FATF’s Oman case shows why Pakistani banks must detect cross-border relationships hidden inside ordinary domestic payments.
A Pakistani bank can receive a perfectly ordinary Raast transfer at 10:17 in the morning. Imagine Rs85,000 entering a personal account in Karachi. The beneficiary is known, the account is active, and the payment arrives through Pakistan’s national instant-payment system. Nothing in the payment message says Oman, hawaladar or informal remittance.
Yet the economic story behind the transfer may have begun in Muscat.
Raast hawala monitoring therefore cannot stop at the domestic payment message. FATF’s September 2026 report on underground banking and hawala describes an Oman case in which suspected operators offered expatriates cheaper remittance services and used payment channels in destination countries, including fee-free Raast transfers in Pakistan. SBP correctly responded that Raast itself does not process cross-border transfers and that FATF did not identify Raast as a money-laundering mechanism.
Both statements can be true. A domestic payment rail can remain technically sound while an informal network uses it for the local payout leg of a wider cross-border arrangement.
Raast Hawala Monitoring Cannot Depend on One Transaction
The first mistake would be to treat every unusual Raast payment as evidence of hawala. Raast has become too large and too ordinary for that approach.
SBP’s Q2 FY26 Payment Systems Review shows how quickly the system has expanded:
| Measure | Q2 FY25 | Q2 FY26 | Change |
|---|---|---|---|
| Total Raast transactions | 295.7 million | 645.7 million | +118% |
| Total value | PKR 6.36 trillion | PKR 18.47 trillion | +190% |
| P2P transactions | 293.7 million | 603.0 million | +105% |
| P2P value | PKR 6.14 trillion | PKR 15.69 trillion | +156% |
At that scale, a crude rule based on transaction value will create noise. A salary account may suddenly receive money for a wedding. A small trader may collect payments from many customers. A family may move funds between relatives. None of those facts proves an informal remittance arrangement.
Banks need to ask a different question: does the behaviour fit what they know about the customer?
SBP’s AML/CFT/CPF rules already point in that direction. Regulated entities are expected to use automated transaction-monitoring systems and compare activity with customer profiles. Transactions that depart from the history or normal operation of an account require closer examination.
Raast adds speed and volume to an old monitoring problem. The answer should not be to make Raast slower.
The Account Pattern Matters More Than the Payment
A single domestic transfer often tells very little. A sequence can tell much more.
Compliance teams should pay attention when a personal account receives funds from many unrelated senders and quickly disperses them to other beneficiaries. Analysts often describe those patterns as fan-in and fan-out. Rapid pass-through matters too: money arrives and leaves so quickly that the account behaves more like a conduit than an account used for normal personal or business activity.
FMU’s own hawala typologies have repeatedly highlighted accounts with activity inconsistent with the customer’s profile, unrelated counterparties and rapid movement of funds. Older payment instruments produced those patterns before Raast existed. Instant payments can now compress the same behaviour into minutes.
No single indicator should trigger an accusation. A marketplace seller can show high fan-in. A payroll account can show fan-out. A charity can receive money from people who have no obvious relationship with one another.
Context decides whether the pattern deserves escalation. Banks need combinations of signals followed by human review.
KYC Must Become Behavioural, Not Merely Documentary
Know Your Customer often receives most attention when an account is opened. The customer provides an identity document, occupation, expected income and purpose of account. The file can look complete on day one and become stale months later.
Digital hawala makes ongoing profiling more important.
A stronger model would continuously compare actual account behaviour with the customer’s expected activity. A salaried person who suddenly begins receiving dozens of transfers from unrelated people deserves a different review from a retailer whose business naturally produces the same pattern.
Centralised KYC could help, but the phrase needs care. Pakistan should not create a giant pool of customer data that every institution can browse. Privacy and data-security rules must govern legal access.
A more defensible goal is consistent customer-risk information and stronger ecosystem-level analytics under clear regulatory authority. Banks still need responsibility for their own customers. SBP and FMU need enough visibility to identify patterns that cross institutional boundaries.
Better profiling should reduce false positives rather than multiply them.
From I. I. Chundrigar Road, the Gap Looks Familiar
Working around banking and SWIFT taught me to separate the message from the economic relationship behind it.
A SWIFT message can be technically valid while the underlying transaction still raises a compliance question. Nobody would conclude that SWIFT itself had failed simply because a suspicious payment used the network. Investigators would examine the parties and the economic purpose of the transaction.
Raast deserves the same distinction.
SBP’s September 4 clarification matters because some reporting blurred the line. Raast currently handles domestic payments. FATF did not say that Raast carried money from Oman into Pakistan.
The Oman case points to a different mechanism. A customer abroad can give value to a hawala operator. The network can create an obligation to pay a beneficiary in Pakistan. A counterpart in Pakistan can then use local funds to make the payout through Raast.
The Raast transaction remains domestic. The economic relationship does not.
Digitalisation therefore does not automatically eliminate hawala. It can give an informal network a cheaper domestic payout tool while the cross-border settlement happens somewhere else.
Banks Need Network Analysis, Not More Blanket Limits
Pakistan should resist the easiest response: lowering limits for everyone.
Blanket restrictions punish ordinary customers and weaken one of Raast’s main advantages. They can also push activity back toward cash, where monitoring becomes harder.
Banks should instead examine networks. An account that repeatedly receives funds from unrelated people may connect to another account showing the same behaviour. Several accounts may share devices or contact details where law and available data permit those links to be analysed. Recurring counterparties can reveal a pattern that no individual payment exposes.
FMU typologies already show the value of connected-account analysis. One published hawala case describes interlinked accounts with heavy turnover and unrelated counterparties. Another describes rapid movement of funds linked with people already suspected of illegal foreign-exchange activity.
Fraud monitoring and AML monitoring also need different questions. Fraud systems often ask whether the customer authorised a payment. AML systems ask whether an authorised payment makes economic sense in the customer’s broader activity. A transfer can pass authentication checks and still deserve AML review.
Graph analysis can help compliance teams find those relationships, but an algorithm should not become a verdict. Analysts still need evidence and customer context. Their reasoning should be documented before an STR is filed.
SBP Can See a Problem One Bank May Miss
One bank may see only one fragment.
Imagine an account at Bank A receiving money from several customers. Some funds move to Bank B. Another part reaches a wallet at a third institution. Each institution sees its own customer and its own transactions.
No bank necessarily sees the whole network.
SBP, Raast’s operator and FMU occupy different positions in the system. Their legal powers and responsibilities also differ. Pakistan should examine whether privacy-preserving, regulator-led analytics can identify cross-bank patterns without turning the payment system into an unrestricted customer-surveillance database.
The distinction matters. Central visibility should identify risk patterns and support lawful investigation. It should not erase institutional accountability or customer privacy.
A sensible model would allow regulators to identify suspicious network structures and then route intelligence to the institutions or authorities legally entitled to act on it.
Speed also matters. Instant payments can move through several accounts before a traditional case-review process begins. Monitoring has to become closer to the speed of the payment system without assuming that every fast transfer is suspicious.
The Missing Record May Sit Outside Pakistan
FATF’s Oman case exposes the hardest problem.
A Pakistani bank can see the domestic payout. It may know the account holder and counterparties in Pakistan. The bank may even detect rapid pass-through behaviour. Yet none of those records necessarily explains why someone in Oman handed money or value to an informal operator.
The missing information may sit with an Omani bank, an e-wallet provider or investigators who identified the suspected hawala network.
FMU already has a legal basis for cooperation with foreign financial-intelligence units. Its international-cooperation guidance explains that Section 6(4)(e) of the Anti-Money Laundering Act empowers FMU to exchange relevant information with counterpart financial-intelligence units through reciprocal arrangements.
That international connection is where Raast hawala monitoring becomes more than a software problem.
Pakistan can improve customer profiling while banks tune transaction-monitoring scenarios. Regulator-led analysis can also expose cross-bank patterns. Even together, those measures cannot reconstruct an offshore relationship that never appears in the domestic payment message.
The next test is whether Pakistan can connect a suspicious-looking domestic pattern with foreign intelligence quickly enough to understand what it means.
A payment in Karachi may look entirely local.
The record that explains it may be sitting in Muscat.
Related Reading: Pakistan Built Raast to Fight Cash. Hawala Found a Way In
This analysis was drafted under editorial direction with AI technical assistance, then verified and edited by Munaeem Jamal.
