The State Bank of Pakistan [“SBP”] has issued framework for Managing Risks of Trade Based Money Laundering and Terrorist Financing vide Circular No. 4 dated 14 October 2019. The objective is to reinforce trade related Anti Money Laundering and Combating Financing Terrorism [“AML/CFT”] regime and preserve foreign exchange.

It includes amongst other things, that Banks are responsible to make policies and procedures for price verification and suspicious transaction reporting mechanism and verify the prices of underlying contracts from reliable sources. Carry out assessment of prices of underlying contracts on post transaction basis which has to be concluded within 30 days of post transaction basis.