helped to strengthen thesoundness and stability of the international banking system as a result of the highercapital rations it required.

Know Your Customer (KYC)The requirement that financial institutions understand who their customers are, whichincludes obtaining documentation to verify identity, address source of Income.

Non-Bank institution

Non-Banking Financial Institutions By law or regulation, the jurisdiction requires nonbank financial institutions to meet the same customer identification standards andadhere to the same reporting requirements that it imposes on banks.

Data ProtectionThe regulation of the use of personal data held by businesses, covering the way suchInformation is handled and the rights of individuals to gain access to information heldabout them.

Dormant Accounts

These are bank accounts where there have been no transactions (deposits orwithdrawals for a period of time (usually at least a year) and where the account holderhas made no contact with the bank during the period or following attempts made bythe bank to make contact with the account holder.

Terrorist Financing

The financing of terrorist acts, terrorists, and terrorist organizations

Financial Action Task Force (FATF)Financial action task force is an inter-governmental body; its Secretariat is based at theOrganization for Economic Co-operation and Development (OECD). FATFs purposeis to develop and promote policies to combat money laundering and terrorist financing.It currently has 29 member countries.Prevalence of money launder ing in Commercial Bank of Pakistan 100

Transaction Monitoring: Monitoring customer transactions for indications ofsuspicious activity report to be filed.

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