Islamabad, 30 September 2025 — In ongoing negotiations over Pakistan’s economic programme, the International Monetary Fund (IMF) has strongly urged Islamabad to take concrete steps against trade-based money laundering (TBML). The call comes as part of the second economic review tied to a $1.2 billion tranche from the IMF.

Sources say the Fund has laid down a set of tough demands — from tighter monitoring of nonfinancial sectors to the adoption of an electronic procurement system — arguing that legal loopholes and weak oversight are being exploited for illicit finance.

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What the IMF Wants: Key Measures & Targets

According to media reports:

• Pakistan must monitor sectors including lawyers, law firms, accountants, auditors, real-estate agents, and traders dealing in gold, silver, gemstones, and other precious metals.
• Authorities should emphasize identifying beneficial owners behind companies, trusts, and financial entities — not just the legal names on paper.
• The IMF has pressed for an electronic procurement system for public projects and contracts, to reduce human interference, increase transparency, and prevent manipulation.
• Disposal or sale of state-owned or redundant assets must follow clearly published,.

These recommendations are not new in Pakistan’s reform dialogue: the IMF has previously flagged weaknesses in AML/CFT (Anti-Money Laundering / Combating Financing of Terrorism) frameworks, especially when it comes to TBML and beneficial ownership transparency.

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Why the IMF Is Pushing So Hard

1. TBML is a stealth route
   Trade-based money laundering lets illicit funds move under the cover of legitimate imports or exports. Over- or under-invoicing, falsified trade documents, or inflated shipping costs are common tactics. By targeting this, the IMF aims to close a “hidden” flow of dirty money that weakens revenue systems and governance.
2. Cross-sector risks
   When lawyers, auditors, real-estate agents or precious-metal traders are weakly supervised, they can serve as conduits or facilitators. The IMF sees them as “gatekeepers” whose oversight is vital.
3. Conditionality & credibility
   With a big tranche on the line, the Fund is walking a tightrope: show flexibility where needed, but insist on structural reforms to avoid backsliding.
4. Global standards & reputational risk
   Pakistan must maintain credibility with international lenders, FATF (Financial Action Task Force) watchers, and donors. Weaknesses in money-laundering framework could threaten future support or even its standing with FATF.

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Challenges Ahead & Risks

• Implementation is tough: Passing rules is one thing; enforcing them in far-flung districts or opaque sectors is another.
• Resistance from powerful interests: Some of the sectors to be monitored have entrenched influence and may push back.
• Data & capacity gaps: Beneficial ownership registries, digital systems, and robust auditing capacity need build-out.
• Balancing speed and depth: The IMF wants fast reforms, but overly hasty plans may backfire or be superficial.
• Political risk: If perceived as external pressure, reforms could generate political backlash.

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What to Watch

• Legislative moves / regulation drafts — Will the government table bills or regulations on beneficial ownership, sector monitoring, procurement?
• E-procurement deployment — Whether tenders, bid evaluation, and asset sales shift online in visible ways.
• Reports submitted to IMF — The quality, detail, and timelines of Pakistan’s risk assessments and implementation plans.
• Institutional coordination — Whether FMU, SECP, FBR, SBP, audit bodies work in sync or remain siloed.
• Pushback or delays — From stakeholders, courts, or bureaucracy — delays may signal lack of real commitment.