Ten Departments by the End of October: the IMF Benchmark, the Anti-Corruption Establishments and the Notification the Anti-Money Laundering Act, 2010 Still Awaits

On Saturday, 31st October 2026, a structural benchmark falls due under Pakistan’s Extended Fund Facility with the International Monetary Fund. By that date the National Accountability Bureau is to have completed an action plan to mitigate corruption vulnerabilities in the ten departments of the Government identified as carrying the highest corruption risks. Four days before the date, on 27th October 2026, I can find no such plan on the website of the Bureau, of the Ministry of Law and Justice or of the Ministry of Finance, and I can find no published copy of the methodology on which the ten departments were to be chosen.

Behind that benchmark sits a second promise, given in the same paragraph of the same document, which matters more to the practice of anti-money laundering law in this country and has attracted almost no attention. By the end of December 2026 the Federal Government is to issue the notification that makes the Provincial Anti-Corruption Establishments investigating agencies under the Anti-Money Laundering Act, 2010 (Act VII of 2010). Until that notification issues, a provincial corruption case can reach the bribe but not the money.

What Pakistan wrote down

The commitments are in the Memorandum of Economic and Financial Policies attached to the Letter of Intent of 23rd April 2026, published as IMF Country Report No. 26/101 with the staff report for the third review, which the Executive Board completed on 8th May 2026. Paragraph 38(c) records that the National Accountability Bureau, tasked by the Anti-Corruption and AML/CFT Committee constituted by the Prime Minister and chaired by the Minister for Law and Justice, “has been designated to lead the development of an action plan to mitigate corruption vulnerabilities in the top ten departments of the Government identified with highest corruption risks”, marked as a proposed revised end-October 2026 structural benchmark. The same paragraph commits the Committee, “in consultation and agreement with IMF staff, by end-June 2026”, to “develop and publish a methodology for assessing and prioritizing agency level corruption risks”.

The benchmark was first set in the second review of December 2025, as Business Recorder reported on 23rd December 2025, and revised in the third. Item 17 of the benchmark table opens with the word “Publish”, and its status on 23rd April 2026 was “In progress”.

Paragraph 38(d) is the second commitment. It reads: “In line with the AML Act and the National Fiscal Pact, the relevant federal notification process initiated by the Financial Monitoring Unit (FMU) will be issued by end-December 2026, designating the PACEs to investigate money laundering related to corruption offenses within their jurisdiction, and to request and receive financial intelligence from the FMU as an investigating agency.” That is not a structural benchmark but a dated commitment, a softer obligation and an easier one to let slip.

Where corruption cases now sit

The Fund’s own Governance and Corruption Diagnostic Assessment of November 2025 explains why the provinces matter. Paragraph 11 of that report names the three primary anti-corruption agencies as the Bureau, the Federal Investigation Agency and the provincial Anti-Corruption Establishments, and records that they “are viewed as having poor coordination”. Paragraph 374 records that when the Bureau’s monetary threshold was raised to Rs. 500 million, “hundreds of cases” below it went to the Federal Investigation Agency and the provincial establishments, some of which had to start their investigations from scratch.

Paragraph 372 then identifies the defect this article is about. The provincial establishments, it says, are hindered by “their lack of access to databases, including on the national identification system, tax information, asset declarations and bank accounts”, and the authorities are “moving ahead with initiatives to designate PACEs as anti-money laundering authorities to allow them to request and access financial intelligence from the Financial Monitoring Unit”. Its footnote 243 traces the commitment to the National Fiscal Pacts of the four provinces.

Hence the work has moved down to the provinces while the financial intelligence has stayed in Karachi.

What the Act actually says

The gate is a single definition. Section 2(xviii) of the Anti-Money Laundering Act, 2010, as substituted by the amendments of September 2020 and unchanged in the Pakistan Code consolidation of 2nd September 2022, provides that “investigating or prosecuting agency” means “the National Accountability Bureau (NAB), Federal Investigation Agency (FIA), Anti-Narcotics Force (ANF), Directorate General of (Intelligence and Investigation – Customs) Federal Board of Revenue, Directorate General (Intelligence and Investigation Inland Revenue) Federal Board of Revenue, Provincial Counter Terrorism Departments or any other law enforcement agency as may be notified by the Federal Government for the investigation or prosecution of an offence under this Act”.

Everything turns on being inside that list. Section 6(4)(c) lets the Financial Monitoring Unit disseminate its analysis of suspicious and currency transaction reports “to the concerned investigating or prosecuting agencies”. Section 24(1) lets an “investigating or prosecuting agency” nominate its own officers as investigating officers. Section 25 obliges federal, provincial and local officers and every reporting entity to produce the records reasonably required “by the investigating or prosecuting agency or FMU”, on pain of a misconduct proceeding. A provincial establishment outside the definition has none of these.

The odd part is that the substance is already provincial. Schedule-I lists as predicate offences Sections 161 to 165A of the Pakistan Penal Code, 1860, Sections 5, 5B and 5C of the Prevention of Corruption Act, 1947 (Act II of 1947), and Section 9 of the National Accountability Ordinance, 1999 (XVIII of 1999). The first two are the offences a provincial establishment registers every day. Section 20(1), proviso (a), then sends the money laundering charge to “the Court trying the predicate offence” where that court is not the Court of Session, which for a provincial corruption case is the Special Judge Anti-Corruption. The predicate is provincial, the court is provincial and the evidence is provincial; only the agency entitled to investigate the laundering is missing.

Nor would a provincial name in the list be new. “Provincial Counter Terrorism Departments” were written into Section 2(xviii) in 2020, and the reasoning that let a provincial police department receive financial intelligence on terrorist financing applies equally to the proceeds of a bribe.

Three points on the notification

First, the power belongs to the Federal Government, not to the Unit. Paragraph 38(d) speaks of a notification process “initiated by the Financial Monitoring Unit”, and that is a fair description of who will draft it, but Section 2(xviii) gives the power to notify to “the Federal Government” alone. The instrument should therefore issue in the Gazette in the name of the Federal Government and it should recite Section 2(xviii) as its source. A memorandum of understanding under Section 6(4)(i) is useful for the working arrangements but makes nobody an “investigating or prosecuting agency”.

Second, the scope must be drafted with care. The Fund’s text speaks of money laundering “related to corruption offenses within their jurisdiction”. Section 2(xviii) allows notification “for the investigation or prosecution of an offence under this Act”, and a notification confined by predicate and by territory is within that language. But it should name each establishment by the provincial statute or rules under which it exists, it should say whether it covers prosecution as well as investigation, and it should state plainly that the establishment may receive disseminations under Section 6(4)(c). An ambiguous notification invites a bail application arguing that the investigating officer had no power, an argument made in every money laundering file.

Third, Section 24(2) is not a substitute. It already lets the Federal Government empower a provincial officer not below BPS-18 to act as an investigating officer, but Section 6(4)(c) disseminates to agencies, not to officers, hence an officer empowered alone cannot bring the Unit’s analysis into his case.

An action plan nobody can read

The ten-department plan has the opposite problem. The Diagnostic’s recommendation 11 called for “publishing an action plan” for the top ten agencies “based on a centralized assessment using pre-established and public criteria”. Paragraph 38(c) required the methodology itself to be published by the end of June 2026 and listed what it must weigh: the money at risk, the typologies of corruption in the agency, its structural weaknesses and the frequency of past and current cases.

That was four months ago. When Business Recorder asked in December 2025 which ten departments were meant, it reported no response from the Ministry of Finance, the Ministry of Law and Justice or the Fund’s office in Islamabad. A plan whose criteria nobody has seen and whose ten departments nobody has named cannot be tested by Parliament, by the Auditor-General or by the press; it can only be reported to the Fund as done.

What should happen before the year ends

It is highly recommended that the Anti-Corruption and AML/CFT Committee publish the methodology now, on the website of the Ministry of Law and Justice, since the plan of 31st October 2026 is worth no more than the criteria behind it. The plan itself should be published on the day it is completed, with the ten departments named; a department that knows it is on the list is a department that can be asked in the Public Accounts Committee what it has done.

On the notification, it is urgently required that the Federal Government issue it under Section 2(xviii) before 31st December 2026, naming each Provincial Anti-Corruption Establishment, covering both investigation and prosecution of offences under Sections 3 and 4 where the predicate is a Schedule-I corruption offence within the province, and stating the right to receive disseminations under Section 6(4)(c). The Unit should use Section 6(4)(g) from the first year to ask each establishment what it did with what it received, and publish the numbers, since a designation that produces no money laundering case in a provincial court will be one more notification in field and nothing more.

The ten departments are a federal exercise. The notification is the provincial one, and of the two it is the one that can put a corrupt officer’s money before a judge.