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FATF & Pakistan’s faulty action plan   

Huzaima Bukhari, Dr. Ikramul Haq & Abdul Rauf Shakoori

Under the Anti-Money Laundering Act, the Federal Board of Revenue is responsible for ensuring that designated non-financial businesses and professions (DNFBPs) including real estate agents, dealers in precious metals and stones, and FBR-supervised accountants comply with anti-money laundering and counter financing of terrorism obligations. Financial institutions, lawyers, law firms, notaries and non-FBR-supervised accountants are supervised by other competent authorities and self-regulatory bodies—Federal Board of Revenue on its website under the heading “ANTI-MONEY LAUNDERING AND COUNTER FINANCING OF TERRORISM (AML/CFT) FOR DNFBPS”.

Pakistan’s efforts to comply with conditions of Paris-based Financial Action Task Force (FATF) since 2018 to come out of grey list have been elaborated in detail in Pakistan Tackling FATF: Challenges and Solutions, coauthored by us. This book highlights critical shortcomings in our laws and their enforcement to counter terrorist financing, money laundering, tax evasion and all other financial crimes. It precisely pinpoints the weaknesses in the existing anti-terrorism, anti-money laundering, tax and other laws, contradictory provisions and policies coupled with faulty strategy and lack of a comprehensive plan to uproot these menaces. In the end, it also suggests a pragmatic model for not only coming out of the grey list of FATF but for our own survival, devise and implement a system for countering all the threats against our national security. As expected, our politicians and policy makers seldom read and write and as expected they ignored the book as well as many articles written by us, individually and jointly.

The FATF in its latest communique said: “we take note of the significant progress made on a number of action plan items. To date, Pakistan has made progress across all action plan items and has now largely addressed 21 of the 27 action items. As all action plan deadlines have expired, the FATF strongly urges Pakistan to swiftly complete its full action plan by February 2021—Jurisdictions under Increased Monitoring–23 October 2020, Financial Action Task Force.

The deadline of February 2021 is fast approaching and the Government’s stance is that it has already passed all the required legislations (main laws and rules). On September 12, 2020, the Parliament adopted amendments in money-laundering and terrorism financing laws by passing three bills at a joint sitting of the National Assembly and Senate, though the Opposition resisted and voiced their concerns. The Government used it as “blackmailing” to get immunity from criminal cases—some at investigation stage by National Accountability Bureau (NAB) and some sub judice in various courts. All the Opposition parties are now united under Pakistan Democratic Movement (PDM) demanding resignation of Prime Minister and fresh elections. This confirms that on vital issues like combatting money laundering and terrorist financing, countering corruption and other financial crimes there is tug of war amongst the coalition partners of the ruling party Pakistan Tehreek-i-Insaf (PTI) and all Opposition parties.

In the joint session, three FATF-related laws, namely, the Anti-Money Laundering (Second Amendment) Bill, 2020, Anti-Terrorism (Third Amendment) Bill 2020, were passed. It is worthwhile to mention that between Februarys to September 2020, the Parliament amended 10 Acts through 13 Bills aimed at enabling the country to come out of grey list. After passages of law, the Federal Law Minister made the claim that “after the joint session Pakistan has “completed all FATF-related legislation before the deadline”. He further added that “there are no more amendments required for now”. He admitted that Pakistan might have to pass new laws or further amend the existing ones if required in future.

The FATF placed Pakistan in grey list in June 2018 and had asked Pakistan to implement the action plan by end of 2019 but later extended the deadline because of the Covid-19 pandemic and delay on the part of the country to meet the requirements. The Anti-Terrorism (Third Amendment) Act inserted section 19C to the application of investigation techniques. It gives spying powers to the investigators and allows them to conduct undercover operations, intercept communication and access computer systems with the permission of court.

Through Anti-Money Laundering (Second Amendment) Act, 2020 and Anti-Money Laundering (Third Amendment) Act, 2020 Pakistan has tried to address remaining non-compliant FATF recommendations such as role of Designated Non-Financial Businesses and Professions (DNFBPs) transparency and beneficial ownership of legal arrangements, regulations and supervision of DNFBPs, mutual legal assistance, freezing and confiscation. The aim of this legislation is to address the concerns of FATF, however, structure introduced under this legislation has created complexities and raised doubts regarding transparency and its effectiveness.

With introduction of multiple committees, sub-committees consisting of politically exposed persons (PEP’s) to run the matters pertaining to financial crimes itself negate the very concept of transparency. This new arrangement lost its effectiveness when powers pertaining to regulating DNFBPs are assigned to their own elected bodies. This very idea on one hand creates conflicts of interest and on the other it is against the international best practices. For example, as per new law, lawyers’ regulatory bodies such as Pakistan Bar Council and other provincial bar councils will act AML/CFT regulatory authorities whereas their own laws bar disclosure of information of clients.

While making lawyers as DNFBPs, the Ministry of Finance and Federal Board of Revenue (see message in the beginning of the article), overlooked the fact that the attorney-client privilege or counsel-client relationship being fiduciary in nature cannot be allowed to be betrayed at any cost as held by the Lahore High Court in the following judgement in I.C.A. No.119 of 2014 by Lahore High Court on 22-04-2016 [2016 PTD 2043] as under:

Shujaat Ali Khan, J:- The appellant has assailed judgment dated 16.01.2014, passed by the learned Single Judge, whereby Writ Petition No.16001 of 2013, filed by the respondent, was allowed.

2.         The facts of the instant appeal are that during a drive against fraudulent tax adjustments availed by different registered persons, the staff of the Directorate of Intelligence and Investigation, Inland Revenue, Lahore unveiled that M/s Pearl Enterprises, Lahore (hereinafter to be referred as “the Registered Person”) was involved in illegal tax refund. As a result, a notice was issued to the Registered Person for showing cause as to why its registration may not be suspended. In response to the Show Cause Notice, the Registered Person submitted its reply through the respondent before the Commissioner, Inland Revenue, Lahore. On 01.06.2013, the Assistant Director, Directorate of Intelligence and Investigation, Inland Revenue, Lahore/Investigating Officer (hereinafter to be referred as the Investigating Officer) issued letter to the respondent with the averment to furnish duly executed power of attorney/authorization to represent the Registered Person before the Commissioner, Inland Revenue. The respondent replied to the said letter contending that as he was only engaged to represent the Registered Person before the Commissioner, Inland Revenue, therefore, he could not plead its case before the Investigating Officer. As a replication to the reply submitted by the respondent, the Investigating Officer addressed another letter, dated 07.06.2013, to the respondent with the request to share the particulars of the person (hereinafter to be referred as the Client) who engaged him to defend the Registered Person before the Commissioner, Inland Revenue, Lahore. As the respondent did not respond to communication, dated 07.06.2013, summons were issued to him in terms of Section 37 of the Sales Tax Act 1990 (“Act”) requiring him to appear before the Investigating Officer in connection with case FIR No.03/2013, dated 16.05.2013. The respondent assailed the vires of the summons before this court through aforementioned Constitutional Petition which came up for final hearing on 04.12.2013 when the same was accepted by the Learned Single Judge, hence this appeal.

3. Leaned counsel for the appellant submits that the learned Single Judge did not appreciate that proceedings against the Registered Person could not be finalized for the reason that exact antecedents of the owner of the Registered Person were not traceable and the appellant could only reach the Client through the courtesy of the respondent; that the Writ Petition filed by the respondent was accepted by the learned Single Judge mainly on the ground that the Registered Person was owned by one Munir Ahmad but during the course of investigation it surfaced to the scene that said Munir Ahmad belongs to District Bahawalnagar and is a Tailor by profession; that as the respondent filed reply to the Show Cause Notice, issued in the name of the Registered Person, before the Commissioner, Inland Revenue, Lahore he was well aware about the bio-data of the Client who engaged him as counsel; that the jurisdiction of the Investigating Officer to issue summons in the name of any person under Section 37(ii) of the Act for the purpose to furnish evidence or to produce documents, has not been considered by the learned Single Judge; that under Article 9 (2) of the Qanun-e-Shahadat Order, 1984 (“Order”) the respondent, being professional lawyer, is bound to disclose about the identity of the Client who hired his legal services to represent the Registered Person before the Commissioner, Inland Revenue, Lahore; that the learned Single Judge has not taken into consideration the fact that notice under Section 37 of the Act was issued to the respondent just requiring him to disclose identity of the Client who was acting on behalf of the Registered Person; that the learned Single Judge has mainly based her findings on Article 9 of the Order but no independent findings have been given qua the fate of summons issued in the name of the respondent under Section 37 of the Act; that the respondent, being responsible citizen, is bound to facilitate the investigation of the case being conducted in a scam of billions of rupees; that the learned Single Judge has accepted the writ petition mainly for the reason that the communication between the respondent and the Client being privileged one the respondent was not bound to disclose him before the Investigating Officer but as a matter of fact, the respondent was not being asked about any communication undertaken by him with his Client rather he was only being asked to unveil the identity of his Client; that the case-law relied upon by learned Single Judge, while accepting the writ petition, being quite distinguishable was not applicable in the facts and circumstances of the present case and that in case the respondent does not facilitate the department to unearth the Client/person, who played havoc with the National Exchequer, perhaps the department would not be able to hold investigation of the case in an efficient manner.

4. The learned Law Officer, who has entered appearance on Court’s call, submits that the respondent is not bound to disclose facts which may adversely affect his Client and if such a practice is allowed to continue the very foundation of the legal profession which hinges upon confidentiality and privileged communication inter-se the counsel and client will stand severely undermined; that if the department is conducting investigation of a criminal case it can utilize all the available resources but, in no manner, it can compel the respondent to disclose any fact which may prejudice the case of his Client; that according to Article 10A of the Constitution of the Islamic Republic of Pakistan, 1973 (the Constitution), fair trial is a vested right of every accused and in case the respondent is compelled to disclose the identity of his Client, the same would adversely affect his case and his right guaranteed under Article 10A would be infringed; that even in the United States of America, the communication and discussion inter-se the counsel and the client is privileged and no one can compel a counsel to disclose the same. To fortify his last noted contention, the learned Law Officer has referred the cases of Swindler & Berlin ET AL. v. United States, (524 U.S 399 (1998), Muhammad Maqsood Sabir Ansari v. District Returning Officer, Kasur and others (PLD 2009 SC 28) and Syed Ali Nawaz Gardezi v. Lt. Col. Muhammad Yusuf (PLD 1963 SC 51); that the lawyers are under bounden duty to maintain confidentiality relating to a matter in which he represents his client in view of the law laid down in Municipal Corporation of Greater Bombay and another, Petitioners v. Vijay Metal Works, Bombay, Respondent (AIR 1982 Bom 6); that according to Article 12 of the Order even a person, other than an advocate, who comes across any communication inter-se the counsel and client cannot be compelled to disclose the same before any authority; that according to the Pakistan Legal Practitioners and Bar Council Act, 1973 and the Rules made thereunder all the members of the Bar are under obligation to maintain high standard of professional integrity and dignity specially with reference to their duties towards the clients; that Canon 4 of the Model Code of Professional Responsibility (American Bar Association) governs the privilege which often is clarified by the committees of the Association in informal and formal opinions and in Formal Opinion 23, the Committee concerned on Ethics and Professional Responsibility, Formal Op.23 (1980) opined that information regarding whereabouts of a client also falls within the category of privileged communication; that a counsel cannot be compelled even to appear before any Authority, in any matter, relating to his client; that as per Section 126 of the Evidence Act, 1872, no barrister or pleader shall disclose any communication undertaken with his client.

5. Learned counsel appearing on behalf of the respondent instead of addressing the Court has toed the line of learned Law Officer.

6. We have heard learned counsel for the parties at considerable length and have also gone through the documents annexed with this appeal in addition to the case-law cited at the bar.

7. The crux of the arguments advanced by learned counsel for the appellant is that section 37 ibid empowers an investigating officer to summon any person in relation to investigation of a matter irrespective of the fact as to whether he has an active role in commission of the offence, under investigation, or not. In our view, to appreciate the said contention, section 37 of the Act, for convenience, is reproduced herein below:-

37. Power to summon persons to give evidence and produce documents in inquiries under the Act.-

(1) Any officer of Inland Revenue shall have powers to summon any person whose attendance he considers necessary either to tender evidence or to produce documents or any other thing in any inquiry which such officer is making for any of the purposes of this Act.

(2) Any person summoned under sub-section (1) shall be bound to attend either in person or by an authorised agent, as the officer of sales tax may direct; Provided that a person who is exempted from personal appearance in a court under section 132 and 133 of the Code of Civil Procedure (V of 1908), shall not be required to appear in person.

(3) Any inquiry before an officer of sales tax shall be deemed to be a judicial proceeding within the meaning of section 193 and 228 of the Pakistan Penal Code (Act XLV of 1860).”

The afore-quoted provision shows that an officer of Sales Tax/Inland Revenue conducting an investigation/inquiry into a matter is empowered to summon any person to give evidence or to produce documents or to perform any other act relating to the inquiry. In our view, as the respondent was not equipped with any material relating to the criminal case, under investigation before the Investigating Officer, he could neither be summoned to tender evidence nor could he be required to produce any document. Now the question which boils down for determination by this Court is as to whether an officer of the Sales Tax/Inland Revenue can summon an advocate while dealing with an investigation of a criminal case under the Act. In this regard, we are of the view that unless the advocate is personally involved in the commission of an offence cognizable under the Act, he enjoys immunity from appearance before the said officer. There is no denying the fact that counsel-client relationship being fiduciary in nature cannot be allowed to be betrayed at any cost. If the learned Members of the Bar are compelled to disclose about any fact, which otherwise form part of privileged communication, the entire legal system will collapse. Even otherwise, Article 12 of the Order provides a shield to a counsel against disclosure of confidential communication which takes place inter-se counsel and client during the course of the agency. The said principle enjoys universal acknowledgement. The Supreme Court of United Kingdom in the case of Prudential PLC and another v. Special Commissioner of Income Tax and another (2013 SCMR 403 (U.K)) while dealing with the importance of the privileged communication inter-se the counsel and client has inter-alia ruled as under:-

“39. There is no doubt that the argument for allowing this appeal is a strong one, at least in terms of principle, as anyone reading Lord Sumption’s judgment can appreciate. LAP is based on the need to ensure that a person can seek and obtain legal advice with candour and full disclosure, secure in the knowledge that the communications involved can never be used against that person. And LAP is conferred for the benefit of the client, and may only be waived by the client; it does not serve to protect the legal profession. In light of this, it is hard to see why, as a matter of pure logic, that privilege should be restricted to communications with legal advisers who happen to be qualified lawyers, as opposed to communications with other professional people with a qualification or experience which enables them to give expert legal advice in a particular field.”

Further, the Supreme Court of United States in Upjohn Co. v. United States (449 U.S. 383 (1981) while highlighting the importance of privileged communication between the counsel and client has inter-alia held as under: –

“The attorney-client privilege is the oldest of the privileges for confidential communications known to the common law. 8 J. Wigmore, Evidence 2290 (McNughton rev. 1961). Its purpose is to encourage full and frank communication between attorneys and their clients, and thereby promote broader public interests in the observance of law and administration of justice. The privilege recognizes that sound legal advice or advocacy serves public ends and that such advice or advocacy depends upon the lawyer’s being fully informed by the client……”

Moreover, the House of Lords in the consolidated appeals titled Regina v. Derby Magistrates Court ([1995] UKHL 18), while rendering their opinion, highlighted the importance of confidentiality attached to the counsel-client communication in the following words:-

“48. The case is thus clear early authority for the rule that the privilege is that of the client, which he alone can waive, and that the court will not permit, let alone order, the attorney to reveal the confidential communications which have passed between him and his former client. His mouth is shut forever.”

The above jurisprudence shows that counsel-client privilege enjoys a pivotal role in the legal system with the result that no authority is permitted to enquire from an advocate about any matter which he has come across during the course of his engagement with his client.

8. Learned counsel for the appellant has repeatedly argued that the respondent is being summoned just to disclose identity of person/Client who has camouflaged himself during investigation of a criminal case. As far as identity of person/Client representing the Registered Person is concerned, suffice it to note that as Show Cause Notice was issued to the Registered Person who was being represented by the respondent before the Commissioner Inland Revenue, Lahore is under legal and ethical duty not to disclose the same to anybody else including the Investigating Officer which may prejudice his case before any authority. If the department is so curious to unearth the identity of the person/Client representing the Registered Person it can order for personal appearance of the person/Client who has filed reply to the Show Cause Notice and in the event of his default, penal action can be initiated against such person but by no stretch of imagination the departmental authorities can compel the respondent to expose the personal bio-data of his Client. Furthermore, as per Formal Opinion 23, referred supra, even the question regarding whereabouts of a client forms part of privileged communication and counsel should not unveil the same before any authority.

9. It is of common knowledge that the affairs of the members of the legal fraternity are being governed under the Pakistan Legal Practitioners and Bar Councils Act 1973 as well as the Pakistan Legal Practitioners and Bar Councils Rules, 1976. The Chapter XII of the said Rules deals with the canons of Professional conduct and Etiquette of Advocates. Further, part B of the said Chapter provides guidelines for counsel-client relationship. According to rule 134 of the said Rules a member of a Bar is under bounden duty to maintain high standards of his profession in addition to his own dignity. In our view, if a counsel opts to share anything with somebody about which he came across during the period of his engagement by a particular party, perhaps on the one hand he would be lowering down the dignity of the profession and on the other would be guilty of misconduct. Overall reading of Chapter XII makes it clear that an Advocate is bound to maintain confidentiality about the facts which came into his knowledge as a result of engagement.

10. Learned counsel for the appellant has vehemently argued that as colossal loss has been caused by the Registered Person to the National Exchequer, the respondent, being responsible citizen, is bound to disclose the identity of the person/Client representing the Registered Person just to enable the Investigating Officer to conduct the investigation of criminal case in a transparent and fair manner. In this regard, we are of the view that the Investigating Officer can use all means available to him under the Act, but in no way, can ask the respondent to disclose identity of his Client. If such approach is permitted to be followed perhaps nobody would depend upon his counsel while sharing information/material in respect of a particular matter. Insofar as question regarding loss of billions of rupees to the National Exchequer is concerned, suffice it to observe that this court has no sympathy for the looters, swindlers and plunderers but at the same time cannot allow a public functionary to force a counsel to disclose the antecedents of his client which otherwise falls under privileged communication.

11. It is admitted that criminal case has been registered against the Registered Person relating to fraudulent tax adjustments prior to the engagement of the respondent as a counsel by the Registered Person. There is nothing on record to establish the involvement or connivance of the respondent in the alleged default of the Registered Person. The investigation of the Registered Person has no nexus with the professional duties of the respondent. The Investigating Officer cannot require the respondent to share with him information regarding identity of his client merely due to the fact that he represented the Registered Person in the proceedings pending before the Commissioner, Inland Revenue, Lahore.

12. For the above reasons we hold that the appellant has miserably failed to make out a case for interference in the impugned judgment. Consequently, judgment of the learned Single Judge, dated 16.01.2014, is upheld and the appeal in hand is dismissed with no order as to costs.

13. Before parting with this order, we acknowledge the valuable assistance rendered by the learned Law Officer, his associate and the Research Officer of the Lahore High Court Research Centre”.

In the light of above, it is clear that Ministry of Finance regulations under SRO 950(I)/2020, dated October 1, 2020 [AML/CFT Sanctions Rules, 2020] issued in exercise of the powers conferred by section 43 of the Anti-Money Laundering Act 2010 (Act VII of 2010) read with clause (h) of sub-section (2) of section 6A and clause (c) of section 6C of that Act and Federal Board of Revenue (FBR) vide SR0 924(1)/2020 [Federal Board of Revenue Anti Money Laundering and Countering Financing of Terrorism Regulations for DNFBPs, 2020] issued on September 29, 2020 in exercise of powers conferred under section 6A of the Anti-Money Laundering Act, 2010 (VII of 2010) read with clause 1(iii) of Schedule IV to the said Act are in conflict with various laws of the land as far as lawyers are concerned. This vital aspect is ignored when notifications are issued by the Ministry of Finance and FBR.

Moreover, the Schedule IV of the Anti-Money Laundering (Second Amendment) Act, 2020 (AML Act, 2020) gives the powers to FBR to act as an AML-CFT regulatory authority for various businesses such as  real estate agents, accountants, jewelers, dealers in precious metals and precious stones etc. By exercising powers conferred under section 6 read with clause 1(iii) of Schedule IV to the said Act, FBR issued regulations in respect of DNFBPs through S.R.O. 924(I)/2020, Islamabad, the 29th September 2020 to regulate DNFBPs. A detailed review of these regulations reveals that FBR officials has no ability to comprehend the depth and technicalities of different sectors as they have issued a set of generic regulations as a “fit for all” solution. These regulations must be carefully crafted, and its requirements should be laid down in accordance with business dynamics of each sector.

Let’s take example of jewelers and dealers in precious metals, stones and gems which are designated as DNFBPs under section 2(xii)(b) of the AML Act 2020. However, regulations issued under SRO 924(1)/2020 by the FBR failed to define precious metals, precious stones and gems. Though precious metals and precious stones are made part of the definition of jewelers under rule 2(k) of the said regulations. However, there is no classification available which defines precious metals and precious stones. Similarly there is no mention of treatment for dealers of gems in the regulations under questions.  Moreover, due diligence procedure mentioned in rule eight seems flawed, under the subject rule, jewelers and dealers in precious metal and stones are required to perform due diligence if the volume of cash transactions is equal to or above PKR 2 Million. This shows complete ignorance of our FBR officials towards this special industry and international practices. Jewelry, precious stones and precious metals are easily transportable and known as highly concentrated forms of wealth which is extremely attractive to money launderers and other crooks including financiers of terrorism. Therefore, keeping in view Pakistan’s situation, condition for performing of due diligence only for cash transactions above PKR 2million is against best practices and shows obliviousness of FBR officials regarding money laundering schemes.

It is apparent that the author of these regulations must be cognizant of the fact that jewelers, dealers in precious metals and stones are high risk businesses and vulnerable to money laundering and their state of affairs are different from other businesses made part of DNFBPs, their verification procedures, due diligence guidelines, enhanced due diligences and risk assessment parameters are different than other industries. However, stakeholders with responsibility of maintaining FATF program preferred to choose an easy way by issuing non-specific regulations and failed to address the specific risks exposed to each sector and imperceptibility of those risks can pollute our entire financial systems.

Additionally, requirements of reporting suspicious transactions mentioned in rule 14 read with section 7 of the AML Act are also sweeping and do not meet the needs of each industry. Therefore, way forward to improve our system is to re-draft the regulations for each sector highlighting the elements necessary to combat the threat of money laundering and terrorist financing. The industry specific regulations would address the potential risks of each industry. Like current regulations are silent about various matters related to jewelers, precious metals and stones and even no guidelines are available to address the issues when these professionals are dealing with third party, cases where dealers get payments of their products other than purchasers, cases where payments made through sequential cheques, cases where foreign jurisdictions are involved, payments where no identified payer is involved, method to determine the value of goods, the terms ‘retailers’ and ‘dealers’, situations where foreign jurisdictions are involved, treatment of trade-in transactions , remodeling of  gold with common items, rule to deal with fabrication of goods,  who will report suspicious transactions and who will maintain AML-CFT programs etc.

It is an ideal time to streamline our issues in line with global practices. We have paid a huge price in the past and we are not ready to let go these habits which are the reasons of our current embarrassment at global index. Despite lapse of more than three years we could not comply with all 27 action items of FATF. Even whatever we have complied so far is not according to international standards.

FATF consolidated assessment rating issued in December 2020 (cited above) confirms low level of our compliance. In this report our progress with reference to technical compliance and its effectiveness was rated poor. The effectiveness measures of our so far compliance was rated on a scale of high, substantial, medium, and low levels of effectiveness based on eleven immediate outcomes (IOs). Pakistan’s levels of effectiveness were rated low on ten and medium for one immediate outcome (IO2). Unfortunately, we have failed to secure a single substantial or high level of effectiveness rating. Now the question arises, even if we manage to comply with all 27 action items, but their effectiveness is rated low, shall we be able to get out of the grey list? And further, even if we do manage to elevate ourselves on “white list”, is there any surety that with this compliance level we will not be a part of “jurisdictions under increased monitoring” (grey list) again.

We must keep in mind that conventional approach will not get us the respect we deserve on the map of global index. We must go one step ahead to achieve it. Best way to comply with FATF mandates and fight with Financial Crimes is to establish an independent entity which consists of industry experts with vast experience in dealing with white-collars crimes and the said entity should issue regulations, guidance and directives for all sectors. However, FBR and other agencies will play the role of enforcement agencies, proceed with coordination, directions and powers delegated by the independent authority. This is the only solution to deal with financial crimes.


Ms. Huzaima Bukhari, Advocate High Court and Visiting Faculty at Lahore University of Management Sciences (LUMS), is author of numerous books and articles on Pakistani tax laws. She is editor of Taxation and partner of Huzaima & Ikram, a leading law firm of Pakistan. From 1984 to 2003, she was associated with Civil Services of Pakistan. Since 1989, she has been teaching tax laws at various institutions including government-run training institutes in Lahore. She specialises in the areas of international tax laws, corporate and commercial laws. She is review editor for many publications of Amsterdam-based International Bureau of Fiscal Documentation (IBFD) and contributes regularly to their journals. She has to her credit over 1500 articles on issues of public importance, printed in various journals, magazines and newspapers at home and abroad.

She has coauthored with Dr. Ikramul Haq many books that include  Tax Reforms in Pakistan: Historic & Critical Review, Towards Flat, Low-rate, Broad and Predictable Taxes (revised & Expanded Edition, Pakistan: Enigma of Taxation, Towards Flat, Low-rate, Broad and Predictable Taxes, Law & Practice of Income Tax, Law , Practice of Sales Tax, Law and Practice of Corporate Law, Law & Practice of Federal Excise, Law & Practice of Sales Tax on Services, Federal Tax Laws of Pakistan, Provincial Tax Laws, Practical Handbook of Income Tax, Tax Laws of Pakistan, Principles of Income Tax with Glossary andMaster Tax Guide, Income Tax Digest 1886-2011 (with judicial analysis).

The recent publication, coauthored with Abdul Rauf Shakoori and Dr. Ikramul Haq, is Pakistan Tackling FATF: Challenges & Solutions

available at:  https://www.amazon.com/dp/B08RXH8W46

She regularly writes columns for Pakistani newspapers and has contributed over 1500 articles on issues of public finance, taxation, economy and on various social issues in various journals, magazines and newspapers at home and abroad.


Dr. Ikramul Haq, Advocate Supreme Court, specialises in constitutional, corporate and tax laws. He established Huzaima & Ikram in 1996 and is presently its chief partner as well as partner in Huzaima Ikram & Ijaz. He studied journalism, English literature and law. He is Chief Editor of Taxation andVisiting Faculty at Lahore University of Management Sciences (LUMS).

He has coauthored with Huzaima Bukhari many books that include Tax Reforms in Pakistan: Historic & Critical Review, Towards Flat, Low-rate, Broad and Predictable Taxes (revised & Expanded Edition,  Pakistan: Enigma of Taxation, Towards Flat, Low-rate, Broad and Predictable Taxes, Law & Practice of Income Tax, Law , Practice of Sales Tax, Law and Practice of Corporate Law, Law & Practice of Federal Excise, Law & Practice of Sales Tax on Services, Federal Tax Laws of Pakistan, Provincial Tax Laws, Practical Handbook of Income Tax, Tax Laws of Pakistan, Principles of Income Tax with Glossary andMaster Tax Guide, Income Tax Digest 1886-2011 (with judicial analysis).

The recent publication, coauthored with Abdul Rauf Shakoori and Huzaima Bukhari is Pakistan Tackling FATF: Challenges & Solutions

available at:  https://www.amazon.com/dp/B08RXH8W46

He is author of Commentary on Avoidance of Double Taxation Agreements signed by Pakistan, Pakistan: From Hash to Heroin, its sequelPakistan: Drug-trap to Debt-trap and Practical Handbook of Income Tax. He regularly writes columns for many Pakistani newspapers and international journals and has contributed over 2500 articles on a variety of issues of public interest, printed in various journals, magazines and newspapers at home and abroad.


Abdul Rauf Shakoori, Advocate High Court, is a subject-matter expert on AML-CFT, Compliance, Cyber Crime and Risk Management. He has been providing AML-CFT advisory and training services to financial institutions (banks, DNFBPs, Investment companies, Money Service Businesses , insurance companies and securities), , government institutions including law enforcement agencies located in North America (USA & CANADA), Middle East and Pakistan. His areas of expertise include legal, strategic planning, cross border transactions including but not limited to joint ventures (JVs), mergers & acquisitions (M&A), takeovers, privatizations, overseas expansions, USA Patriot Act, Banking Secrecy Act, Office of Foreign Assets Control (OFAC). Over his career he has demonstrated excellent leadership, communication, analytical, and problem-solving skills and have also developed and delivered training courses in the areas of AML/CFT, Compliance, Fraud & Financial Crime Risk Management, Bank Secrecy, Cyber Crimes & Internet Threats against Banks, E – Channels Fraud Prevention, Security and Investigation of Financial Crimes. The courses have been delivered as practical workshops with case study driven scenarios and exams to insure knowledge transfer. His notable publications are; Rauf’s Compilation of Corporate Laws of Pakistan, Rauf’s Company Law and Practice of Pakistan, Rauf’s Research on Labour Laws and Income Tax Etc. His articles includes; Revenue collection: Contemporary targets vs. orthodox approach, It is time to say goodbye to our past, US double standards., Was Due Process Flouted While Convicting Nawaz Sharif?, FATF and unjustly grey listed Pakistan, Corruption is no excuse for Incompetence, Next step for Pakistan,, Pakistan’s compliance with FATF mandates, a work in progress, Pakistan’s strategy to address FATF Mandates was Inadequate, Pakistan’s Evolving FATF Compliance, Transparency Curtails Corruption, Pakistan’s Long Road towards FATF Compliance, Pakistan’s Archaic Approach to Addressing FATF Mandates.

The recent book, coauthored with Huzaima Bukhari & Dr. Ikramul Haq is Pakistan Tackling FATF: Challenges & Solutions

available at:  https://www.amazon.com/dp/B08RXH8W46

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