ZEEQUEE EXCHANG COMPANY (PVT.) LTD. (ZQEC) is committed to the highest standards of Anti-Money Laundering (AML), Counter Terrorism Financing (CTF), Anti-Fraud and other punishable criminal acts including Anti-Bribery and Corruption (ABC).The members of the Board and Compliance team are highly committed to protect ZQEC and its reputation from being misused for money laundering and/or terrorist financing or other illegal purposes.
Compliance Mission Statement
To establish and implement risk-based policies, procedures, and processes to adequately comply with the laws of Pakistan in which ZQEC operates and to safeguard ZQEC’s operations from being used as a vehicle for money laundering, terrorist financing and consumer fraud. ZQEC’s Compliance Department strives to be considered a best-in-class in the prevention of money laundering, terrorist financing and consumer fraud as well as an industry example in compliance with consumer protection laws.
The State Bank of Pakistan (SBP) has in the past issued detailed AML/CFT regulations, as well as guidelines on a risk-based approach in 2012. The SBP is the regulator for AML controls for banking and financial services while the Securities and Exchange Commission (SECP) is the regulator for all other entities. Other regulatory authorities include the National Accountability Bureau (NAB), the Anti-Narcotics Force (ANF), the Federal Investigation Agency (FIA), and the Customs Authorities oversee Pakistan’s AML law enforcement efforts.
The major laws in these areas include:
The Anti-Terrorism Act of 2002, which defines the crimes of terrorist finance and money laundering and establishes jurisdictions and punishments (amended in October 2004 to increase maximum punishments).
The National Accountability Ordinance of 1999, which requires financial institutions to report suspicious transactions to the NAB and establishes accountability courts.
The Control of Narcotic Substances Act of 1997, which also requires the reporting of suspicious transactions to the ANF, contains provisions for the freezing and seizing of assets associated with narcotics trafficking, and establishes special courts for offenses (including financing) involving illegal narcotics.
All these laws include provisions to allow investigators to access financial records and conduct financial investigations.
In 2007, Pakistan enacted the AML Ordinance, establishing regulations for AML and combating the financing of terrorism and criminalizing money laundering. Under the Ordinance, the Financial Monitoring Unit (FMU) was created. The FMU serves as Pakistan’s FIU and is in charge of handling Suspicious Transaction Reports (STRs). In 2010, the SBP passed the Anti-Money Laundering Act, replacing the 2007 AML Ordinance.
The FMU works with several Pakistani law enforcement agencies that are responsible for enforcing financial crime laws, including the National Accountability Bureau (NAB), the Anti-Narcotics Force (ANF), the Directorate of Customs Intelligence and Investigations (CII), and the Federal Investigative Agency (FIA).
The FIA deals with crimes relating to money laundering, terrorism, human smuggling and trafficking, and cybercrime, among others.
The State Bank of Pakistan (SBP) and the Securities and Exchange Commission of Pakistan (SECP) are the primary financial regulators. Notwithstanding the absence of standalone AML legislation, the SBP and SECP have independently established AML units to enhance their oversight of the financial sector. The SBP has introduced regulations intended to be consistent with the Financial Action Task Force’s (FATF) recommendations in the areas of a Know Your Customer (KYC) policy, record retention, due diligence of correspondent banks, and the reporting of suspicious transactions.
ANTI FRAUD POLICY
ZQEC adopts zero tolerance to all kinds and forms of fraud and corruption to or from customers.
FRAUD AGAINST THE CONSUMER
ZQEC is highly committed to prevent all of its consumers to become a victim of fraud.
The cellphone, electronic mail and postal mail helplines dedicated to direct communication are the same as that maintained under the Company’s Code of Conduct. All Company personnel and consumers will be made aware of the existence and availability of the helplines. All Company personnel are encouraged to report any potential violation of the Policy or the Compliance Program via one of the helplines. Reports may be made anonymously if so desired. The Company’s Non-Retaliation Policy covers anyone submitting information about a potential violation of the Policy, the Compliance Program, laws, regulations, or the Code of Conduct.
There will be no reprisal for the submission of any information or report that is submitted in good faith and same may apply on consumers where applicable.
Cellphone: + 92-3354-933-783 [033-54-(ZeeQue)]
Postal: Compliance Officer (LG 3-13 Al Hafeez Shopping Mall, Gulberg III, Lahore, Pakistan)