The Chief Executives of all

Exchange Companies &

Exchange Companies of ‘B’ Category

Dear Sir/Madam,

Reporting of Suspicious Transaction Reports (STRs)/ Currency Transaction Reports (CTRs) to Financial Monitoring Unit (FMU) Under AML Act, 2010

1. Attention of the Exchange Companies is invited towards compliance of the regulatory & legal requirements of Anti-Money Laundering (AML) /Countering Financing of Terrorism (CFT) regime.
2. It is reiterated that Exchange Companies, being “Financial Institutions” under the Anti-Money Laundering Act 2010, are required to submit Suspicious Transaction Reports (STRs) and Currency Transaction Reports (CTRs) ,as per Section 7 of the AML Act, 2010, to the Financial Monitoring Unit (FMU). The standard templates for STRs & CTRs are part of the AML Regulations 2008, issued under the AML Ordinance 2007 and protected under the AML Act, 2010.
3. In this respect, Exchange Companies are strongly advised to meticulously follow the requirements of the law, and report STRs and CTRs manually or electronically, as per Section 7 of AML Act, 2010, directly to the Financial Monitoring Unit located at 2nd Floor, State Bank of Pakistan Building, I.I. Chundrigar Road, Karachi. The relevant documents may be accessed at the following links:

1. STR Form
   http://www.fmu.gov.pk/docs/Suspicious_Transaction_Report_Form.pdf
   1. STR Guidance Notes (Non-Banking Sector)
      http://www.fmu.gov.pk/docs/Guidance_notes_to_Reporting_Entities_(Non_Bank).pdf
2. CTR Form
   http://www.fmu.gov.pk/docs/Currency_Transaction_Report_Form.pdf
   1. CTR Guidance Notes
      http://www.fmu.gov.pk/docs/CTR_Guidance_Notes.pdf
   2. Observations in CTRs Being Filed by Financial Institution
      http://www.fmu.gov.pk/docs/OBSERVATIONS_IN_CTRs_BEING_FILED_BY_FINANCIAL_I NSTITUTIONS.doc
   3. CTR Threshold – SRO Notification
      http://www.fmu.gov.pk/docs/Currenct_Transaction_Report_Notification.PDF
3. AML Regulations 2008 http://www.fmu.gov.pk/docs/AML_Regulations-2008.pdf
4. AML Act, 2010
   http://www.fmu.gov.pk/docs/laws/AML_ACT_2010.pdf

4. In case of any enquiry, please contact the office of FMU at the following:

Phones: 021- 32453160 Ext 106 and 116

Fax Number: 021-99212512

Email: [email protected] URL: www.fmu.gov.pk

5. It may be clearly noted that Section 33 of the AML Act 2010, inter alia specifically provides for criminal sanctions on failure to file above mentioned reports and for providing false information. Furthermore, in case any EC is found to be in violation of above legal requirements, a simultaneous regulatory action shall be initiated against concerned EC and officials involved as per rules, which may result, among others, in suspension/ cancellation of licenses of the concerned company.

Please bring the contents of the above instructions to the knowledge of all your constituents for strictest compliance.