The Solar Panel Import Scandal in Pakistan: Trade-Based Money Laundering, Policy Gaps, and Enforcement Challenges

Executive Summary
This report examines one of Pakistan’s largest recorded trade-based money laundering (TBML) cases — the 2023–2025 solar panel import scandal — which exposed systemic weaknesses in customs valuation, anti-money laundering controls, and renewable energy policy safeguards. The Federal Board of Revenue’s (FBR) Post-Clearance Audit uncovered over Rs111 billion in penalties against 13 importers, with evidence of over-invoicing up to five times the market value, dummy companies, illicit offshore remittances routed through the UAE and Singapore, and fabricated domestic sales tax records.
Key players included shell entities such as Bright Star Business Solution, Moonlight Traders, and Solar Site Pvt Ltd, collectively implicated in siphoning billions of rupees abroad. The investigation revealed non-existent offices, forged documentation, inflated invoices, and large cash deposits exceeding Rs45 billion. The scandal’s fallout has not only undermined public trust in the renewable energy sector but also raised critical questions about Pakistan’s capacity to safeguard clean energy transitions from financial crime exploitation.
The document also outlines a capacity-building framework for investigative and enforcement agencies, covering TBML typologies, customs valuation protocols, beneficial ownership tracing, cross-border evidence gathering, and prosecution strategies. Drawing comparative insights from the United States, United Kingdom, Singapore, and the UAE, it offers a policy roadmap for strengthening enforcement without stifling renewable sector growth.

 
Preface
The rapid adoption of renewable energy technologies in Pakistan was expected to bring economic relief, reduce dependency on fossil fuels, and support climate commitments. However, the solar panel import scandal has revealed a darker reality — the exploitation of green technology supply chains as a conduit for large-scale financial crime. This report provides an evidence-based account of how loopholes in customs valuation, beneficial ownership verification, and trade-finance oversight were manipulated to launder billions of rupees under the guise of sustainable energy imports.
Beyond detailing the mechanics of the fraud, the study aims to equip policymakers, investigators, and compliance professionals with actionable strategies to detect, deter, and prosecute such crimes. While the enforcement challenge is significant, the stakes are higher still — ensuring that Pakistan’s renewable energy transition is not undermined by criminal networks and policy inertia. The proposed reforms balance the imperatives of clean energy adoption with the demands of financial integrity, offering both a cautionary tale and a strategic blueprint for future resilience.

 
About the Author
Mian Zafar Iqbal Kalanauri is an Advocate of the Supreme Court of Pakistan, Chartered Arbitrator, Mediator, and a Fellow of the Chartered Institute of Arbitrators (FCIArb). With decades of experience in dispute resolution, legal reform, and professional training, he has advised on high-profile commercial and financial crime matters across jurisdictions. Mr. Kalanauri is also an accomplished legal author and educator, having developed training curricula for judicial officers, lawyers, and compliance professionals in Pakistan and abroad. His expertise bridges law, policy, and capacity-building, with a particular focus on anti-money laundering, trade-based financial crime, and alternative dispute resolution in emerging markets.
 

 
Index of Contents
Introduction
1.1 Background to the Solar Panel Import Scandal
1.2 Scope and Methodology of the Report
Case Overview
2.1 Scale of the Fraud and Financial Losses
2.2 Key Actors and Corporate Entities Involved
2.3 Modus Operandi: Over-Invoicing and Dummy Companies
Financial Crime Typologies in the Case
3.1 Trade-Based Money Laundering Patterns
3.2 Offshore Routing and Beneficial Ownership Concealment
3.3 Fabricated Sales Tax Returns and Domestic Sales Fraud
Enforcement Actions and Institutional Response
4.1 Customs Adjudication and Penalties
4.2 Investigations by FBR, FIA, and Senate Committees
4.3 Challenges in Prosecution and Asset Recovery
Policy and Legal Gaps
5.1 Weaknesses in Customs Valuation Framework
5.2 Beneficial Ownership Registry Limitations
5.3 AML/CFT Compliance Failures in Banking Channels
5.4 Renewable Energy Policy Vulnerabilities
Comparative Jurisdictional Insights
6.1 United States: Black Market Peso Exchange Model
6.2 United Kingdom: Civil Recovery and Corporate Liability
6.3 Singapore: Trade-Finance AML Controls
6.4 United Arab Emirates: TBML Risk Assessments
Capacity-Building Framework for Pakistan
7.1 TBML Detection and Case Building
7.2 Customs Valuation and Reference Pricing Protocols
7.3 Trade-Finance AML for Banks and SBP Supervision
7.4 Beneficial Ownership Verification and Corporate Integrity
7.5 Cross-Border Evidence Gathering and MLA Procedures
7.6 Prosecution Strategies for TBML Cases
Sector-Safe Policy Recommendations
8.1 Duty-Free Continuity with Risk Controls
8.2 Importer Licensing and Fit-and-Proper Criteria
8.3 Volume Caps and Installation Verification
Training Program Prospectus
9.1 Modules and Learning Outcomes
9.2 Simulation Exercises and Toolkits
9.3 Target Audience and Delivery Method
Conclusion
10.1 Summary of Findings
10.2 Strategic Imperatives for Clean Energy Integrity
Bibliography and References
1. Introduction
The solar panel import sector in Pakistan has recently become the focal point of one of the largest trade-based money laundering (TBML) investigations in the country’s history. Allegations of systematic over-invoicing, illicit offshore remittances, and the use of shell corporations for financial crime have culminated in unprecedented enforcement actions. The Directorate of Customs Post-Clearance Audit (PCA) has imposed cumulative penalties of Rs111 billion on thirteen companies implicated in fraudulent solar panel import transactions.
According to Shiraz Ahmed, Director of PCA Karachi, these penalties — adjudicated by Deputy Collector Dr. Iram Zahra — followed conclusive findings that the companies declared fictitious imports valued at Rs1.2 trillion for the purpose of unlawfully transferring funds abroad. Financial records further revealed that the entities collectively received Rs1.4 trillion in domestic bank accounts, including Rs45 billion in large cash deposits.
The investigation established that these corporate entities were purely paper constructs with no operational presence. Their sales tax returns reported fabricated local transactions amounting to Rs85 billion, listing fictitious buyers to create an appearance of legitimate business activity. The Federal Board of Revenue (FBR) has identified approximately eighty companies suspected of participation in the scheme, which collectively facilitated the siphoning of billions of rupees from Pakistan’s economy.
The scandal’s magnitude has compelled intensified scrutiny from multiple investigative and regulatory authorities, with mounting public and political pressure to ensure accountability, close policy loopholes, and deter recurrence. Entities fined include Smart Impex, Ehsan Importer & Exporter, Asadullah Enterprises, SH Traders, Delta Trading Company, Sehar International, Sky Linker Business Chain, and Pak Electronics.
The refusal of the accused to contest the charges has resulted in an additional Rs45 million in penalties against forty-five individuals. Customs authorities have seized 327 containers linked to Solar Site Pvt Ltd, scheduled for auction to recover an estimated Rs1.5 billion in public revenue.
The FBR’s detailed investigative report underscores the role of two primary companies in funnelling approximately Rs72.83 billion out of Pakistan. The imports, sourced from China, were invoiced at significantly inflated prices, with payment trails leading to accounts in Singapore and the United Arab Emirates. A total of 63 consignments were found to be over-invoiced, and First Information Reports (FIRs) have been registered against both companies, which reportedly sold goods worth Rs72.83 billion for Rs45.61 billion domestically.
A field investigation revealed that the registered office addresses for these companies — purportedly located in the same Peshawar building — were entirely fictitious. Income tax filings further confirmed the fabricated nature of these entities, which managed to illicitly expatriate Rs20.4 billion under false pretences.
Concurrently, a large-scale solar panel fraud was uncovered in Ahmedpur Sial tehsil of Jhang District, where unsuspecting citizens and traders, lured by promises of relief from high electricity tariffs, invested in advance payments for solar equipment that was never delivered. Estimated losses in Ahmedpur Sial alone range from Rs2 to Rs2.5 billion, with provincial estimates suggesting total losses of Rs14–15 billion. The alleged mastermind absconded, leaving local business owners in severe financial distress and jeopardising the commercial viability of solar energy enterprises in the area.
Affected stakeholders have formally petitioned the Government to constitute a high-level investigative committee, expedite the apprehension of perpetrators, recover misappropriated funds, and prosecute those responsible. The scandal thus presents not only an economic crime of unprecedented scale but also a significant test of Pakistan’s institutional capacity to protect both its financial system and the integrity of its renewable energy sector.
 
Here’s a breakdown of the key aspects of the scandal:
 
Over-invoicing and Money Laundering:
Massive Scale:
The FBR estimates that over Rs. 106 billion were transferred abroad for solar panel imports, with Rs. 69 billion attributed to over-invoicing. 
Dummy Companies:
Many of the implicated companies are believed to be dummy entities, created to facilitate the illicit financial transactions. 
Illicit Financial Flows:
Funds were allegedly routed through various countries, including the UAE and Singapore, before being deposited in commercial banks in Pakistan. 
Inflated Prices:
Solar panels were imported at prices significantly higher than their actual market value in China, with some panels imported at double or even five times their original cost, according to the FBR. 
 
Key Players and Companies:
Rab Nawaz and Ahmed Nawaz:
These individuals, along with their company Bright Star Company, are major suspects in the case, having allegedly laundered billions of rupees. 
3.2 Moonlight Traders:
This company is also under investigation for over-invoicing and money laundering. -Rs21 billion
Bright Star Business Solution, Peshawar – Rs53 billion
Sky Linkers Trading Company – Rs8.6 billion
Royal Zone – Rs16 billion
Solar Site Pvt Ltd – Rs7.7 billion (327 containers seized at Karachi Port)
3.6 Other companies:
A total of 80 companies are under scrutiny, with many flagged for suspicious transactions and over-invoicing. 
Official Response and Investigations:
FBR Investigations:
The FBR has registered FIRs (First Information Reports) against implicated companies and is pursuing further investigations. 
Senate Committee:
The Senate Finance Subcommittee has been actively involved in probing the scandal, demanding transparency and accountability from banks and other stakeholders. 
Audit of Solar Imports:
A comprehensive audit of all solar panel imports since 2018 has been ordered to uncover the full extent of the fraud. 
Proposed Tax:
There was a proposal to impose an 18% GST on imported solar panels, but it was later rejected by the National Assembly and Senate panels, although a 10% sales tax was later introduced. 
Impact and Concerns:
5.1 Erosion of Public Trust:
The scandal has eroded public trust in the energy sector and government institutions. 
Financial Losses:
The illicit financial flows and over-invoicing have resulted in significant financial losses for the country. 
Energy Policy Concerns:
The scandal has raised serious questions about the government’s energy policies and the implementation of renewable energy initiatives, according to Courting The Law. 
 
Executive update (as of 13 Aug 2025)
Customs Adjudication has imposed Rs111 billion in penalties on 13 importers after Post-Clearance Audit confirmed fake/over-invoiced solar-panel imports used for trade-based money laundering (TBML); appeals to the Customs Appellate Tribunal/High Courts are expected.
Earlier probes (2023–2025) had already flagged Rs69.5–106 billion in over-invoicing, shell companies in Lahore/Peshawar, unusual cash deposits, and bank AML gaps raised in Parliament/Senate.
Patterns remain consistent with your first file: dummy entities, over-invoicing up to 2–5×, off-shore routing via UAE/Singapore, bogus sales tax returns, and seizure/auction of consignments (e.g., 327 containers).
 
Key concerns for investigation & successful prosecutions
Tight ML case-linkage: Anchor AMLA charges to clear predicate offences (fake invoicing, tax fraud) so cases don’t collapse into mere tax settlements.
Evidence completeness & integrity: Reconcile Customs declarations, BLs, Form-I/TTs/LCs, bank records, GST returns, and sales ledgers; preserve digital trails (emails/WhatsApp).
Beneficial ownership opacity: Piercing shell networks and identifying ultimate beneficial owners (UBOs) to support restraint/confiscation orders.
Banking compliance failures: Retrospective KYC/EDD and STR/CTR look-backs for large, round-number remittances and Rs 45 billion+ cash deposits cited in probes.
Cross-border cooperation: Fast MLA/ROG to UAE/Singapore before funds dissipate.
Valuation weaknesses: Lack of robust reference pricing and exporter-side confirmation enables inflated invoices at clearance.
Appeal drag: Adjudication wins can stall on appeal; need specialised benches/fast-track to avoid deterrence erosion.
Policy volatility: Oscillating tax proposals around solar imports invite arbitrage and complicate enforcement narratives.
Loopholes in law & policy (as surfaced by both records)
Customs valuation: No compulsory benchmark price bands/valuation rulings for PV modules; limited pre-shipment verification and exporter attestation.
TBML analytics gap: PSW/WeBOC not uniformly flagging outliers (unit $/W anomalies, split-country payments, first-time high-volume importers).
Beneficial ownership & corporate registry: Weak BO verification and modest penalties for false declarations; ease of registering paper companies.
Sales tax chain controls: Insufficient e-invoicing and invoice-matching allows fictitious domestic sales and input-tax abuse.
Judicial throughput: No dedicated AML/TBML appellate track to sustain penalties/convictions quickly.
 
Roles & concrete actions (FIA, FBR–Customs & Inland Revenue, SBP, plus coordination)
FIA (AML/CFT lead; cross-border & asset recovery)
Register AMLA 2010 cases in parallel with Customs Act counts; obtain freezing/attachment orders and pursue MLA to UAE/Singapore; form JITs with Customs/FBR-IR/SBP/SECP/prosecutors.
 
FBR – Customs (valuation, seizures, adjudication)
Issue valuation rulings/benchmark price bands for HS codes covering PV modules; require pre-shipment accredited inspections and upload of third-party price evidence into WeBOC/PSW; expand post-clearance audits for HS 8541.43 and adjacent codes.
Maintain hold/blacklists for importers lacking premises or with exporter-jurisdiction/payment mismatches; fast-track adjudication and forfeiture/auction where appropriate.
FBR – Inland Revenue (GST/income tax)
Enforce mandatory e-invoicing and real-time invoice matching; block input-tax credits/refunds until verification; conduct joint audits of flagged groups and related parties.
State Bank of Pakistan (supervision & FX controls)
Conduct targeted AML/CFT on-site exams of banks named in PCA/adjudication orders; mandate remediation/penalties for KYC/EDD lapses; order a 2018-to-date look-back on solar-import payments and linked cash deposits.
Require documentary congruence: exporter’s country, invoice, BL, beneficiary, and remittance must match; ban split-country settlements without SBP NOC; prefer LCs/BPOs over open account for high-risk items.
Cross-agency fusion & transparency
Stand-up a Customs–SBP–FBR Fusion Cell to cross-match import values with global price data and domestic installation plausibility (MW installed vs. modules imported); integrate red-flag models into PSW/WeBOC (round-figure invoices, third-country payments, first-time surges).
Public disclosure & debarment: Publish penalised entities; consider procurement debarment until cleared—mirroring global practice.
Prevention playbook (with timelines & KPIs )
Immediate (0–90 days)
Freeze & preserve assets/consignments; launch bank look-backs; file AMLA charges alongside customs/tax counts; set up the Fusion Cell and start cross-matching.
KPIs: Fusion Cell operational; # of accounts frozen; # of STRs/EDDs completed.
Medium term (3–12 months)
Roll out valuation/price-verification protocols (pre-shipment verification + third-party price evidence uploads); integrate red-flag alerts in PSW/WeBOC; commence importer licensing (fit-and-proper) and random site audits to confirm stock/use; initiate peer-country data-sharing (e-CO/e-Invoice) with China/UAE.
KPIs: % of high-risk imports with verified pricing; # of alerts and response rate; MoUs signed; % of imports traced by serial number + buyer NTN/CNIC.
Structural (12+ months)
Legislative upgrades: Amend Customs Act to codify reference pricing/exporter verification and elevate penalties for invoice fraud linked to ML; reinforce AMLA to enumerate trade-document fraud and enable civil forfeiture; strengthen SECP powers to strike-off for false BO and disqualify shadow directors.
Judicial fast-track: Designate customs/TBML benches and appellate timelines; issue prosecutorial guidance on trade-data evidence and standard MLA templates for proceeds tracing.
9.8 Sector safeguards that don’t hurt renewables
Keep panels duty-free, but ring-fence with: importer licensing; volume caps tied to verified sales/installs; traceability via serial-number/buyer e-reporting; random post-clearance site audits to prove goods exist
9.9 Practical checklists for current cases
Document congruence test (invoice/packing list/BL/insurance/inspection/Form-I/SWIFT/TT/WeBOC entry); compute $/W and variance vs. benchmark.
Cash-flow reconstruction (CIF → bank payments → third-country transfers → repatriation/mixing); connect to fake domestic sales and cash deposits.
Network analysis of shared signatories, phones, accountants, clearing agents, exporters across the ~80 companies; flag non-existent premises.

• Bottom line

Both records point to one of Pakistan’s largest TBML crackdowns to date: adjudication penalties are in, but durable accountability hinges on AMLA-first prosecutions, rapid asset restraint (home & abroad), hardened valuation/payment controls, bank supervision, BO enforcement, and expedited judicial tracks—all while preserving the momentum of clean energy adoption.

• Compact, actionable training blueprint for Pakistani investigative agencies: (FIA, FBR–  Customs & Inland Revenue, SBP, SECP) and private investigation forums (CFEs, forensic accountants, trade-finance investigators).

12.1 Why training is urgent (Pakistan context)

The record shows TBML via over-invoiced or ghost solar imports, dummy firms, split-country payments, unusual cash deposits, and large administrative penalties—now moving toward appeals and (ideally) AML prosecutions.

Bank look-backs, price-verification protocols, Fusion-Cell analytics, importer licensing, and fast-track AML/TBML litigation—all of which need specialized skills.

13. A. Core training curriculum (for FIA, FBR–Customs/IR, SBP, SECP;  also private investigators)

1. Module A1 — TBML Typologies & Case Building

FATF/Egmont TBML red flags; invoice/BL/insurance/packing-list congruence; mapping unit $/W outliers.

Pakistani patterns: over-invoicing, dummy companies, third-country payments, fake domestic sales, and cash deposits—turn these into predicate offences + AMLA counts.
Outcomes: trainees can draft ML charge sheets that survive beyond tax adjudication.

1. Module A2 — Customs Valuation & Reference Pricing

Building benchmark price bands for PV modules; use of pre-shipment third-party verification; attaching proof in WeBOC/PSW.
Outcomes: confident use of valuation rulings; fewer inflated invoices at clearance.

1. Module A3 — Trade Finance AML

Controls over LCs/BPOs vs. open account, document checking, and split-jurisdiction payments; STR/CTR essentials for banks.

MAS (Singapore) supervisory guidance on trade-finance AML and correspondent banking; practical checklists.
Outcomes: SBP examiners and bank AML teams detect TBML earlier.

1. Module A4 — Data & Analytics for TBML

Build/operate a Customs–SBP–FBR Fusion Cell; risk-scoring importers; PSW/WeBOC red-flag logic (round-number invoices, third-country payments, first-time surges).
Outcomes: analysts generate leads from data, not luck.

1. Module A5 — Beneficial Ownership & Corporate Abuse

Verifying UBOs, striking off non-existent premises, and linking related parties across importers, brokers, and banks (Pakistan pattern).
Outcomes: cases climb the chain to real controllers.

1. Module A6 — Cross-Border Evidence & MLA

Drafting mutual legal assistance (UAE/Singapore/China) for bank records and exporter attestations; asset restraint abroad. (Your brief urges standard templates and specialized benches.)
Outcomes: faster foreign evidence and recoveries.

1. Module A7 — Prosecution Strategy & Expert Testimony

Converting post-clearance audit findings into AMLA 2010 + Customs Act trials; expert testimony on price indices and trade documents; appellate survival.

1. Module A8 — Sector-Safe Design

Keep renewables duty-free yet ring-fenced: importer licensing, volume caps, serial-number traceability, site audits.

14.  B. Role-specific training tracks

14.1 FIA (lead on AML/MLA/asset recovery)

• Financial profiling & network analysis; device seizures and trade-document forensics; MLA drafting exercises to UAE/Singapore.
  FBR–Customs
• Reference pricing, exporter-side verification, and adjudication drafting; seizure-to-auction chain of custody.
  FBR–Inland Revenue
• E-invoicing and invoice-matching to detect fictitious sales and refund abuse.
  SBP (and bank AML teams)
• Look-back reviews on 2018-to-date payments; indicators of split-country settlements; STR/CTR case write-ups.
  SECP & Private Investigation Forums
• BO verification drills; corporate-registry analytics; liaison with auditors/CFEs on shell-company indicators.

14 C. Exercises & toolkits to include

• Document Congruence Lab: Invoice ↔ BL ↔ insurance ↔ packing list ↔ Form-I ↔ SWIFT; compute $/W and variance vs. benchmark.
• Bank Look-Back Simulation: Flag and narrate STRs for round-figure remittances, third-country payments, large cash deposits (mirrors the Pakistan record).
• JIT tabletop: FIA–Customs–SBP–SECP coordination with ML + predicate counts, restraint orders, and evidence disclosure timelines.
• Prosecutor’s Brief Pack: Charge-sheet templates, expert-witness CVs, and MLA request checklists.
• D. Comparative practice & case references (useful for class discussions)

United States

Black Market Peso Exchange (BMPE) remains a canonical TBML model; July 2025 sentencings illustrate current U.S. practice (DEA/IRS-CI, forfeiture, cross-border teamwork).
Training takeaway: embed joint financial-intelligence teams and storefront-to-export tracing.

United Kingdom

NCA civil recovery and transnational ML recoveries (recent £5.8m case) show strong use of civil tools alongside criminal proceedings.

The “failure to prevent facilitation of tax evasion” corporate offence pushes firms to adopt robust procedures—relevant to importers/clearing agents.
Training takeaway: combine criminal, civil-recovery and corporate-offence levers.

Singapore

MAS guidance sets detailed expectations for trade-finance AML and correspondent banking; Singapore Customs issues practitioner-level TBML indicators and STR guidance for traders/declarants.
Training takeaway: publish granular indicator lists and require traders to STR via a dedicated portal.

United Arab Emirates

UAE FIU strategic analysis (2024) on TBML typologies (incl. third-party intermediaries and sanctions risks) is a useful template for Pakistan’s Fusion-Cell analytics.
Training takeaway: national-level TBML risk assessments that feed sector-specific red flags.

Global Standards

FATF/Egmont 2020 TBML Update for case-study-rich training slides and red-flag annexes.

15. Program structure & delivery (6–8 weeks, modular)

• Week 1–2: A1–A3 (typologies, valuation, trade-finance AML) with hands-on document labs.
• Week 3–4: A4–A6 (analytics, BO, cross-border/MLA) with Fusion-Cell simulations.
• Week 5: A7 (prosecution strategy) with mock admissibility & expert-evidence hearings.
• Week 6: A8 + sector safeguards; build agency SOPs and an importer licensing checklist.
• Capstone: JIT tabletop on a Pakistan-style case file; deliver charge sheet + restraint orders + MLA pack + PSW/WeBOC red-flag queries.

Trainers to invite: senior Customs valuers; SBP supervisors (trade-finance); prosecutors with AMLA experience; data scientists; external CFEs, White Collor Crime Investigators/Trainers from public Sector and trade-finance bankers.

16. Quick reference to Pakistan facts you’re training against

• Rs111bn penalties on 13 importers; ghost/over-invoicing; dummy firms; cash deposits; seizures/auctions.
• Controls recommended: benchmark pricing, pre-shipment verification, PSW/WeBOC alerts, payment-route alignment, STR look-backs, importer licensing, Fusion-Cell, and MLA templates.
• Training Prospectus
• Title: Trade-Based Money Laundering (TBML) & Cross-Border Financial Crime Investigation – Capacity Building Program for Pakistan
• Duration: 6–8 weeks (modular, hybrid delivery)
• Target Audience:
• Public sector: FIA, FBR–Customs, FBR–Inland Revenue, SBP supervision, SECP corporate registry staff, Prosecutors.
• Private sector: Certified Fraud Examiners (CFEs), forensic accountants, trade-finance compliance officers, investigation consultancies.
• Rationale:
• The ongoing Solar Panel Import TBML Scandal — with Rs111bn in customs penalties, dummy importers, over-invoicing up to 5×, off-shore routing via UAE/Singapore, fake sales tax returns, and cash deposits exceeding Rs45bn — has exposed deep gaps in Pakistan’s AML/CFT enforcement, customs valuation, trade-finance compliance, and inter-agency coordination.
• Similar patterns have been seen in the U.S. Black Market Peso Exchange, UK NCA civil recovery cases, and Singapore Customs TBML typologies, all of which employ fusion analytics, cross-border MLA, and beneficial ownership verification as standard.
• Program Objectives:
• Build technical expertise in detecting TBML typologies (incl. over/under-invoicing, phantom shipments, split-country payments).
• Equip investigators with customs valuation & reference pricing tools for high-risk imports (e.g., PV modules).
• Train SBP/bank AML teams in trade-finance red flags & STR/CTR escalation.
• Operationalise a Customs–SBP–FBR Fusion Cell for real-time risk-scoring.
• Strengthen beneficial ownership tracing and shell-company dismantling.
• Enable swift MLA drafting & asset restraint abroad.
• Improve prosecution capacity for AMLA-linked TBML cases.
• Introduce renewable sector safeguards to avoid chilling investment while preventing abuse.
• Modules:
• A1–A3: TBML typologies, customs valuation, trade-finance AML.
• A4–A6: Data analytics, BO tracing, MLA/cross-border evidence.
• A7: Prosecution & expert testimony.
• A8: Sector safeguards & policy coherence.
• Methods:
• Document-congruence labs (invoice/BL/insurance/Form-I/SWIFT matching).
• Bank look-back simulations for STR/CTR triggers.
• Fusion-cell analytics drills.
• Joint Investigation Team (JIT) tabletop exercises.
• Mock court & expert testimony sessions.
• Comparative Insights:
• US: United States v. Black Market Peso Exchange — DEA/IRS-CI model for TBML disruption.
• UK: National Crime Agency v. Baker — civil recovery in cross-border ML.
• Singapore: MAS & Singapore Customs trade-finance AML advisories.
• UAE: FIU TBML typologies & sector-specific red flags.
• Deliverables:
• Trained cadre of public & private investigators.
• Draft SOPs for customs valuation, STR/CTR escalation, and MLA requests.
• Importer licensing framework for high-risk goods.
• Live Fusion-Cell dashboard demo.
• Bibliography:
• Pakistan – Primary Sources
• Federal Board of Revenue, Post-Clearance Audit Findings in Solar Panel Import Cases (Customs Adjudication, Karachi, 2025) [unreported] (as referenced in “A major scandal involving solar panel imports in Pakistan…” PDF).
• Directorate of Customs PCA Karachi v Bright Star Business Solution & Others (Adjudication Order, 2025) [unreported].
• First Information Reports – Solar Panel Import Over-Invoicing Cases (FIA/Customs,
• Peshawar & Lahore, 2023–2025) [unreported].
• Pakistan – Secondary Sources
• M Z I Kalanauri, ‘From Rejection to Reality: The Return of Solar Panel Tax in Pakistan’ Courting the Law (1 July 2025) https://courtingthelaw.com/2025/07/01/commentary/blawgs/from-rejection-to-reality-the-return-of-solar-panel-tax-in-pakistan/.
• ‘Govt Mulls Abolishing Sales Tax on Solar Panel Imports, Faces Rs20bn Revenue Hit’ Energy Update (19 June 2025) https://www.energyupdate.com.pk/2025/06/19/govt-mulls-abolishing-sales-tax-on-solar-panel-imports-faces-rs20bn-revenue-hit/.
• International Cases
• United States v Black Market Peso Exchange Network (DEA/IRS-CI, multiple indictments, S.D. Fla. 1990s–2025) [unreported] — see eg US Department of Justice, ‘Convictions in BMPE Trade-Based Money Laundering Cases’ (2025).
• National Crime Agency v Baker [2020] EWHC 822 (Admin) (civil recovery, unexplained wealth orders, UK High Court).
• United States v HSBC Bank USA NA (Deferred Prosecution Agreement, EDNY 2012) (trade-based AML failures).
• FATF+1
• Department of JusticeLaredo Morning Times
• Monetary Authority of Singapore
• National Crime Agency
• Skadden
• Monetary Authority of Singaporecustoms.gov.sg
• uaefiu.gov.ae
• FATFEgmont Group
• International Guidance & Typology Reports
• Financial Action Task Force (FATF), Trade-Based Money Laundering: Trends and Developments (Paris, FATF/OECD, December 2020).
• Egmont Group, TBML Case Studies Compilation (2020).
• Monetary Authority of Singapore (MAS), Trade Finance AML/CFT Guidelines (MAS, 2023).
• Singapore Customs, Advisory on Trade-Based Money Laundering (Singapore Customs, 2024).
• UAE Financial Intelligence Unit (FIU), National Risk Assessment: Trade-Based Money Laundering Typologies (Abu Dhabi, 2024).
• Comparative Legislative References
• UK, Criminal Finances Act 2017, s 45 (corporate offence of failure to prevent facilitation of tax evasion).
• Pakistan, Anti-Money Laundering Act 2010 (as amended).
• Pakistan, Customs Act 1969 (as amended).