The agencies: NAB, FIA, FBR, SECP, and the provincial ACEs

Every white-collar matter in Pakistan begins with the same question: which agency is this? The answer decides the statute that applies, the court that will hear the case, whether bail is governed by the ordinary criminal law or a special regime, and how long custody can last. Two notices that look alike can lead to very different years.

This chapter maps the five bodies a director or general counsel is most likely to meet. It states the position as of April 2026. The accountability laws have been amended repeatedly in recent years, and points that are still moving are bracketed for verification.

The National Accountability Bureau

NAB is the federal accountability agency. It operates under the National Accountability Ordinance 1999, has a Chairman at its head, and works through regional bureaus. Its core subject is corruption and corrupt practices by holders of public office. Private individuals and companies come within its reach when they are alleged to have connived in, or benefited from, such practices.

A NAB matter moves through defined stages: complaint verification, then inquiry, then investigation, then — if the Chairman authorises it — a reference filed before an accountability court. At the inquiry and investigation stages the Bureau issues call-up notices under section 19 of the Ordinance, requiring a person to appear or to produce records. A call-up notice does not by itself make the recipient an accused. It does mean the Bureau has a file.

The Ordinance was amended substantially in 2022. Among other changes, the amendments narrowed NAB's jurisdiction, including a pecuniary threshold of Rs 500 million [THRESHOLD AND ITS CURRENT STATUS TO BE VERIFIED BY REVIEWING LAWYER]. The Supreme Court struck down parts of those amendments in 2023 and then restored them on intra-court appeal in 2024. As of April 2026 the amended Ordinance is treated as the operative law, and many smaller matters have been transferred to the FIA and the provincial establishments [TO BE VERIFIED BY REVIEWING LAWYER].

NAB can arrest during an investigation. The permissible period of physical remand — custody with the Bureau rather than in prison — has been changed more than once by amendment and must be confirmed against the current text [CURRENT NAB REMAND PERIOD TO BE VERIFIED BY REVIEWING LAWYER]. Trials are held before accountability courts, which are special criminal courts. Bail under this regime has its own history, covered in chapter 3.

The Federal Investigation Agency

The FIA is a federal investigative agency constituted under the Federal Investigation Agency Act 1974. It investigates the offences listed in the schedule to that Act. For a business, the relevant files usually sit with its corporate crime, commercial banking and anti-corruption wings.

The statutes that matter most: the Anti-Money Laundering Act 2010; the Foreign Exchange Regulation Act 1947; the Offences in Respect of Banks (Special Courts) Ordinance 1984; and the Prevention of Corruption Act 1947 as it applies to federal public servants. Cybercrime under the Prevention of Electronic Crimes Act 2016 was moved from the FIA to the National Cyber Crime Investigation Agency, created in 2024 [ALLOCATION OF PENDING PECA MATTERS TO BE VERIFIED BY REVIEWING LAWYER].

The FIA's defining feature is that it works under the ordinary Code of Criminal Procedure 1898. It conducts enquiries, registers FIRs, investigates, and files a challan before the ordinary or special court concerned. Notices to appear are typically issued under section 160 of the Code. Because the CrPC applies, the ordinary law of arrest, remand and bail applies too. That makes an FIA matter procedurally more familiar than a NAB matter, though not gentler.

The Federal Board of Revenue

The FBR administers the federal tax laws through two wings: Inland Revenue, which handles income tax, sales tax and federal excise, and Customs. Most engagement with the FBR is civil: audit notices, show-cause notices, assessments, and appeals through the Commissioner (Appeals) and the Appellate Tribunal.

The criminal edge sits behind that. The Income Tax Ordinance 2001 contains prosecution offences. The Sales Tax Act 1990 defines tax fraud and gives officers a power of arrest, subject to internal approvals that have been revised in recent Finance Acts [CURRENT ARREST SAFEGUARDS TO BE VERIFIED BY REVIEWING LAWYER]. The Directorates General of Intelligence and Investigation run the cases with a criminal complexion. The working discipline is simple: treat every information notice under section 176 and every audit under section 177 of the Income Tax Ordinance as a document that may one day sit in a prosecution file, and answer it accordingly.

The Securities and Exchange Commission of Pakistan

The SECP is the corporate and capital-markets regulator, constituted under the Securities and Exchange Commission of Pakistan Act 1997. It administers the Companies Act 2017, the Securities Act 2015 and the regulated-sector laws for non-banking finance companies, insurance and modarabas.

Its usual instruments are administrative: inspection of books, investigation into a company's affairs under the Companies Act, show-cause notices, monetary penalties, and orders against directors and officers. It also has a criminal side. Insider trading and market manipulation are offences under the Securities Act 2015, and the Commission can refer matters to the FIA or NAB where the conduct crosses into their fields. A statement given to the SECP in an inspection can resurface in a criminal file years later. It should be prepared with that in mind.

The provincial anti-corruption establishments

Each province maintains an Anti-Corruption Establishment. Their legal foundations are older and vary by province — in Punjab the framework descends from the 1961 anti-corruption ordinance and its rules; Sindh, Khyber Pakhtunkhwa and Balochistan have their own instruments [PROVINCIAL LEGAL BASES TO BE VERIFIED BY REVIEWING LAWYER].

The ACEs investigate corruption by provincial public servants, chiefly under the Prevention of Corruption Act 1947 and the related provisions of the Pakistan Penal Code. A private company enters the frame as the alleged giver of a bribe or as an abettor. Procedure follows the CrPC: FIR, investigation, challan, trial before a special judge (anti-corruption). Since the 2022 narrowing of NAB's jurisdiction, the ACEs' caseloads have grown, and matters once handled federally now arrive at the provincial level.

Where the agencies overlap

The same facts can support several files. A procurement dispute can be a NAB reference, an FIA money-laundering case, an FBR tax-fraud prosecution and an SECP disclosure inquiry at once. The Anti-Money Laundering Act 2010 accelerates this: many offences are predicate offences for money laundering, and the Financial Monitoring Unit circulates suspicious-transaction reports to whichever agency has jurisdiction. Parallel proceedings on the same facts are common and, within limits, lawful — the constitutional protection in Article 13 is against double punishment and compelled self-incrimination, not against parallel investigation [SCOPE TO BE VERIFIED BY REVIEWING LAWYER].

So the first task in any matter is a map: every agency that could take an interest, every statute in play, every person exposed. Answering one agency without mapping the rest is how a manageable file becomes three.

What to take from this chapter

Identify the agency and the statute before anyone answers anything. The agency determines the procedure; the procedure determines custody, bail and the court; those determine the next two years. The following chapter deals with the first 48 hours after the knock comes.