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RBI flags indirect fund flows from Pakistan as high-risk after conflict investigations

On August 6, 2025, the Reserve Bank issued an advisory requiring banks to tighten scrutiny over funds routed through third countries from Pakistan, citing terror financing and arms procurement concerns.

FINSAMUDRA DESK · 27 Aug 2025, 1:55 pm IST · 2 MIN

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🔒 India Flags Indirect Fund Flows from Pakistan as “High-Risk” — Image: Finsamudra LinkedIn archive

The RBI's move follows investigations into the May 2025 India–Pakistan conflict, which uncovered funds being channelled into India via third-country intermediaries. The central bank has now formally classified Pakistan as a "high-risk" jurisdiction, mandating enhanced anti-money laundering (AML) and know-your-customer (KYC) checks across the banking system.

Banks and financial institutions now face operational pressure to strengthen due diligence on indirect payment routes originating from Pakistani sources. Regulatory negligence or weak compliance systems carry material penalties: reputational damage, supervisory action, and enforcement risk for institutions that fail to detect illicit flows.

Pakistan's State Bank and banking association dismissed the advisory as politically motivated, asserting their existing anti-money laundering and counter-financing of terrorism (CFT) frameworks comply with international standards. The dispute underscores mounting cross-border financial tension even as global bodies like the Financial Action Task Force (FATF) intensify focus on proliferation financing and sanctions evasion.

The advisory aligns India's banking oversight with international financial security norms. Third-country routing mechanisms—particularly through Southeast Asian hubs, Middle Eastern intermediaries, and informal channels—are now under heightened scrutiny across the sector.

For compliance teams, the order is unambiguous: review correspondent banking relationships, audit transaction flows from high-risk jurisdictions, and flag suspicious remittance patterns. The RBI has effectively signalled that Pakistan-origin funds, regardless of transit points, warrant enhanced vetting.

This regulatory shift reflects a broader fusion of national security doctrine with financial regulation. As geopolitical tensions drive policy, India's lending ecosystem must absorb compliance costs and operational friction to maintain banking system integrity.

Why it matters for connectors & lenders

For DSAs, connectors, and loan distribution networks, this advisory tightens the compliance burden upstream. Any retail lending transaction linked—however distantly—to cross-border fund flows now faces extended due diligence windows. Banks may impose stricter KYC norms on applicants with overseas connections, slowing loan approvals and narrowing addressable credit markets for fintech platforms that scale through speed.

For NBFCs and smaller lenders working with DSA partners, the advisory compounds Know-Your-Customer costs and extends settlement timelines. Enhanced third-party verification on fund sources means loan origination cycles lengthen, capital deployment slows, and compliance overhead rises. Connectors must now factor regulatory delays and potential transaction rejections into their DSA economics.

RBI flags indirect fund flows from Pakistan as high-risk after conflict investigations

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