PVARA Licensing & Regulatory Services
Navigate Pakistan's Virtual Assets Framework with Confidence
Complete PVARA license application management — from initial NOC to full regulatory approval. We handle all documentation, compliance frameworks, and regulatory coordination so you can focus on your business.
Why PVARA Compliance is Complex
Pakistan's regulatory framework presents unique challenges for foreign crypto companies
-
Extensive Documentation
Comprehensive application package including Form A1, Annex A, detailed business plans, tech specifications, and security protocols required by PVARA. Document volume varies by applicant.
-
AML/CFT Mandates
Strict anti-money laundering and counter-terrorism financing policies fully aligned with FATF standards — mandatory for all VASPs.
-
Multiple Regulators
Coordination required across PVARA, SECP, FMU, and SBP — each with different requirements, timelines, and submission formats.
-
Ongoing Obligations
Post-license compliance reporting, regulatory updates, and periodic renewal requirements — continuous commitment after approval.
Complete PVARA Licensing Support
Six integrated services that cover every aspect of regulatory compliance and licensing in Pakistan
-
PVARA Advisory & Strategy
Initial assessment, eligibility check, and licensing pathway recommendation tailored to your specific business model and operational requirements.
-
NOC Application & Facilitation
No Objection Certificate preparation using official Form A1 and Annex A documentation, submission, and follow-up with PVARA. We manage the entire NOC process end-to-end.
-
License Documentation
Complete application package including Form A1, Annex A, business plan, technology stack documentation, security protocols, and operational procedures tailored to your business model.
-
AML/CFT Policy Framework
Anti-money laundering and counter-terrorism financing policies fully compliant with FATF standards and Pakistan's regulatory requirements.
-
Compliance Infrastructure
KYC/KYB procedures, transaction monitoring systems, suspicious activity reporting protocols, and complete compliance operational setup. Note: AML-critical functions (CDD/EDD, sanctions screening, transaction monitoring, STR/CTR reporting, MLRO duties) cannot be outsourced unless strict oversight conditions are met.
-
Ongoing Regulatory Reporting
Periodic compliance reports, regulatory updates tracking, license renewal support, and continuous regulatory relationship management.
Your Path to PVARA License
A structured approach to navigate the licensing process efficiently
-
01
Initial Assessment
Business model review, eligibility analysis, gap identification
-
02
NOC Application
Submit Form A1 + Annex A to PVARA for No Objection Certificate
-
03
AML Registration
Register with FMU on goAML portal — mandatory before operations
-
04
SECP Incorporation
Local entity incorporation under Companies Act 2017 using NOC
-
05
AML-Registered Services
Operate Exchange, Custody, Broker-Dealer & Derivatives under NOC+AML
-
06
Full License & Launch
Apply for full VASP license when published, then expand operations
-
01
Initial Assessment
Business model review, eligibility analysis, gap identification
-
02
NOC Application
Submit Form A1 + Annex A to PVARA for No Objection Certificate
-
03
AML Registration
Register with FMU on goAML portal — mandatory before operations
-
04
SECP Incorporation
Local entity incorporation under Companies Act 2017 using NOC
-
05
AML-Registered Services
Operate Exchange, Custody, Broker-Dealer & Derivatives under NOC+AML
-
06
Full License & Launch
Apply for full VASP license when published, then expand operations
What You Get
Comprehensive deliverables and ongoing support throughout your licensing journey
Documents
- Complete PVARA application package
- AML/CFT Policy Manual
- KYC/KYB Procedures Document
- Risk Assessment Framework
- Compliance Officer Handbook
- Board Resolution Templates
- Controller Disclosure (Form A2) & Source of Wealth
Support
- Dedicated compliance consultant
- Regulatory liaison services
- Query response preparation
- License renewal reminders
- Regulatory update briefings
- Post-license compliance support
8 Mandatory Key Individuals
Every PVARA applicant must appoint these roles before applying, as mandated by the official NOC Regulations (Section 5.1)
-
Chief Executive Officer
Overall executive responsibility for VASP operations and regulatory compliance.
-
Director
Executive or non-executive director responsible for governance and strategic oversight.
-
Chief Financial Officer
Financial management, capital adequacy, and financial reporting compliance.
-
Compliance Officer
Day-to-day regulatory compliance and adherence to PVARA obligations.
-
Money Laundering Reporting Officer (MLRO)
Dedicated AML/CFT oversight and suspicious activity reporting to FMU.
-
Head of Internal Audit
Independent internal audit function for controls and regulatory adherence.
-
Head of Risk Management
Enterprise risk framework including operational, market, and regulatory risks.
-
Head of Information Security
Cybersecurity, data protection, and technology risk management.
Coordinating with Pakistan's Regulators
We navigate the multi-agency regulatory landscape on your behalf
-
SECP
Securities and Exchange Commission of Pakistan
Company registration and incorporation authority under Companies Act 2017. Coordination body for VASP corporate structure, not the primary licensor.
-
FMU
Financial Monitoring Unit
AML/CFT compliance oversight and suspicious transaction reporting authority — mandatory goAML portal registration for all VASPs.
-
SBP
State Bank of Pakistan
Banking relationships and payment system integration oversight for virtual asset service providers operating in Pakistan.
Frequently Asked Questions
How long does PVARA licensing take?
NOC decisions are targeted within 60 calendar days of complete submission. Full licensing regulations and timelines have not yet been published by PVARA. We help expedite by ensuring complete, accurate submissions from day one.
What are the controller disclosure requirements?
The NOC Regulations require disclosure of all Controllers (anyone with 20%+ voting power or share capital). Each controller requires a Form A2 submission with Source of Wealth and Source of Funds documentation. PVARA pre-approval is required before AML registration.
What are the capital requirements?
PVARA has not yet published full licensing regulations including capital requirements. These will be detailed in forthcoming regulations. We provide estimates based on comparable jurisdictions during consultation.
Do I need a local director for licensing?
PVARA requires at least one Key Individual (e.g., CEO, Director, or MLRO) to be ordinarily resident in Pakistan with operational decision-making authority. We can facilitate resident Key Individual placement if needed as part of our Corporate Setup services.
What ongoing compliance is required?
Licensed entities must submit periodic compliance reports, maintain updated AML/CFT policies, report suspicious transactions, and undergo regular audits. We provide ongoing compliance support to ensure you stay compliant at all times.
Can foreign companies apply directly?
Foreign companies must first obtain a PVARA NOC, which grants permission to incorporate a local entity under the Companies Act 2017. We handle the complete corporate setup process as part of our integrated services.
What happens if my application is rejected?
Rejections typically come with specific reasons. We help address deficiencies and resubmit. Our thorough preparation process significantly reduces rejection risk — we don't submit until the application is complete and fully compliant.
Ready to Get Licensed?
Start your PVARA journey with a free compliance assessment. We'll review your business model and provide a custom licensing roadmap.
Response within 24 hours
PVARA Licensing & Regulatory Services
Navigate Pakistan's Virtual Assets Framework with Confidence
Complete PVARA license application management — from initial NOC to full regulatory approval. We handle all documentation, compliance frameworks, and regulatory coordination so you can focus on your business.
Why PVARA Compliance is Complex
Pakistan's regulatory framework presents unique challenges for foreign crypto companies
-
Extensive Documentation
Comprehensive application package including Form A1, Annex A, detailed business plans, tech specifications, and security protocols required by PVARA. Document volume varies by applicant.
-
AML/CFT Mandates
Strict anti-money laundering and counter-terrorism financing policies fully aligned with FATF standards — mandatory for all VASPs.
-
Multiple Regulators
Coordination required across PVARA, SECP, FMU, and SBP — each with different requirements, timelines, and submission formats.
-
Ongoing Obligations
Post-license compliance reporting, regulatory updates, and periodic renewal requirements — continuous commitment after approval.
Complete PVARA Licensing Support
Six integrated services that cover every aspect of regulatory compliance and licensing in Pakistan
-
PVARA Advisory & Strategy
Initial assessment, eligibility check, and licensing pathway recommendation tailored to your specific business model and operational requirements.
-
NOC Application & Facilitation
No Objection Certificate preparation using official Form A1 and Annex A documentation, submission, and follow-up with PVARA. We manage the entire NOC process end-to-end.
-
License Documentation
Complete application package including Form A1, Annex A, business plan, technology stack documentation, security protocols, and operational procedures tailored to your business model.
-
AML/CFT Policy Framework
Anti-money laundering and counter-terrorism financing policies fully compliant with FATF standards and Pakistan's regulatory requirements.
-
Compliance Infrastructure
KYC/KYB procedures, transaction monitoring systems, suspicious activity reporting protocols, and complete compliance operational setup. Note: AML-critical functions (CDD/EDD, sanctions screening, transaction monitoring, STR/CTR reporting, MLRO duties) cannot be outsourced unless strict oversight conditions are met.
-
Ongoing Regulatory Reporting
Periodic compliance reports, regulatory updates tracking, license renewal support, and continuous regulatory relationship management.
Your Path to PVARA License
A structured approach to navigate the licensing process efficiently
-
01
Initial Assessment
Business model review, eligibility analysis, gap identification
-
02
NOC Application
Submit Form A1 + Annex A to PVARA for No Objection Certificate
-
03
AML Registration
Register with FMU on goAML portal — mandatory before operations
-
04
SECP Incorporation
Local entity incorporation under Companies Act 2017 using NOC
-
05
AML-Registered Services
Operate Exchange, Custody, Broker-Dealer & Derivatives under NOC+AML
-
06
Full License & Launch
Apply for full VASP license when published, then expand operations
-
01
Initial Assessment
Business model review, eligibility analysis, gap identification
-
02
NOC Application
Submit Form A1 + Annex A to PVARA for No Objection Certificate
-
03
AML Registration
Register with FMU on goAML portal — mandatory before operations
-
04
SECP Incorporation
Local entity incorporation under Companies Act 2017 using NOC
-
05
AML-Registered Services
Operate Exchange, Custody, Broker-Dealer & Derivatives under NOC+AML
-
06
Full License & Launch
Apply for full VASP license when published, then expand operations
What You Get
Comprehensive deliverables and ongoing support throughout your licensing journey
Documents
- Complete PVARA application package
- AML/CFT Policy Manual
- KYC/KYB Procedures Document
- Risk Assessment Framework
- Compliance Officer Handbook
- Board Resolution Templates
- Controller Disclosure (Form A2) & Source of Wealth
Support
- Dedicated compliance consultant
- Regulatory liaison services
- Query response preparation
- License renewal reminders
- Regulatory update briefings
- Post-license compliance support
8 Mandatory Key Individuals
Every PVARA applicant must appoint these roles before applying, as mandated by the official NOC Regulations (Section 5.1)
-
Chief Executive Officer
Overall executive responsibility for VASP operations and regulatory compliance.
-
Director
Executive or non-executive director responsible for governance and strategic oversight.
-
Chief Financial Officer
Financial management, capital adequacy, and financial reporting compliance.
-
Compliance Officer
Day-to-day regulatory compliance and adherence to PVARA obligations.
-
Money Laundering Reporting Officer (MLRO)
Dedicated AML/CFT oversight and suspicious activity reporting to FMU.
-
Head of Internal Audit
Independent internal audit function for controls and regulatory adherence.
-
Head of Risk Management
Enterprise risk framework including operational, market, and regulatory risks.
-
Head of Information Security
Cybersecurity, data protection, and technology risk management.
Coordinating with Pakistan's Regulators
We navigate the multi-agency regulatory landscape on your behalf
-
SECP
Securities and Exchange Commission of Pakistan
Company registration and incorporation authority under Companies Act 2017. Coordination body for VASP corporate structure, not the primary licensor.
-
FMU
Financial Monitoring Unit
AML/CFT compliance oversight and suspicious transaction reporting authority — mandatory goAML portal registration for all VASPs.
-
SBP
State Bank of Pakistan
Banking relationships and payment system integration oversight for virtual asset service providers operating in Pakistan.
Frequently Asked Questions
How long does PVARA licensing take?
NOC decisions are targeted within 60 calendar days of complete submission. Full licensing regulations and timelines have not yet been published by PVARA. We help expedite by ensuring complete, accurate submissions from day one.
What are the controller disclosure requirements?
The NOC Regulations require disclosure of all Controllers (anyone with 20%+ voting power or share capital). Each controller requires a Form A2 submission with Source of Wealth and Source of Funds documentation. PVARA pre-approval is required before AML registration.
What are the capital requirements?
PVARA has not yet published full licensing regulations including capital requirements. These will be detailed in forthcoming regulations. We provide estimates based on comparable jurisdictions during consultation.
Do I need a local director for licensing?
PVARA requires at least one Key Individual (e.g., CEO, Director, or MLRO) to be ordinarily resident in Pakistan with operational decision-making authority. We can facilitate resident Key Individual placement if needed as part of our Corporate Setup services.
What ongoing compliance is required?
Licensed entities must submit periodic compliance reports, maintain updated AML/CFT policies, report suspicious transactions, and undergo regular audits. We provide ongoing compliance support to ensure you stay compliant at all times.
Can foreign companies apply directly?
Foreign companies must first obtain a PVARA NOC, which grants permission to incorporate a local entity under the Companies Act 2017. We handle the complete corporate setup process as part of our integrated services.
What happens if my application is rejected?
Rejections typically come with specific reasons. We help address deficiencies and resubmit. Our thorough preparation process significantly reduces rejection risk — we don't submit until the application is complete and fully compliant.
Ready to Get Licensed?
Start your PVARA journey with a free compliance assessment. We'll review your business model and provide a custom licensing roadmap.
Response within 24 hours