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[null,"Prepared By:","Contributors:"]
[null,"RIAA Barker Gillette","Shafaq Rehman"]
[]
[]
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["Lex Mundi Global Anti-Corruption Compliance Guide"]
[]
["Report Generated: 4/28/2025"]
[]
["View your report results on next tab"]

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["Question","Pakistan"]
["Anti-Corruption Compliance"]
["What is the key anti-bribery and corruption legislation in your jurisdiction?"," In Pakistan, anti-bribery and corrupt practices are not regulated exclusively by a single piece of legislation. The following are some of the key anti-bribery and corruption legislation in Pakistan: \n\n \n\t the  Pakistan Penal Code, 1860 (hereinafter referred to as the “ PPC ”); \n\t the Prevention of Corruption Act, 1947 (hereinafter referred to as the “ PCA ”); \n\t the Pakistan Army Act of 1952 (hereinafter referred to as the “ Pakistan Army Act ”); \n\t the Pakistan Army Act Rules of 1954 (hereinafter referred to as the “ Pakistan Army Rules ”); \n\t the Army Regulations of 1986 (hereinafter referred to as the “ Army Regulations ”); \n\t theâ€‹â€‹â€‹â€‹â€‹â€‹â€‹ Pakistan Air Force Act of 1953 (hereinafter referred to as the “ Pakistan Air Force Act ”); \n\t theâ€‹â€‹â€‹â€‹â€‹â€‹â€‹  National Accountability Bureau Ordinance,1999 (hereinafter referred to as the “ NAO ”); \n\t theâ€‹â€‹â€‹â€‹â€‹â€‹â€‹ Government Servant (Conduct) Rules, 1964 (hereinafter referred to as the “ GSR ”); \n\t theâ€‹â€‹â€‹â€‹â€‹â€‹â€‹ Islamabad Capital Territory Local Government Act, 2015 (the “ ILGA ”); \n\t theâ€‹â€‹â€‹â€‹â€‹â€‹â€‹ Sindh Local Government Act, 2013 (hereinafter referred to as the “ SLGA ”); \n\t theâ€‹â€‹â€‹â€‹â€‹â€‹â€‹ Punjab Local Government Act 2019 (hereinafter referred to as the “ PLGA ”); \n\t theâ€‹â€‹â€‹â€‹â€‹â€‹â€‹ Khyber-Pakhtunkhwa Local Government Act, 2013 (hereinafter referred to as the “ KPLGA ”); \n\t theâ€‹â€‹â€‹â€‹â€‹â€‹â€‹ Balochistan Local Government Act, 2010 (hereinafter referred to as the “ BLGA ”);  \n\t theâ€‹â€‹â€‹â€‹â€‹â€‹â€‹ Public Sector Companies (Corporate Governance) Rules, 2013 (hereinafter referred to as the “ Corporate Governance Rules ”); and \n\t the  Listed Companies (Code of Corporate Governance) Regulations 2019 ) (hereinafter referred to as the \" Corporate Governance Regulations \").  \n \n\n The ILGA, SLGA, PLGA, KPLA and BLGA shall collectively be referred to as the \" LGA s\". \n"]
["Has there been a specific anti-bribery and corruption law enacted in your jurisdiction in the last ten years?"," No. While no specific anti-bribery and corruption laws have been promulgated in the last ten years, the following laws (promulgated within the last ten years) address anti-bribery and corruption: \n\n \n\t The LGA s \n \n\n The LGA s regulate inter alia corrupt practices and bribery by members and electoral candidates of local government councils, as well as by members of the public in relation to local government elections in the provinces and capital territory of Pakistan. Amongst other things, the LGA s aim to introduce transparency in the electoral process as well as the acts of local government officials.  \n\n \n\t The Corporate Governance Rules \n \n\n The Corporate Governance Rules apply to all public sector companies and regulate the conduct of officers and directors of such companies. The Corporate Governance Rules require every board of a public sector company to develop and implement anti-corruption policies as well as a mandatory declaration from each director and executive of a public sector company that they shall not offer or accept any payment, bribe, favor or inducement which might influence, or appear to influence, their decisions and actions. The Corporate Governance Rules also provide for the removal of a director of a public sector company who engages in acts of misconduct, which is defined to include acts of corruption. \n\n \n\t The Corporate Governance Regulations \n \n\n The Corporate Governance Regulations require every board of listed companies to constitute an audit committee of at least three members comprising non-executive directors and at least one independent director. It is mandatory that the Board shall provide adequate resources and authority to enable the audit committee to carry out its responsibilities effectively including consideration of major findings of internal investigations of activities characterized by fraud, corruption and abuse of power and management's response thereto. The audit reports involving the cases of corruption and bribery shall be one of the significant issues to be placed for the decision of the board of directors. \n"]
["Is a bribe payment to domestic government officials prohibited by the legislation?"," Yes. The act of bribing domestic government officials is prohibited and treated as an offense under the provisions of the NAO , read with the PPC .  \n\n \n\t The PPC \n \n\n As per Section 161 of the PPC, it is a crime for a public servant to receive any payment or benefit other than that which is permitted by the authority by which he is employed as a motive or reward for carrying out of an act under his official capacity. Such a provision is inclusive of obtaining a bribe and accepting an offered bribe. Further, in accordance with Section 165 of the PPC, it is an offense if a public servant accepts or obtains, or agrees to accept or attempts to obtain for him or herself, or for any other person, any valuable thing without consideration, or for a consideration which he or she knows to be inadequate, from any person whom he or she knows to have been, or to be, or to be likely to be concerned in any proceeding or business transacted or about to be transacted by such public servant or having any connection with the official functions for him or herself or of for any public servant to whom he or she is subordinate, or from any person whom he or she knows to be interested in or related to the person so concerned. \n\n \n\t The NAO \n \n\n Under Section 9 of the NAO , a holder of public office or any other person is said to have committed corrupt practices if he commits any of the following acts:  \n\n \n\t if he accepts or obtains from any person or offers any gratification as specified in Section 161 of the PPC ; \n\t if he accepts or obtains from any person or offers any valuable thing without consideration as specified in Section 165 of the PPC ; \n\t if he dishonestly or fraudulently misappropriates or otherwise converts for his own use, or for the use of any other person, any property entrusted to him or under his control, or willfully allows any other person to do so; \n\t if he, by corrupt, dishonest, or illegal means, obtains or seek to obtain for himself or for his spouse, or dependents or any other person any property, valuable thing or pecuniary advantage;  \n\t if he or any of his dependents or beneficiaries own, possesses, or has acquired right or title in acquired assets or holds irrevocable power of attorney in respect of any assets or pecuniary resources disproportionate to his known sources of income, which he cannot reasonably account for or maintains a standard of living beyond that which is commensurate with his sources of income; \n\t if he misuses his authority so as to gain any benefit or favor for himself or any other person, or renders or attempts to render or willfully fails to exercise his authority to prevent the grant, or rendition of any undue benefit or favor which he could have prevented by exercising his authority; \n\t if he has issued any directive, policy, SRO ( Statutory Regulatory Order ) or any other order which grants or attempts to grant any undue concession or benefit in any taxation matter or law or otherwise so as to benefit himself or any relative or associate or a benamidar or any other person; \n\t if he commits an offense of wilful default; \n\t if he commits the offense of cheating as defined in Section 415 of the PPC , and thereby dishonestly induces members of the public at large to deliver any property including money or valuable security to any person; \n\t if he commits the offense of criminal breach of trust as defined in Section 405 of the PPC with regard to any property including money or valuable security entrusted to him by members of the public at large; and \n\t if he, in his capacity as a banker, merchant, factor, broker, attorney or agent, commits criminal breach of trust as provided in Section 409 of the PPC in respect of property entrusted to him or over which he has dominion. \n \n"]
["Is a bribe payment to foreign government officials prohibited by the legislation?","The bribery of foreign officials is not specifically regulated.\n"]
["Is requesting or accepting a bribe prohibited by the legislation?"," Yes. Requesting or accepting a bribe is prohibited under the provisions of the PPC , PCA , Pakistan Army Act, Pakistan Air Force Act, NAO, GSR, LGA s and Corporate Governance Rules . For details on the NAO , please see the answer to \"Is a bribe payment to domestic government officials prohibited by the legislation?\" . \n\n The PPC \n\n In addition to the provisions of the PPC discussed in the answer to \"Is a bribe payment to domestic government officials prohibited by the legislation?\"  above, Section 162 of the PPC makes it a crime for any person to accept or obtain, or agree to accept or attempt to obtain for himself or any other person any gratification, as a motive or reward for inducing any public servant to do or forbear to do any official act or show favor or disfavor. Under Section 163 , any person, who accepts or obtains or agrees to accept or attempts to obtain, from any person, for him or herself or for any other person, any benefit whatsoever, as a motive or reward for inducing, by the exercise of personal influence, any public servant to do or to forbear to do any official act, or in the exercise of the official functions to show favor or disfavor to any person, be it for him or herself or for any other person will be liable for punishment with imprisonment for a term which may extend to one year, or fine or both.  \n\n The PCA \n\n Section 5 of the PCA provides inter alia the following offenses of criminal misconduct committed by a public servant: \n\n \n\t any act as mentioned under Section 161 of the PPC ; \n\t accepting/agreeing to accept or attempting to obtain for himself, or any other person, any valuable thing without consideration or for a consideration which he knows to be inadequate, from any person whom he knows to be, or likely to be, concerned in any proceeding of business, transacted by him or in relation with his official functions or those of any public servant to whom he is subordinate;  \n\t if he dishonestly or fraudulently misappropriates or otherwise converts for his own use any property entrusted to him or under his control as a public servant or allows any person to do so, or \n\t if he, by corrupt or illegal means, or by otherwise abusing his position as a public servant, obtains for himself or for any other person any valuable thing or pecuniary advantage; or \n\t if he or any of his dependents is in possession of pecuniary resources or of property disproportionate to his known sources of income which the public servant cannot reasonably account for.  \n \n\n The GSR \n\n As per Section 5 of the GSR no government servant, except with the prior sanction of the government, shall accept or permit any member of his family to accept, from any person any gift the receipt of which will place him under any form of official obligation to the donor. The GSR provides for exceptional circumstances where if the gift cannot be refused, it may be kept for official use in the department or organization where the concerned government servant is working. \n\n Pakistan Army Act \n\n Under Section 42 , a person subject to the Army Act who directly or indirectly accepts or obtains, or agrees to accept, or attempts to obtain, from any person for him/herself or any other person, any gratification other than legal remuneration, as a motive or reward for doing or forbearing to do any act, or for showing favor or disfavor to any person, in relation to any of the affairs of the State or of any service affairs, shall be punishable.  \n\n Pakistan Air Force Act \n\n Under Section 66 (e) of the Pakistan Air Force Act any person subject to the Pakistan Air Force Act , who directly or indirectly accepts or obtains or agrees to accept or attempts to obtain, for himself or for any other person, any gratification as a motive or reward for procuring the enrollment of any person, or leave of absence, promotion or any other advantage or indulgence for any person in the service shall, on conviction by court-martial, be liable to suffer short imprisonment which may be rigorous or simple, for a term not exceeding two years. \n\n LGA s \n\n Each of the respective LGA s makes it an offense to commit bribery. Each of the LGA s (other than the PLGA ) contains a comprehensive definition of acts of bribery, committed directly or indirectly by any person, which acts include (a) receiving, agreeing or contracting for any gratification for voting or refraining from voting or refraining from being a candidate at or withdrawing or retiring from an election; and (b) giving, offering or promising any gratification to or rewarding any person for the purposes of inducing a person to be or refrain from being an electoral candidate or withdrawing from an election or inducing or rewarding voters to vote or refrain from voting at any election. \n\n Further, pursuant to the PLGA , “corruption” by a head of the local government, convenor, counselor or an officer or servant of a local government or any other person acting under this Act means (i) accepting, obtaining or offering any gratification or valuable thing, directly or indirectly, other than the legal remuneration, as a reward for doing or for bearing to do any official act; or (ii) dishonestly or fraudulently misappropriating, or indulging in embezzlement or misuse of property or resources of a local government; or (iii) possession of pecuniary sources or property by himself or any of his dependents or any other person, through him or on his behalf, which cannot be accounted for and which are disproportionate to his known sources of income; or (iv) maintaining standard of living beyond known sources of income; or (v) having a reputation of being corrupt; or (vi) entering into plea bargain under any law for the time being in force and return the assets or gains acquired through corruption or corrupt practices, voluntarily. The PLGA further provides that no person shall directly or indirectly, by himself or by any other person on his behalf receive, agree to or contract for; or give, offer or promise any gratification to: \n\n \n\t cast a vote or refrain from casting a vote; or \n\t refrain from being a candidate at, or to withdraw or retire from an election. \n \n\n Corporate Governance Rules \n\n The Corporate Governance Rules require every board of a public sector company to develop and implement anti-corruption policies as well as a mandatory declaration from each director and executive of a public sector company that they shall not offer or accept any payment, bribe, favor or inducement which might influence, or appear to influence, their decisions and actions. \n"]
["Who is subject to the legislation?"," The PPC \n\n A public servant is the subject matter under Sections 161 and 164 of the PPC with respect to anti-bribery and corruption. The term ‘public servant’ has been defined under Section 21 of the PPC to denote a person falling under the following description: \n\n \n\t Every Commissioned Officer in the Military, Naval or Air Forces of Pakistan while serving under the Federal Government or any Provincial Government;  \n\t Every Judge;  \n\t Every officer of a Court of Justice whose duty it is, as such officer, to investigate or report on any matter of law or fact, or to make, authenticate, or keep any document, or to take charge or dispose of any property, or to execute any judicial process, or to administer an oath, or to interpret, or to preserve order in the Court; and every person specially authorized by a Court of Justice to perform any of such duties;  \n\t Every juryman, assessor, or member of a panchayat assisting a Court of Justice or public servant;  \n\t Every arbitrator or other person to whom any cause or matter has been referred for decision or report by any Court of Justice, or by any other competent public authority;  \n\t Every person who holds any office by virtue of which he is empowered to place or keep any person in confinement;  \n\t Every officer of the government whose duty it is, as such officer, to prevent offenses, to give information of offenses, to bring offenders to justice, or to protect the public health, safety or convenience;  \n\t Every officer whose duty it is, as such officer, to take, receive, keep or expend any property on behalf of the government, or to make any survey, assessment or contract on behalf of the government, or to execute any revenue process, or to investigate, or to report, or any matter affecting the pecuniary interests of the government, or to make, authenticate or keep any document relating to the pecuniary interests of the government, or to prevent the infraction of any law for the protection of the pecuniary interests of the government, and every officer in the service or pay of the government or remunerated by fees or commission for the performance of any public duty;  \n\t Every officer whose duty it is, as such officer, to take, receive, keep or expend any property, to make any survey or assessment or to levy any rate or tax for any secular common purpose of any village, town or district, or to make, authenticate or keep any document for the ascertaining of the rights of the people of any town or district; and \n\t Every person who holds any office in virtue of which he is empowered to prepare, publish, maintain or revise an electoral roll or to conduct an election or part of an election. \n \n\n The PCA \n\n The provisions of the PCA are applicable to public servants. The term ‘public servant’ means a public servant as defined in Section 21 of the PPC and includes an employee of any corporation or other body or organization set up controlled or administered by or under the authority of the Federal Government. \n\n The Pakistan Army Act \n\n The following persons are subject to the Pakistan Army Act : officers, junior commissioned, officers and warrant officers of the Pakistan Army and persons enrolled under the Pakistan Army Act, until they duly retire, are released, discharged, removed, or dismissed from service. In addition, persons not otherwise subject to the Pakistan Army Act , who, on active service, in camp, on the march, or at any frontier post specified by the Federal Government by notification, are employed: by, or are in the service of or are followers of, or accompany any portion of the Pakistan Army, will also be subject for the specified time to the Pakistan Army Act .  \n\n The Pakistan Air Force Act \n\n Pursuant to Section 2 of the Pakistan Air Force Act , the following persons shall be subject to the Pakistan Air Force Act , wherever they may be:  \n\n \n\t Officers and warrant officers of the Pakistan Air Force; \n\t Persons enrolled under the Pakistan Air Force Act ; \n\t Persons belonging to the Air Force Reserves in the circumstances prescribed by rules made under Section 6 of the Pakistan (Army and Air Force) Reserves Act, 1950 ; and \n\t Persons not otherwise subject to Pakistan Air Force law who are on active service, in camp, on the march, or at any frontier post specified by the Central Government, by notification in this behalf; are employed by or are in the service of; or are followers of; or accompany any; portion of the Pakistan Air Force.  \n \n\n The NAO \n\n The NAO applies to all persons (i.e., holders of public office or private citizens, and the provider and recipient of any benefit) in Pakistan, and persons who are or have been in the service of Pakistan, wherever they may be. \n\n The GSR \n\n The GSR applies to every person, whether on duty or on leave, within or without Pakistan, serving in a civil capacity in connection with the affairs of the center and to the members of an All-Pakistan Service during their employment under the Provincial Governments or while on deputation with any other government, agency, institution or authority to every person serving provincial government in a civil capacity, within or outside of Pakistan. \n\n The LGA s \n\n The LGA s applies to every member and electoral candidate of local government councils, as well as by members of the public in relation to local government elections in the relevant provinces of Pakistan and the Islamabad Capital Territory.  \n\n The Corporate Governance Rules \n\n The Corporate Governance Rules apply to all public sector companies and regulate the conduct of the officers and directors of such companies. \n\n The Corporate Governance Regulations \n\n The Corporate Governance Regulations are applicable to listed companies based on “comply or explain approach” except those requirements which are explicitly stated as “mandatory” and it shall be the responsibility of the board of directors to use this approach wisely and of investors to assess differing company approaches thoughtfully. \n"]
["Is there criminal liability for corporate entities who have either paid or accepted a bribe payment?","No. However, as per the \nNAO, the offenses set out in \nSection 9 (as discussed in the answer to \n\"Is a bribe payment to domestic government officials prohibited by the legislation?\" above) extend to, in the case of a company or a body corporate, the sponsors, chairman, chief executive, managing director, elected directors, by whatever name called, and guarantors of the company or body corporate or anyone exercising direction or control of the affairs of such company or a body corporate.\n"]
["What is the penalty for individuals violating the law?"," The penalties for individuals for violating the laws are as follows: \n\n The PPC \n\n Any person liable under S ections 161, 162, 163 and 165 and 165 A of the PPC shall be punishable with imprisonment for a term which extends to three years, or a fine, or with both. An offense under Section 163 is liable to imprisonment of a term which extends to one year, or a fine, or with both. \n\n The PCA \n\n A public servant who commits or attempts to commit criminal misconduct or possesses property disproportionate to his/her known sources of income shall be punishable with imprisonment for a term which may extend to ten years but not less than seven years or with fine, or with both.    \n\n The NAO \n\n A person who commits the offense of corruption and corrupt practices may be punished with up to 14 years imprisonment, or a fine, or both. In addition, such assets and property found to be disproportionate to the known sources of his/her income or ones acquired by money obtained through corruption and corrupt practices, whether in his/her name or in the name of any of his/her dependents or beneficiaries, are subject to forfeiture to the appropriate government.  \n\n Furthermore, any person giving illegal gratification, or abetting a holder of a public office in any manner including by receiving or holding any property obtained or acquired by such holder, or by deriving any benefit through the commission of the offense of Section 9 , is liable to be punished by the same or a lesser punishment that may be awarded to a holder of public office. Where an accused found guilty of the offense is sentenced to pay a fine, the amount of the fine imposed shall not be less than the gain derived by the accused or any relative or associate by the commission of the offense. \n\n A person convicted of corruption and corrupt practices under Section 9 will forthwith cease to hold public office, if any, held by him and will also be disqualified from seeking or holding, as a member or a representative, any public office, or any statutory or local authority of the Government of Pakistan for a period of 10 years. This ban is also applicable to those persons who during or before the commencement of trial opt for plea-bargaining.  \n\n The GSR \n\n If a government servant behaves in a manner contrary to the GSR he shall be liable to the following penalties, as imposed by an authorized officer under the Government Servants (Efficiency and Discipline) Rules, 1973 , or a competent authority under the Removal from Service (Special Powers) Ordinance, 2000 :  \n\n Minor penalties:  \n\n \n\t censure;  \n\t withholding, for a specific period, promotion or increment, otherwise than for unfitness for promotion or financial advancement in accordance with the GSR or orders pertaining to the service or post;  \n\t stoppage, for a specific period, at an efficiency bar in the timescale, otherwise than for unfitness to cross such bar; and \n\t recovery from the pay of the whole or any part of any pecuniary loss caused to the government by negligence or breach of orders. \n \n\n Major Penalties: \n\n \n\t reduction to a lower post or time-scale, or to a lower stage in a time scale; \n\t compulsory retirement; \n\t removal from service (which disqualifies the individual from future employment); and \n\t dismissal from service.  \n \n\n The Pakistan Army Act \n\n Upon conviction by a court-martial of an offense under Section 42 , the person shall be subject to rigorous imprisonment for a term which may extend up to five years.  \n\n The Pakistan Air Force Act \n\n The punishments awarded by court-martial under this Act are as follows:   \n\n \n\t long imprisonment which shall be rigorous and for a term not exceeding fourteen years;  \n\t short imprisonment which may be rigorous or simple, for a term not exceeding two years (this applies specifically to the offense of bribery); \n\t detention for a term not exceeding two years in the case of airmen;  \n\t dismissal from service;  \n\t reduction to the ranks or to a lower rank or to a lower grade, in the case of warrant officers and non-commissioned officers; and forfeiture of all or any part of their service for the purpose of promotion, in the case of any of them whose promotion depends upon the length of service;  \n\t forfeiture of seniority of rank in the case of officers warrant officers and non-commissioned officers and forfeiture of all or any part of their service for the purpose of promotion in the case of any of them whose promotion depends upon the length of service;  \n\t forfeiture of service for the purpose of increased pay, pension or any other prescribed purpose;  \n\t severe reprimand or reprimand in the case of officers, warrant officers, and non-commissioned officers:  \n\t forfeiture of pay and allowances for a period not exceeding three months for an offense committed on active service;  \n\t forfeiture in the case of a person sentenced to dismissal from the service of all arrears of pay and allowances and other public money due to him at the time of such dismissal;  \n\t stoppages of pay and allowances until any proved loss or damage occasioned by the offense of which he is convicted is made good.  \n \n\n The LGA s \n\n The LGA s (other than the BLGA and PLGA ) provide a penalty of imprisonment of up to three years as well as a fine of up to PKR 100,000, or both, for anyone found guilty of the offenses related to acts of bribery. The BLGA prescribes a penalty of imprisonment of up to three years, as well as a fine of up to PKR 15,000 or both for anyone, found guilty of the offenses related to bribery. The PLGA provides a punishment of imprisonment for a term not exceeding three years, or with fine not exceeding fifty thousand rupees, or with both for the offense of offering, accepting or promising illegal gratification. In addition, where a head of the local government, convenor or counselor is involved in a dereliction relating to corruption or corrupt practice, or gross excess in the use of his authority, or conviction in a crime involving moral turpitude, and fails to show cause within the specified period or the cause shown by him in the opinion of the Government, unsatisfactory, the Government may suspend him, in accordance with the terms of the PLGA .  \n"]
["Assuming corporate entities are liable for violating the legislation, what is the penalty for corporate entities violating the law?","N/A. Please see the answer to \n\"Is there criminal liability for corporate entities who have either paid or accepted a bribe payment?\".\n"]
["Assuming corporate entities are liable for violating the legislation, does having a compliance program designed to prevent bribery constitute a defense?","N/A. Please see the answer to \n\"Is there criminal liability for corporate entities who have either paid or accepted a bribe payment?\".\n"]
["Assuming corporate entities are liable for violating the anticorruption law, is it possible for a corporate entity to reach a deferred prosecution agreement or leniency agreement with the enforcement authorities?","N/A. Please see the answer to \n\"Is there criminal liability for corporate entities who have either paid or accepted a bribe payment?\".\n"]