of the Exchange Companies and Exchange
Companies of ‘B’ category
is invited towards Para 14, Chapter
6 of the Exchange Companies Manual –
2017 whereby it has been advised to
ensure strict compliance of Statutory
Regulatory Orders (SROs) and Notifications
issued by the Government of Pakistan
under the United Nations (Security Council)
Act, 1948 and The Anti Terrorism Act
(ATA), 1997 respectively.
2. In this regard,
detailed guidelines on Targeted Financial
Sanctions (TFS) for prevention of Terrorism
Financing and Proliferation Financing
under UNSC Act, 1948 and ATA, 1997 are
attached as annexure. In the light of
attached guidelines, Exchange Companies
and Exchange Companies of ‘B’
category are required to ensure meticulous
compliance of the statutory and regulatory
framework. Further, following minimum
measures shall be taken:
a. No services shall
be provided to individuals designated
under UNSC Resolutions or proscribed
under ATA, 1997.
b. The company’s Information System
managing the transactions shall be able
to screen the designated and proscribed
individual on real time basis.
c. The updated consolidated list of
persons designated / proscribed under
UNSC Act 1948 and ATA, 1997 respectively
shall be updated in the company’s
Information System and should be available
throughout the company’s network
including franchises/third party payment
booths etc. SBP during the course of
inspection would check the availability
of these updated lists in Exchange Companies.
d. Unique Identification Numbers e.g.
CNICs, Passports etc. available in the
UNSC Sanction Lists and lists of proscribed
individuals under ATA, 1997 shall be
blocked in company’s information
system. Any similarity between the identification
information of the customer and that
of designated / proscribed entities
and persons should be properly investigated
for necessary action, as per law, including
reporting to the Financial Monitoring
e. Special attention shall be given
to the screening of remittances received
from or transfer made to ‘high-risk’
jurisdictions, as identified by Financial
Action Task Force (FATF).
f. Internal controls shall be strengthened
by means of deploying adequate systems
for real time screening and allocating
sufficient/trained resources to ensure
meticulous compliance of TFS regime.
g. Antecedents of all employees, franchise
owners and their employees alongwith
the persons associated with the third
party business relationships e.g. landlords,
vendors etc. shall be reviewed on an
ongoing basis to ensure that no designated/proscribed
individual is associated/working with
the Exchange Companies and Exchange
Companies of ‘B’ category.
h. Trainings on the subject matter shall
be arranged for all the staff/officers
including the personnel of third parties
3. Government of Pakistan
has already prescribed penalty up to
Rs. 10 million for non-compliance of
sanctions regime under the United Nations
(Security Council) Act, 1948 and the
Anti-Terrorism Act, 1997.
4. Failure to comply
with the above instructions shall also
attract regulatory action under the
relevant provisions of Foreign Exchange
Regulation Act, 1947 in addition to
penalties prescribed under other laws.
5. Please bring the
above to the notice of all your constituents.