The First Counsel

Practice Area

Regulatory Enforcement (SECP · SBP · FBR)

We act for companies, financial institutions, and their officers in enforcement proceedings brought by the SECP, the State Bank of Pakistan, and the FBR — from the first show-cause notice to the last appeal. The work is procedural at its core: answer on time, answer on the record, and answer with the eventual challenge already in view.

Enforcement begins with a notice and a deadline, and the response to that notice becomes the record for everything that follows — the adjudication order, the appeal, the writ, and any parallel criminal complaint. So we write the first response as if the last court will read it, because it will. Admissions are made deliberately or not at all; facts are supported by the document that proves them; and points of jurisdiction are taken at the start, since a ground not raised before the regulator is a ground the appellate forum may never hear.

The three regulators run on different clocks and different temperaments, and matters increasingly cross between them: an SBP inspection finding surfaces in an FIA enquiry, an FBR audit feeds a money-laundering predicate, an SECP order is quoted in a shareholder dispute. We map the exposure across agencies at the outset and keep one consistent factual account across every forum. Where officers are named personally — and they usually are — their defense is coordinated with the company's, and separated the moment interests diverge.

Timelines and forums in this field move with the Finance Act each year and with the regulators' own regulations. The positions on this page — including the appellate structure for tax cases and the arrest powers in fraud matters — are stated as of mid-2026 and are verified at the outset of every mandate.

How We Serve

The SECP enforces the Companies Act 2017 and its regulatory statutes through show-cause notices that name companies and, routinely, their directors and officers personally. We draft the response, appear at the adjudication hearing, and contest the penalty order. Because the Commission publishes its orders, we treat every filing as a public document from the first line.

We defend insider trading, market manipulation, and disclosure cases under the Securities Act 2015, including proceedings arising from PSX surveillance referrals and the Commission's own enquiries. We act for issuers, brokers, and individuals, and we advise before trading windows and disclosures ever become a file.

The Companies Act 2017 gives the Commission power to inspect books and to order investigations into a company's affairs. We manage the production of records, prepare officers for examination, and hold the inspection to its stated scope — what leaves the building in an inspection frames everything that follows.

We represent banks, exchange companies, and their sponsors and officers in State Bank enforcement under the Banking Companies Ordinance 1962, in fit-and-proper proceedings, and in adjudication of contraventions under the Foreign Exchange Regulation Act 1947. AML and CFT inspection findings under the Anti-Money Laundering Act 2010 increasingly drive this docket, and we answer them with the remediation evidence the regulator actually weighs.

We handle audits and amended assessments under section 122 of the Income Tax Ordinance 2001, and we resist coercive recovery — including bank-account attachment under sections 138 and 140 — while the appeal runs. First appeals now divide between the Commissioner (Appeals) and the Appellate Tribunal Inland Revenue by pecuniary value following the 2024 amendments, with a reference to the High Court under section 133 on questions of law; we confirm the current forum and stay position at filing.

Sales tax fraud cases carry arrest powers under section 37A of the Sales Tax Act 1990, and the Income Tax Ordinance 2001 has its own chapter of prosecutable offences. We defend the criminal track alongside the assessment track, and where the demand itself is without jurisdiction we take it to the High Court under Article 199, planning around the six-month lapse of revenue stays under Article 199(4A).

Representative Matters

  • 20—Acted for a listed company on SECP inquiries concerning related-party disclosures.Regulatory
  • 20—Acted for a corporate group in parallel FBR and FIA proceedings arising from the same transaction set.White-Collar
  • 20—Appeared for a regulator's licensee in appellate proceedings before the — High Court.Regulatory
All Representative Matters

Illustrative of the practice; matters anonymized consistent with confidentiality obligations.

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