Analysis
The Law Firm Wall Street Influence Can’t Escape: How Sullivan & Cromwell Wrote the Rules of Modern Finance
Corporate law influence rarely announces itself. It arrives in footnotes, closing conditions, and regulatory comment letters written in careful, deliberate prose.
There is a building at 125 Broad Street in Lower Manhattan that most New Yorkers walk past without a second glance. It is handsome, institutional, unsentimental—the kind of architecture that suggests permanence rather than power. Inside, Sullivan & Cromwell LLP has, for nearly a century and a half, quietly drafted the legal frameworks that govern how capital moves, how corporations die and are reborn, and how governments decide which financial risks are tolerable and which are not. To understand the law firm Wall Street influence depends upon most, you must begin here. And you must begin with the uncomfortable truth that the legal architecture of finance was not designed by legislators or central bankers—it was designed, to a remarkable degree, by lawyers billing by the hour.
Sullivan & Cromwell was founded in 1879 by Algernon Sullivan and William Nelson Cromwell, at a moment when American capitalism was shedding its agrarian skin and growing something altogether harder. Cromwell, in particular, arrived as a legal mercenary of unusual audacity. He restructured the Erie Railroad’s debt, saved the Northern Pacific from receivership, and—most consequentially—lobbied the United States Congress to abandon the Nicaragua route for an inter-oceanic canal, steering the project toward Panama. A 1977 Foreign Affairs essay on American empire in Latin America noted that Cromwell’s role in securing Panama’s secession from Colombia in 1903 remained, at the time of writing, one of the least-examined legal interventions in diplomatic history. The fees his firm collected from the French canal company exceeded $800,000—equivalent to roughly $28 million today—making it, at the time, one of the largest legal payouts in American history.
The Cravath System Is Famous. The Sullivan System Is More Powerful.
Legal historians tend to celebrate the “Cravath System”—the pyramid model of associate recruitment, training, and partnership that Paul Cravath formalized in the early twentieth century—as the defining organizational innovation of elite American law. Harvard Law Review has examined this model extensively, tracing how it professionalized corporate legal practice and concentrated talent in a small number of New York firms. But while Cravath systematized the firm, Sullivan & Cromwell systematized something subtler and more durable: the relationship between the law firm and its clients that persists across regulatory epochs, market cycles, and even national borders.
John Foster Dulles, who served as the firm’s senior partner from the 1920s through 1949, exemplifies this dynamic with almost uncomfortable clarity. Dulles represented German industrial conglomerates before and after the First World War, advised on the reparations framework created by the Treaty of Versailles, and then—as Secretary of State under Eisenhower—shaped the Cold War foreign policy environment in which his former clients operated. The revolving door between Sullivan & Cromwell and the American foreign policy establishment is not a metaphor. It is, in many cases, a documented biographical fact.
“The most powerful legal institution in the world is not the Supreme Court. It is the law firm that advises the institution the Supreme Court is asked to review.”
This is not a sentence any senior partner at Sullivan & Cromwell would utter in public. It represents a judgment that serious scholars of institutional power—including Luigi Zingales at the University of Chicago Booth School of Business, whose work on financial sector capture merits wider attention among policy audiences—have approached from different angles and reached, in softer language, similar conclusions.
Structuring the Crisis: From Glass-Steagall to the Derivatives Revolution
The firm’s most consequential modern chapters are written not in the language of empire but in the language of financial engineering. When Glass-Steagall began its slow political death in the 1980s and 1990s—the Gramm-Leach-Bliley Act finally repealed its core provisions in 1999—Sullivan & Cromwell’s attorneys were central to advising the banks and financial conglomerates that stood to gain. The firm represented Travelers Group in its 1998 merger with Citicorp, a transaction that was technically illegal under then-existing law but predicated on the—correct—assumption that the law would change before the Federal Reserve’s regulatory grace period expired. It did.
This is not illegal. It is not even unusual. But it describes something worth naming clearly: elite law firms do not simply interpret the law. They help to determine which laws will exist, when they will be enforced, and how their language will be structured so as to favor—or at least not disfavor—the clients who pay to have them written. The Financial Crisis Inquiry Commission, in its 2011 report, stopped short of indicting any specific law firm for the legal structures that enabled the 2008 collapse. But its index contains the names of firms, transactions, and regulatory opinions that reward careful reading.
The Derivatives Question No One Wanted to Ask
Brooksley Born, as chair of the Commodity Futures Trading Commission in the late 1990s, attempted to regulate over-the-counter derivatives before they metastasized into the instruments that nearly destroyed the global financial system. She was overruled—by the Treasury, the Fed, and the SEC—after a sustained campaign by financial institutions and their legal counsel arguing that regulation would “disrupt” an efficient market. The legal memoranda supporting that position were not written by legislators. They were written by the Wall Street law firms whose clients stood to lose billions in compliance costs and margin requirements. As the Washington Post documented in a 2009 investigation, the legal and lobbying apparatus arrayed against Born’s proposal represented one of the most coordinated exercises of private legal influence over public policy in the post-war period.
Sullivan & Cromwell was not alone in this landscape. Davis Polk, Skadden Arps, Simpson Thacher—the roster of firms that shaped the legal architecture of finance is longer than any single profile can contain. But Sullivan & Cromwell has a particular claim to primacy: it has advised Goldman Sachs on virtually every significant transaction and regulatory matter since the 1970s, a relationship that grants it an almost unparalleled window into the mechanics of how markets are made and, occasionally, gamed.
“Sullivan & Cromwell does not merely advise Goldman Sachs. In any meaningful structural sense, Sullivan & Cromwell helped to invent Goldman Sachs as a public company.”
That is less hyperbole than it sounds. The firm managed Goldman’s 1999 IPO, one of the most closely watched offerings of the dot-com era, structuring a partnership-to-corporation transition that preserved the firm’s culture while accessing public capital markets. The legal documents that governed that transaction—the partnership agreement modifications, the governance frameworks, the lockup structures—were instruments of institutional design as much as legal compliance.
The International Dimension: Exporting the Legal Architecture of American Finance
Sullivan & Cromwell’s reach is not confined to lower Manhattan or Washington regulatory corridors. The firm has served as lead counsel on sovereign debt restructurings, cross-border mergers, and privatization transactions across Latin America, Europe, and Asia. When Argentina restructured its debt in the aftermath of its 2001 default—the largest sovereign default in history at the time—American law firms, applying New York law principles to Argentine obligations, played a decisive role in determining which creditors recovered what, and on what timeline.
This is the often-overlooked international dimension of elite law firm influence: the fact that New York law governs a disproportionate share of global financial contracts means that New York law firms effectively set the terms of financial relationships between parties who may never set foot in the United States. The International Monetary Fund has noted in successive reports on sovereign debt restructuring that the reliance on New York-law documentation in international bond markets creates systemic asymmetries—between creditors and debtors, between sophisticated institutional investors and sovereign governments with limited legal resources—that have profound implications for financial stability.
A London Footnote That Illuminates the Architecture
The 2012 restructuring of Greek sovereign debt offers a revealing case study. The so-called Private Sector Involvement (PSI), which imposed haircuts on private creditors, was structured under English and New York law with heavy involvement from the major Anglo-American law firms. The legal engineering required to activate collective action clauses, manage holdout creditors, and satisfy the requirements of multiple legal systems simultaneously was, in effect, a demonstration of legal architecture at global scale. The creditors who recovered most were those whose bonds had been issued under legal frameworks that their lawyers had helped design.
The FTX Reckoning: When the Architecture Failed
No treatment of elite law firm influence is complete without confronting its limits. The collapse of FTX in November 2022 revealed something that the legal community found uncomfortable: that the most sophisticated legal structures are no protection against outright fraud. Sullivan & Cromwell had represented FTX as outside counsel and then, controversially, was appointed as lead restructuring counsel following the firm’s bankruptcy—a dual role that drew sustained criticism from the bankruptcy trustee and members of the U.S. Senate Judiciary Committee who questioned whether the firm’s prior relationship created irreconcilable conflicts of interest.
The firm denied any impropriety. But the episode illustrated something important: the legal architecture of finance is only as robust as the honesty of the people operating within it. And it raised a question that the profession has not yet satisfactorily answered—when a law firm’s institutional interests become entwined with its clients’ interests over decades of exclusive representation, who watches the watchmen?
Conclusion: Power Without Accountability, and the Reckoning Still Pending
Sullivan & Cromwell will not appear in most histories of Wall Street. Its name does not trend on financial media platforms. Its senior partners do not write memoirs or give TED talks. This opacity is, in a meaningful sense, the firm’s most powerful product: the ability to shape outcomes without ever becoming the visible agent of change.
I find this troubling—not because legal expertise is illegitimate, but because the concentration of that expertise in a handful of firms representing a handful of institutions creates something that does not appear in any regulatory framework: a private legal infrastructure that operates at global scale with minimal public accountability. The Administrative Conference of the United States has examined revolving-door dynamics in regulatory agencies; it has examined notice-and-comment rulemaking. It has not, to my knowledge, examined the systematic influence of relationship-based legal counsel on the shape of financial regulation.
That examination is overdue. As artificial intelligence reshapes the economics of legal services, as regulatory fragmentation accelerates across jurisdictions, and as financial crises continue to expose the gap between the law as written and the law as practiced by the people who draft it, the question of who designs the legal architecture of finance—and in whose interest—is no longer academic. It is the central governance question of the next century of global capitalism. Sullivan & Cromwell, and the small cohort of firms that sit beside it at the apex of the corporate legal hierarchy, have been answering that question, quietly, for 145 years. The rest of us are only just beginning to notice.
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Analysis
Five PSX Stocks Worth Owning Before the Second Quarter Ends
Pakistan’s stock market doesn’t do anything quietly. In January 2026, the KSE-100 Index scaled an all-time high of 189,556 points — a figure that would have seemed hallucinatory to anyone watching the exchange crater in the summer of 2023. By early May, Operation Sindoor had knocked the index below 104,000, triggering circuit breakers and a one-hour trading halt as panic selling swept through commercial banks, cement, and energy counters alike. The recovery has been partial and fragile. Yet the volatility, for investors with conviction and a horizon measured in quarters rather than days, has done something useful: it’s separated price from value on a clutch of names that were, frankly, overdue for a reset.
With the second quarter of 2026 drawing to a close on June 30, these five stocks on the Pakistan Stock Exchange represent the clearest alignment of macro tailwinds, sectoral fundamentals, and current-price opportunity.
The five PSX stocks best positioned before June 30, 2026 are MCB Bank (shorter bond duration, highest sector dividend), Meezan Bank (Islamic banking structural growth), Lucky Cement (diversified industrial conglomerate), OGDC (oil production at six-and-a-half-year highs), and Fauji Fertilizer (dominant urea pricing power). Each offers a company-specific investment case resilient to the current rate and geopolitical environment.
The Context: A Market That Has Been Through It
To understand where the best PSX stocks for Q2 2026 sit in the cycle, you need to understand what the market has absorbed in less than five months.
The State Bank of Pakistan surprised analysts on April 27, 2026 by raising its benchmark policy rate by 100 basis points to 11.5%, marking the first rate hike since June 2023. The decision came amid heightened economic uncertainty, volatile oil prices from Middle East tensions, and inflation climbing to 7.3% in March — breaching the central bank’s 5–7% target range for the first time since October 2024.
That’s a lot to absorb. An unexpected tightening cycle, a geopolitical shock severe enough to halt trading, and inflation re-accelerating — all in a single quarter. Yet even within this turbulence, the IMF approved a $1.2 billion tranche on May 8, 2026, providing a floor of institutional confidence beneath the chaos.
The picture is more complicated than the bearish headlines suggest. Corporate earnings, though uneven, remained broadly positive through the first quarter of calendar 2026. Pakistan’s banking sector collectively achieved profits of Rs. 671 billion in 2025 — a notable increase from Rs. 600 billion in 2024, even as the benchmark policy rate saw reduction during that year. The structural story of Pakistan’s economic recovery, backed by a three-year IMF Extended Fund Facility, hasn’t reversed. It’s been interrupted.
The Five Stocks: A Selective Case
The best PSX stocks to buy in Q2 2026 are not sector plays or index bets. Each of the five names below has a company-specific argument that would hold up even if the macro environment stayed difficult. In aggregate, they represent the clearest risk-reward in a market that has, in the space of a few months, oscillated between euphoria and panic.
1. MCB Bank (MCB)
MCB is the quiet achiever. It’s not Pakistan’s largest bank, it doesn’t carry the geopolitical weight of Habib Bank or the growth narrative of Meezan, and that restraint is precisely the point right now.
Banks such as MCB Bank are considered relatively better positioned to weather the current rising-yield environment, maintaining shorter-duration portfolios that limit their vulnerability to mark-to-market losses. Analysts expect these institutions to recover more quickly as market conditions stabilize. While United Bank Limited is seen as the most exposed of the major lenders to yield duration risk, with an estimated post-tax hit of Rs. 117 billion to its book value, MCB’s shorter book shields it from the worst of that balance-sheet pressure.
MCB Bank offered the highest dividend in the banking industry at Rs. 36 per share in 2025, with an EPS of Rs. 45.73. For investors who want banking sector exposure without carrying UBL’s interest-rate duration, MCB is the structurally safer entry.
2. Meezan Bank (MEBL)
Meezan Bank is not really a bank play. It’s a demographic play disguised as a bank.
Pakistan’s Islamic finance sector is growing faster than the conventional system, driven by the same ideological and regulatory momentum that has transformed Malaysian and Indonesian markets over two decades. Meezan holds an unassailable structural position as Pakistan’s largest dedicated Islamic bank, and no conventional competitor can credibly replicate its Shariah compliance at scale.
Meezan Bank’s market capitalization stood at Rs. 870.71 billion as of May 12, 2026 — an increase of 78.62% in one year. Even after the geopolitical correction, the structural bull case hasn’t moved. Seven analysts unanimously rate the stock a Strong Buy, with an average 12-month price target of Rs. 577 — implying upside of over 16% from the mid-April price of Rs. 497.
The earnings execution has been precise. MEBL reported quarterly earnings of Rs. 12.10 per share against a consensus estimate of Rs. 12.09 — a number that signals a management team in full control of its cost and revenue levers. This isn’t a story about a rate cycle. It’s a story about irreversible market share in a product vertical that’s growing structurally.
3. Lucky Cement (LUCK)
Call it a cement company if you must, but you’d be underselling it.
Lucky Cement, through its parent and subsidiary network spanning polyester, soda ash, pharmaceuticals, chemicals, automobiles, and power generation, has assembled the most diversified industrial book on the KSE-100. That diversification is now providing real earnings resilience. Lucky Cement’s Q3 net income came in at Rs. 22.62 billion, up from Rs. 21.99 billion in Q2 — a business delivering sequential quarterly growth even as the broader index swung wildly around it.
The cement sector was the second-largest positive contributor to the KSE-100’s April 2026 recovery, adding 1,735 points to the index, with LUCK among the leading individual contributors at 768 points. When the market’s recovery was at its most selective — favouring fundamentals over momentum — cement and LUCK led the way.
Pakistan’s infrastructure ambitions, regardless of which government is in office, require cement. And Lucky’s ability to cross-subsidise its cyclical core with chemicals, automotive, and power revenues makes it structurally more valuable than a price-to-book valuation of the cement segment alone would suggest.
4. Oil and Gas Development Company (OGDC)
OGDC is the government’s most important listed asset and, at current prices, arguably its most overlooked one.
OGDC’s oil production crossed 40,000 barrels per day — its highest level in more than six and a half years — suggesting improving operational momentum despite receivable and curtailment challenges. That’s a material operational milestone, and one that tends to precede upward earnings revisions.
Analysts have adjusted price targets for OGDC to reflect updated expectations for revenue growth of 16.42% and a profit margin of 40.80%, with a future P/E of 12.84x — indicating a modestly stronger earnings profile being incorporated into their models. At a forward earnings multiple well below regional peers and with production volume trending upward, the downside is limited and the recovery trade is straightforward.
The circular debt overhang — historically OGDC’s most persistent structural discount — is actively improving. Cash recoveries now exceed billings, power-sector receivables have declined sharply, and the remaining backlog is expected to clear within the quarter, with gas expected to regain prominence in the production mix as new fields come online.
5. Fauji Fertilizer Company (FFC)
The final pick is the one most directly tied to what Pakistan is — an agrarian economy where the state of the harvest matters more to most households than the price of a US Treasury bond.
FFC holds the dominant market position in urea, the fertilizer that underpins Pakistan’s wheat and rice output. When the government needs to support agricultural productivity — and it always does — FFC is the conduit. That political economy backing is a structural moat most international investors consistently underprice.
The fertilizer sector was the fourth-largest positive contributor to the KSE-100 in April 2026, adding 987 points to the index. Fauji Fertilizer’s extraordinary earnings growth in the prior fiscal year — driven by fertilizer price increases and product diversification into urea, DAP, power, and food segments — has given the company a dominant market position that makes it a standout performer in its sector.
With inflation creating pressure on input costs across the agricultural chain, the farmers who need FFC’s urea have limited alternatives. Pricing power combined with volume certainty is a rare combination on the KSE-100.
The Analytical Layer: What the Rate Hike Changes, and What It Doesn’t
How Will the SBP Rate Hike Affect PSX Stocks in Q2 2026?
The April 27 rate hike to 11.5% is contractionary, but its equity market consequences are asymmetric. Banks with long-duration bond portfolios face mark-to-market pressure; banks with shorter books, like MCB and Meezan, face less. Companies with strong pricing power, like FFC, can pass cost increases through to consumers. Capital-intensive industrials with clean balance sheets, like LUCK and OGDC, are less sensitive to the risk-free rate than leveraged players. The five stocks selected here are precisely the names that the rate environment discriminates in favour of, not against.
The deeper structural question is whether the rate hike marks the beginning of a prolonged tightening cycle or a one-off response to a supply shock. The SBP’s Monetary Policy Committee assessed that the current supply shock may push inflation to double digits in coming months before it begins to ease, but inflation is expected to stay above the upper bound of the target range for most of FY27. That’s hawkish language, but it’s language tied to a supply-side shock — Middle East energy volatility, rupee pressure, monsoon uncertainty — rather than a structurally overheating economy. Once the supply shock fades, the easing cycle resumes. Investors who hold through the noise capture the full re-rating.
Implications and Second-Order Effects
The geopolitical volatility of May 2026 has done something that years of steady gains cannot: it has created entry points in some of Pakistan’s best-managed companies at prices that reflect fear rather than fundamentals.
AKD Research projects the KSE-100 to reach 263,800 points by December 2026, driven by anticipated monetary easing, a stronger external account, and sustained structural reforms. The brokerage expects the rally to be fuelled by higher returns on equity in banking, better profitability in E&P and OMC firms, and a strong fertilizer sector performance. Even the most conservative broker models see a meaningful floor well above current levels.
The IMF’s continued engagement is the key stabilizer. As long as Islamabad remains compliant with its Extended Fund Facility conditionalities — and the May 8 tranche approval signals it is — the macro floor holds. Forex reserves, which once threatened to fall to catastrophic lows, are now on a rebuilding trajectory.
What the volatility has done, perversely, is compress valuations on fundamentally sound names. A forward P/E of approximately 6.8x for the KSE-100 — against a historical average of 8x — is not a market pricing in deterioration. It’s a market pricing in fear. The difference matters to investors with a three-to-six-month horizon.
The Counterargument: Why This Might Not Work
Steel-manning the bear case is not an optional exercise on the PSX in May 2026. It’s essential.
The most credible risk to this thesis isn’t geopolitical noise — it’s fiscal slippage. The IMF noted that Federal Board of Revenue tax collections slowed considerably to 10.2% year-on-year during July–November FY26, implying significant acceleration required to achieve the budgeted tax collection target in the remaining months of the fiscal year. If revenue collection misses materially, the government faces a binary choice: cut spending aggressively in an election-sensitive environment, or risk programme derailment.
The yield shock has also left real scar tissue. The banking sector’s gross revaluation losses are estimated at Rs. 685 billion, with a net impact of approximately Rs. 95 billion across major institutions after adjusting for existing surpluses. This constrains the sector’s capacity to grow lending precisely when economic recovery should be generating credit demand.
And there’s the India-Pakistan dimension. The ceasefire that followed Operation Sindoor has, historically, proved durable. Both countries have strong incentives to de-escalate. But “historically” is not a guarantee, and a second shock event in the same quarter would test the thesis hard.
The counterargument is real. It doesn’t, however, change the specific company cases for MCB, Meezan, LUCK, OGDC, and FFC. All five have balance sheets capable of weathering an extended macro storm. The question is one of patience, not conviction.
Closing
Pakistan’s equity market is not for the faint of heart. Never has been. What it offers, repeatedly and to those willing to hold through the storms, is the chance to buy genuinely good businesses at prices that discount the risk rather than the reality.
The KSE-100’s journey from 40,000 points in mid-2023 to nearly 190,000 at its January 2026 peak was not accidental. It reflected a real improvement in Pakistan’s macro fundamentals — a collapsing inflation rate, IMF stabilization, recovering forex reserves, and a corporate earnings boom. That improvement hasn’t evaporated; it’s been temporarily obscured by a rate hike, a geopolitical shock, and the ordinary noise of a market that moves fast in both directions.
MCB Bank’s balance sheet discipline, Meezan’s structural growth story, Lucky Cement’s diversified industrial logic, OGDC’s production recovery, and Fauji’s pricing power represent the sharpest set of fundamental arguments available on the PSX heading into June 30. They’re not risk-free. Nothing in frontier markets ever is.
But in a market that has consistently rewarded conviction over caution, these five names make the case for both.
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Analysis
The Race to the Regulators: Why AI Pre-Deployment Testing Has Arrived
For most of the past two years, the dominant assumption in Washington’s corridors was that the Trump administration would keep its hands off frontier AI. The January 2025 revocation of Biden’s executive order on AI risk seemed to cement that posture. So when the U.S. Department of Commerce’s Center for AI Standards and Innovation announced on May 5, 2026 that it had signed formal agreements with Google DeepMind, Microsoft, and Elon Musk’s xAI — granting federal evaluators access to unreleased AI models — the pivot was sharper than most observers had anticipated.
The catalyst was not abstract policy debate. It was a model.
When security researchers at Mozilla pointed Anthropic’s new Mythos system at their code, the experience produced something close to vertigo. Bobby Holley, Firefox’s chief technology officer, said Mythos had elevated AI from a competent software engineer to something resembling a world-class, elite security researcher. That description — and its implications for every unpatched vulnerability in every network connected to the internet — lit a fire under the White House that no deregulatory talking point could easily extinguish. The Washington Post
The new AI pre-deployment testing agreements are Washington’s answer. They are voluntary, technically non-binding, and carefully constructed to avoid the language of mandates. They are also, in their quiet way, a structural reckoning with just how consequential the next generation of AI models may be.
What the CAISI Agreements Actually Do
The Center for AI Standards and Innovation announced agreements with Google DeepMind, Microsoft, and Elon Musk’s xAI that will allow the U.S. government to evaluate artificial intelligence models before they are publicly available. CAISI will conduct pre-deployment evaluations and targeted research. The announcement builds on earlier partnerships struck with OpenAI and Anthropic in 2024, which were the first of their kind. CNBC
The scope is broader than a checkbox exercise. CAISI has completed more than 40 evaluations to date, including assessments involving unreleased AI models. Developers frequently provide models with reduced or removed safeguards to support evaluations focused on national security-related capabilities and risks. The agreements also support testing in classified environments and enable participation from evaluators across government agencies through the TRAINS Taskforce, a group of interagency experts focused on AI-related national security issues. Executive Gov
That last point matters. A model tested with its guardrails intact tells evaluators relatively little about what it’s genuinely capable of doing. By examining systems in their more uninhibited state, CAISI can probe for the kinds of capabilities — automated cyberattack sequencing, biochemical synthesis guidance, manipulation of critical infrastructure — that frontier labs are increasingly warning about in their own internal research.
CAISI’s evaluations focus on demonstrable risks, such as cybersecurity, biosecurity, and chemical weapons. These aren’t theoretical threat categories. They are the precise domains in which advanced reasoning models have begun to demonstrate capabilities that, even in controlled settings, have prompted unusual candour from the labs building them. National Institute of Standards and Technology
Prior to evaluating U.S.-based AI models, CAISI recently examined the Chinese model DeepSeek, concluding it underperformed in several areas including accuracy, security and cost efficiency. That context is not incidental. Part of what’s driving Washington’s urgency is the competitive dimension — the fear that adversaries may be racing toward capabilities that American agencies don’t fully understand, even in their own country’s frontier models. Nextgov.com
CAISI Director Chris Fall has framed the institutional mission with deliberate precision. “Independent, rigorous measurement science is essential to understanding frontier AI and its national security implications,” Fall said. “These expanded industry collaborations help us scale our work in the public interest at a critical moment.” Federal News Network
What Does CAISI’s AI Pre-Deployment Testing Actually Involve?
CAISI conducts pre-release evaluations of frontier AI models by accessing versions with reduced or removed safety filters, testing in classified environments, and deploying an interagency task force — the TRAINS Taskforce — across government agencies. Evaluations focus on cybersecurity, biosecurity, and chemical weapons risks. The center has completed over 40 such assessments to date.
That question has real commercial stakes attached to it. NIST said the partnerships would help the agency and the tech companies exchange information, spur voluntary product improvements, and ensure the government had a clear understanding of what AI models were capable of doing. For the companies involved, this framing is tolerable — even attractive. A pre-release government endorsement, implicit or explicit, is worth something in enterprise procurement conversations. It’s harder to challenge a model that CAISI has already looked at. Cybersecurity Dive
Yet the capacity problem is glaring. CSET Senior Research Analyst Jessica Ji noted that government agencies simply don’t have the same amount of resources as big tech companies — either the manpower, technical staff, or access to compute — to run rigorous evaluations of these models. CAISI is a relatively lean organisation operating against labs that employ thousands of the world’s most skilled AI researchers. The asymmetry between evaluator and evaluated has no obvious near-term solution. CSET
The FDA Analogy — and Why It’s Both Tempting and Dangerous
The policy frame that has seized Washington’s imagination is, perhaps inevitably, the Food and Drug Administration. National Economic Council Director Kevin Hassett told Fox Business that the administration is studying a possible executive order to give a clear roadmap for how future AI models that create vulnerabilities should go through a process so that they’re released into the wild after they’ve been proven safe, just like an FDA drug. Bloomberg
The analogy is rhetorically clean. It is also, on closer inspection, strained in ways that matter for how any eventual mandatory regime would function in practice.
Drug approval is predicated on a relatively bounded hypothesis: does this compound do what it claims, without causing specified harms? The FDA’s clinical trial infrastructure, built over decades, evaluates outcomes in controlled populations against defined endpoints. Frontier AI models behave differently. Their capabilities emerge non-linearly from scale, training data, and interaction patterns that no pre-deployment test suite can exhaustively simulate. A model that passes a red-teaming exercise on Tuesday may discover a novel attack vector in production by Thursday.
CAISI conducts post-deployment evaluations to track risks that emerge after launch, since AI systems often behave differently under real-world conditions — including adversarial inputs and dataset drift — than they do in controlled testing environments. This acknowledgment, buried in the operational details of how CAISI works, quietly concedes what the FDA analogy papers over: there is no clean approval moment. Safety is a continuous process, not a gate. Arnav
Still, the political logic of the FDA frame is sound. It gives the administration a vocabulary for oversight that doesn’t require it to announce a regulatory regime. “Proven safe before release” is a message that plays well. The implementation will be considerably messier.
A bipartisan group of 32 House lawmakers has written to National Cyber Director Sean Cairncross urging immediate action to confront the high volume of cyber vulnerability disclosures cropping up from advanced AI systems. The letter marks an escalation in pressure on the Trump administration to confront the risks posed by frontier AI cyber models. That kind of bipartisan pressure — rare in contemporary Washington — signals that this issue has moved beyond the usual partisan channels. Axios
Second-Order Effects: Markets, Enterprise, and the Voluntary-to-Mandatory Gradient
The agreements announced on May 5 are voluntary. That status, however, may have a shorter shelf life than the companies involved are counting on.
National Economic Council Director Hassett said it’s “really quite likely” that any testing spelled out under an executive order would ultimately extend to all AI companies. “I think Mythos is the first of them, but it’s incumbent on us to build a system,” he said. When a White House economic adviser publicly floats universal applicability, the “voluntary” characterisation begins to function more as a transitional state than a permanent arrangement. Insurance Journal
For enterprise buyers, the near-term implications are more concrete. A CAISI evaluation — particularly one conducted in a classified environment, with results shared selectively across agencies — effectively creates an informal tier of government-vetted AI systems. The companies that have signed these agreements (Google DeepMind, Microsoft, xAI, OpenAI, and Anthropic) are, not coincidentally, the same companies that supply the overwhelming majority of frontier AI infrastructure to federal agencies. A new entrant — a well-capitalised European lab, or a fast-scaling domestic startup — that hasn’t been through the CAISI process faces an implicit disadvantage in federal procurement, regardless of whether any formal mandate exists.
The market signal is already visible. Following the announcement, Microsoft’s stock was down 0.6 percent in midday trading, while Alphabet, Google’s parent company, was trending in the opposite direction — up 1.3 percent. These are small moves, and reading too much into single-session trading is unwise. But the divergence may reflect a market reading of which company has the most to gain from tighter relationships with Washington’s AI oversight apparatus. Al Jazeera
The international dimension compounds the picture. The EU’s AI Act, which came into full force in August 2025, imposes mandatory conformity assessments on high-risk AI systems. The CAISI framework, built on voluntary agreements and classified evaluations, is a fundamentally different architecture — one shaped by American deregulatory instincts even as it begins to converge toward similar outcomes. The question of mutual recognition, or regulatory fragmentation, will land on the desks of trade negotiators before the decade is out.
The Counterargument: Testing Without Teeth?
Not everyone views the CAISI expansion as a meaningful check on frontier AI risk. Critics — some within the AI safety research community, others in civil liberties organisations — have raised a set of concerns that deserve a serious hearing rather than a dismissal.
The first is structural: evaluations conducted under voluntary agreements give the evaluated parties significant influence over what the evaluators can access, how results are framed, and whether findings lead to any material consequence. The new agreements allow CAISI to evaluate new AI models and their potential impact on national security and public safety ahead of their launch, and to conduct research and testing after AI models are deployed. What the agreements do not stipulate, publicly at least, is what happens when CAISI finds something troubling. The absence of a defined enforcement mechanism isn’t a technicality — it’s the central design question. CNN
The second concern is about scope creep in the opposite direction. The agreements build upon OpenAI and Anthropic’s agreements in 2024, which were the first of this kind. Each iteration has expanded the framework’s reach without a parallel expansion of CAISI’s evaluation capacity or legal authority. If the executive order now under consideration mandates testing without addressing the resource gap Jessica Ji identified, the process risks becoming a compliance ritual rather than a genuine safety check — something labs can credential-wash without fundamentally altering their deployment timelines. The Hill
Industry groups have been supportive: Business Software Alliance Senior Vice President Aaron Cooper said that CAISI brings the necessary expertise to work with private sector partners to evaluate frontier models for safety and national security risks, and called it the right institutional home within government. Industry enthusiasm for a regulatory body is not, historically, a reliable indicator of rigorous oversight. It can equally signal confidence that the oversight will remain manageable. Nextgov.com
A Framework in Formation
The agreements signed on May 5 are neither a regulatory revolution nor a fig leaf. They are something more interesting and more ambiguous than either characterisation allows.
Washington has moved from ignoring frontier AI risk to institutionalising a mechanism for examining it — in under eighteen months, and largely under the pressure of a single model’s demonstrated capabilities. That is, by the standards of government technology policy, fast. The CAISI framework exists, it has now absorbed five of the most significant frontier labs, and it has begun to develop the institutional muscle memory that eventually becomes precedent.
What it lacks is clarity on consequences. The voluntary-to-mandatory gradient that Hassett suggested — extending CAISI-style testing to all AI companies — would represent a genuine structural shift. Whether such an order arrives, and whether it comes with enforcement mechanisms or remains aspirational, will determine whether the May 5 announcements are remembered as a turning point or a photo opportunity.
The FDA comparison is imperfect. The analogy is imprecise. But the underlying instinct — that something this powerful, moving this fast, probably shouldn’t enter the world completely unexamined — is harder to argue with every week that passes.
The question now isn’t whether Washington will test frontier AI before it ships. It’s whether the testing, when it finds something, will actually matter.
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Analysis
The Price of Fiscal Concord: Inside Pakistan’s Rs500 Billion IMF-Sanctioned Tax Overhaul
Islamabad has concluded another round of grueling fiscal negotiations, securing an explicit nod from the International Monetary Fund for a sweeping suite of revenue-mobilization measures slated for the fiscal year 2026-27 budget. The agreement clears the path for the government to execute an aggressive tax enforcement strategy targeting between Rs 400 billion and Rs 500 billion in fresh revenue. Yet, the headline development is an unexpected retreat: the state is preparing to abandon the controversial Capital Value Tax on foreign assets held by resident citizens. In its stead, policymakers are wagering the country’s fiscal stability on an unprecedented digital containment strategy, aiming to force the vast, parallel undocumented economy into the formal net through real-time electronic monitoring and algorithmic surveillance.
The macroeconomic backdrop explaining this radical pivot is one of structural exhaustion. For decades, the state has relied on blunt, inflationary indirect levies to meet its fiscal targets while leaving politically sensitive sectors—such as wholesale distribution, retail trade, and large-scale agriculture—largely untouched. The strategy has reached its absolute ceiling. According to recent economic assessments from the World Bank Pakistan Overview, the country’s tax-to-GDP ratio has hovered at an unsustainable level of less than 10%, leaving the federal government trapped in a destructive loop of borrowing simply to service existing debt. The current structural adjustment program overseen by the IMF demands a permanent break from this ad-hoc policymaking. The state must find a way to generate durable, recurring revenue without triggering a total collapse in consumer demand or driving capital out of the country entirely.
+-----------------------------------------------------------------------+
| PAKISTAN FY2026-27 FISCAL REFORM FRAMEWORK |
+-----------------------------------------------------------------------+
| |
| [ REVENUE TARGET ] ------------------------> Rs 400-500 Billion |
| |
| [ CORE PILLARS ] |
| ├── 1. Technological Transition: Mandated Digital Invoicing |
| ├── 2. Base Broadening: Sales Tax Expansion & Loophole Closure |
| └── 3. Administrative Pivot: Rollback of Inefficient CVT |
| |
| [ DATA INTEGRATION ] |
| └── FBR Core Systems <---> NADRA / Utilities / Banking Records |
| |
+-----------------------------------------------------------------------+
The Core Development: Scrapping the CVT and Re-engineering Enforcement
At the absolute center of this policy shift is a structural admission of administrative failure. The decision to roll back the CVT on foreign assets highlights the friction between ambitious legislation and the reality of global asset tracking. Introduced during a previous fiscal panic, the tax was designed to levy a premium on the overseas wealth of wealthy residents, capturing revenue from real estate portfolios in the Gulf and offshore financial accounts in Europe.
That plan failed to work. The Federal Board of Revenue encountered severe legal resistance, prolonged litigation in provincial high courts, and complex double-taxation conflicts that made enforcement practically impossible. The administrative expenditure required to track, verify, and litigate foreign asset valuations far outweighed the actual revenue trickling into the national treasury.
To satisfy the fund’s rigid insistence on verifiable revenue streams, Islamabad had to present alternative, highly predictable options. The resulting strategy swaps out the external wealth tax for an intense internal enforcement mechanism. The core of this new approach relies on the deployment of nationwide digital invoicing Pakistan protocols alongside a sweeping sales tax expansion.
By abandoning the low-yield foreign asset tax, the government secured the lender’s endorsement for a plan focused squarely on domestic consumption tracking and supply-chain formalization. Public disclosures from the International Monetary Fund Country Reports indicate that the lender has accepted these domestic structural adjustments, provided the automated systems are fully operational across all retail and wholesale distributions before the start of the next fiscal cycle.
The financial targets are exceptionally ambitious. To extract an additional Rs 500 billion from an economy dealing with sluggish industrial growth, the FBR cannot rely on simple rate increases. Instead, the agency is preparing to dismantle a long list of sales tax exemptions, zero-rated protections, and subsidized tax regimes that have historically shielded politically connected manufacturing cartels.
The state’s updated ledger shows that nearly half of the projected revenue gains will come from removing these domestic market distortions. Still, the success of this strategy depends entirely on the technical capacity of the state’s tax collectors. Without a significant upgrade in enforcement technology, the policy risks turning into another unfulfilled legislative promise.
The Analytical Layer: Inside the Digital Enclosure of the Retail Frontier
The shift toward a technology-driven tax regime marks a fundamental change in how the state plans to exercise its fiscal authority. For decades, the country’s informal wholesale and retail sectors—estimated by independent economists to represent more than a third of total economic activity—have successfully resisted integration into the formal economy through street-level strikes, political lobbying, and sophisticated cash accounting systems. What follows, however, is an effort to make tax evasion physically and operationally impossible through structural market design.
What are the new IMF tax measures for FY2026-27?
The approved measures target Rs 400-500 billion in fresh revenue by mandating end-to-end digital invoicing across supply chains, eliminating widespread sales tax exemptions, and expanding consumption taxes. Crucially, the plan abandons the low-yield Capital Value Tax (CVT) on foreign assets in favor of data-driven domestic enforcement and automated auditing.
The operational core of these Pakistan IMF tax reforms relies on real-time data cross-matching. Rather than relying on the self-declarations of merchants, the tax collector is integrating its databases directly with external entities. The system will continuously pull and analyze data from commercial electricity grids, municipal property registries, third-party banking transactions, and vehicle registration offices.
If a retail establishment in Karachi’s affluent Clifton district or Lahore’s commercial hubs shows a monthly electricity consumption profile matching a high-volume enterprise while declaring nominal revenue on its tax returns, the system automatically flags the variance and issues an automated assessment order. This removes the human element of discretion, which has long been a major source of corruption within the tax administration.
This structural shift alters the political dynamic of tax collection. Historically, shopkeepers could easily shut down local markets to pressure the government into withdrawing tax initiatives. By moving enforcement to digital invoices and electronic clearings at the distributor and manufacturer levels, the state is shifting the compliance burden upstream. A wholesaler or distributor will no longer be permitted to ship goods to an unregistered retailer without incurring an automated fiscal penalty on their own tax ledger.
The strategy creates clear economic incentives for self-policing within the private sector: registered companies will find it too costly to do business with informal enterprises. The policy aims to isolate uncooperative cash businesses, cutting them off from formal supply lines until compliance becomes their only viable option for commercial survival.
Still, this approach assumes the state can successfully execute complex IT projects across its entire economy. The FBR has historically struggled with system downtime, data leaks, and resistance from its own rank-and-file staff, many of whom view automation as a direct threat to their institutional influence. The transition to automated tax enforcement systems requires significant upgrades to server infrastructure, data centers, and advanced predictive analytics models. The true test of this reform will not be found in policy documents signed in Washington, but in whether the government can maintain system uptime when millions of transactions hit its servers simultaneously during peak retail seasons.
Implications and Second-Order Effects on Domestic Markets
The downstream consequences of this tax overhaul will reshape the country’s broader commercial environment. For corporate enterprises that have long operated within the formal tax net, the elimination of sales tax exemptions represents a significant disruption to cash flow management. Industries like textiles, leather, and high-end agriculture, which previously benefited from specialized tax treatments, will see their operating margins squeezed as they adjust to the standard consumption tax rate. Companies will have to dedicate more working capital to cover upfront tax liabilities, a challenge amplified by domestic interest rates that remain highly restrictive.
The domestic retail market will likely experience a sharp bifurcation. Large, organized retail chains that are already integrated into electronic payment networks stand to gain market share. As the enforcement of digital invoicing eliminates the price advantages previously enjoyed by informal, tax-evading competitors, formal retail operators will compete on a more level playing field. Conversely, small and mid-sized traditional retailers face a difficult choice: absorb the costs of compliance and digital integration, or face aggressive administrative penalties, asset seizures, and potential business closures. This tension will likely accelerate consolidation across the consumer retail landscape, driving smaller players out of business while favoring well-capitalized, corporate retail groups.
The macroeconomic impact on consumer behavior will show up quickly in inflation data. While the state insists that expanding the sales tax base avoids increasing taxes on essential goods, the historical reality of Pakistan’s retail distribution networks suggests otherwise. When distributors encounter higher compliance costs and strict digital invoicing requirements, they rarely absorb those expenses. Instead, they pass them directly down the supply chain.
As a result, average consumers will likely face a fresh round of price increases for everyday household goods, clothing, and processed items. This pressure lands on a population that has already endured several years of severe stagflation. Academic studies from the PIDE Institutional Repository indicate that broad-based indirect taxes without effective social safety nets often reduce aggregate consumption, which could slow down the very industrial recovery the government is trying to foster.
+-----------------------------------------------------------------------+
| SUPPLY CHAIN TAX TRANSMISSION |
+-----------------------------------------------------------------------+
| |
| [ Tier-1 Manufacturer ] |
| │ |
| └── Removes tax exemptions; faces standard sales tax rate. |
| ▼ |
| [ Regional Distributor ] |
| │ |
| └── Mandated digital invoicing tracks every single movement. |
| ▼ |
| [ Unregistered Retailer ] |
| │ |
| └── Choice: Face automated penalties or formalize operations. |
| ▼ |
| [ End Consumer ] |
| |
| └── Absorbs higher prices passed down the supply chain. |
| |
+-----------------------------------------------------------------------+
The long-term success of these measures will ultimately determine the country’s access to international capital markets. If the government hits its FBR tax targets 2026 and establishes a stable, expanding tax base, it will signal to international credit rating agencies that Islamabad can manage its fiscal affairs without relying on continuous emergency interventions. This fiscal stabilization is essential for lowering sovereign risk premiums and allowing both the state and private corporations to borrow internationally at reasonable rates.
Yet, if the digital enforcement strategy falters, the country risks falling short of its revenue commitments mid-year. That outcome would force the government to introduce sudden, disruptive mini-budgets, damaging investor confidence and straining its relationship with international financial institutions.
Competing Perspectives: Efficiency vs. Equity in State Extraction
The decision to scrap the CVT on foreign assets while expanding domestic sales taxes has sparked an intense debate among local economists, policymakers, and civil society groups. Critics argue that the policy change represents a clear capitulation to the country’s wealthy elite. By removing a tax focused on luxury properties and overseas bank accounts while expanding consumption taxes on domestic goods, the state appears to be shifting the financial burden of structural adjustment onto middle- and lower-income citizens. This dynamic raises difficult questions about the social equity of a tax regime that struggles to audit affluent citizens’ overseas holdings but deploys advanced digital surveillance to track the transaction of every local retail shop.
+-----------------------------------------------------------------------+
| THE EQUITY VS. EFFICIENCY DEBATE |
+-----------------------------------------------------------------------+
| |
| [ FISCAL EFFICIENCY VALUE ] |
| "Abolish complex, uncollectible wealth taxes (CVT) that stall in |
| courts. Prioritize high-yield digital tracking of domestic sales." |
| |
| VS. |
| |
| [ SOCIAL EQUITY CRISIS ] |
| "Removes tax obligations from elite offshore assets while placing |
| the structural adjustment burden directly onto local consumers." |
| |
+-----------------------------------------------------------------------+
The state’s economic advisors defend the approach on purely pragmatic grounds. They point out that a tax that cannot be efficiently collected is not a policy; it is simply political theater. The CVT on foreign assets was structurally flawed from its inception, yielding little actual revenue while tying up valuable administrative resources in endless court battles.
In a volatile fiscal environment, prioritizing predictable revenue over symbolic wealth taxes is an act of basic economic necessity. From this perspective, implementing end-to-end digital invoicing and eliminating market distortions across major industries is a fairer way to build a sustainable tax system. The goal is to ensure that every commercial transaction within the country contributes to the national treasury, replacing a broken model that relies on over-taxing a small group of compliant corporate entities.
Furthermore, independent analysts note that the focus on digital tracking addresses a systemic problem that wealth taxes often miss: the massive amount of untaxed capital sloshing through the domestic undocumented economy. Wealthy individuals frequently shelter their profits not just in foreign assets, but within unregistered local real estate, informal commodity trading, and cash-based distribution businesses. By focusing enforcement on these local supply chains, the updated policy targets the core mechanics of domestic tax evasion. The long-term goal is to transform the country’s economic structure, forcing informal capital back into the formal financial system where it can be used for productive investment rather than remaining hidden from tax authorities.
The Path Forward
The fiscal policy trajectory for the upcoming year is now clearly established. By anchoring its revenue strategy to digital tracking and domestic consumption taxes, the government has chosen a path that prioritizes systemic efficiency over political symbolism. The removal of the CVT on foreign assets confirms that the state is stepping away from complex, unenforceable global wealth taxes. Instead, it is focusing its energy on building a comprehensive digital monitoring system within its own borders.
This strategy represents a major gamble on the state’s technical capacity and political will. Success requires the government to resist pressure from powerful merchant groups, maintain the integrity of its data infrastructure, and ensure that automated compliance systems operate without political interference. The central challenge for Islamabad is to prove that it can build a modern fiscal system capable of collecting revenue efficiently and equitably from its domestic economy. If these automated systems deliver on their revenue targets, the country may finally break its dependence on repetitive structural adjustment loans. If they fail, the state will face an even deeper fiscal crisis, proving that true economic stability cannot be achieved through technology alone.
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