How are the requirements of AML/CFT applicable on Financial Institutions regulated by the SECP when money is routed through banking channels?

Financial institutions means any natural or legal person who conducts as a business one or more of the following activities or operations for or on behalf of a customer:
i. Acceptance of deposits and other repayable funds from the public;
ii. Lending;
iii. Financial leasing;
iv. Money or value transfer services;
v. Issuing and managing means of payment (e.g. credit and debit cards, cheques, traveller’s cheques, money orders and bankers’ drafts, electronic money);
vi. Financial guarantees and commitments;
vii. Trading in:
a. money market instruments (cheques, bills, certificates of deposit, derivatives etc.);
b. foreign exchange;
c. exchange, interest rate and index instruments;

d. transferable securities;
e. commodity futures trading.
viii. Participation in securities issues and the provision of financial services related to such issues;
ix. Individual and collective portfolio management;
x. Safekeeping and administration of cash or liquid securities on behalf of other persons;
xi. Otherwise investing, administering or managing funds or money on behalf of other persons;
xii. Underwriting and placement of life insurance and other investment related insurance;
xiii. Money and currency changing.
The risk of money laundering in Non-Bank Financial Institutions (NBFIs) may not lie in the placement stage but rather in the layering and integration stages of money laundering. The National Risk Assessment has highlighted the vulnerabilities and threats in terms of both money laundering and terrorist financing in these sectors. Accordingly, NBFI is obliged to comply with FATF recommendations even if money is routed thorough the banking channel.