NIBAF Pakistan organised a one-day customised training program on Trade-Based Money Laundering (TBML) on November 22, 2025, bringing together banking professionals to strengthen their understanding of financial crime risks within trade operations. Held at the BAFL Learning Center in Karachi, the program was tailored specifically for officers from Bank Alfalah Limited, offering them targeted guidance on identifying red flags, understanding regulatory obligations, and improving internal controls to counter TBML practices. With cross-border trade becoming increasingly complex, the session responded to the sector’s need for enhanced vigilance and improved compliance frameworks.
The training was led by Mr. Saleem Sheikh, Joint Director of the Exchange Policy Department at the State Bank of Pakistan. Drawing from his extensive experience in foreign exchange operations and regulatory oversight, he provided a detailed exploration of how trade channels are misused for illicit financial movement. Mr. Sheikh explained that TBML remains one of the most sophisticated forms of money laundering, often concealed behind seemingly legitimate import and export activities. This makes it essential for banking professionals to understand the subtle indicators that point toward suspicious transactions.
Throughout the session, Mr. Sheikh highlighted the global methods used by illicit actors, including over-invoicing, under-invoicing, multiple invoicing, misrepresentation of goods, and the manipulation of shipping and documentation processes. He emphasised that financial institutions play a critical role in disrupting these activities by ensuring that staff involved in trade finance can analyse unusual transaction patterns, inconsistencies in trade documents, and discrepancies in valuation that may indicate criminal activity.
The program also focused on the regulatory landscape governing anti-money laundering and counter-terror financing in Pakistan. Participants were briefed on the expectations outlined by the State Bank of Pakistan and the Financial Action Task Force, as well as the internal compliance requirements banks must meet to avoid penalties and reputational damage. Mr. Sheikh stressed that trade finance units must enhance their due diligence processes, maintain effective communication between compliance and front-line staff, and ensure that monitoring systems are strong enough to flag suspicious behaviour in real time.
Around 35 participants from Bank Alfalah attended the training, engaging in case studies, group discussions, and interactive exercises designed to deepen their understanding of TBML schemes. These activities allowed them to analyse real-world examples and develop practical approaches for responding to suspicious transactions within their departments. The hands-on format encouraged participants to apply regulatory concepts to operational scenarios, making the learning experience directly relevant to their daily responsibilities.
NIBAF Pakistan reiterated that financial crime risks continue to evolve, particularly in areas like trade where high transaction volumes and cross-border payments create opportunities for misuse. The organisation underscored its commitment to supporting banks through specialised programs that address these challenges and equip professionals with the knowledge necessary to safeguard institutional integrity. By creating training opportunities tailored to individual banks, NIBAF aims to help institutions strengthen their compliance culture and align with global standards.
Participants noted that the program significantly improved their understanding of TBML risks and reinforced the importance of maintaining vigilance at every stage of trade processing. Many highlighted the value of learning directly from a senior SBP expert who provided clarity on regulatory expectations and practical guidance for improving internal procedures.
As financial institutions continue adapting to evolving regulatory frameworks and rising sophistication in illicit trade practices, initiatives like this remain essential. The one-day program marked a meaningful contribution toward building a more resilient and compliant banking environment in Pakistan, empowering officers to play a proactive role in detecting and mitigating financial crime risks.
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