--- title: "Pakistan Payments Regulation Monitor | World Payments Monitor" canonical: https://payments.gi/jurisdictions/pakistan/ source_html: /jurisdictions/pakistan/index.html description: "Pakistan payments and e-money regulation: 14 modules, 82 sourced findings, updated 2026-10-26. Licensing, safeguarding, stablecoins, AML/CFT." generated_at: 2026-10-26T19:20:26Z content_sha256: 61922c6cc99db4e75f050deda27683c7ee979a1ac643d54587900e70c0e994b4 generator: "fe-fleet/md-twin@1.0" --- # Pakistan PK schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-26 · 14 modules · 82 sourced findings · 148 sources in the cumulative register Download report (PDF) Expand all 14 Modules 0 Moved this cycle 1 Key judgments 2 Open gaps 82 Findings 25 Tier-1 sources Confidence mix 6 confirmed 8 unpopulated (sums to 14 rendered modules; click to filter) No modules moved this cycle. ## Jurisdiction brief Jurisdiction lead brief 1,721 Full executive summary 557 ###### Latest update · 25 October 2026 #### Lead Signal The payment-intermediary tightening the State Bank of Pakistan introduced in May 2026 has now produced its first visible enforcement materialisation. Account closures at JazzCash (operating through PSO Mobilink Microfinance Bank) and Easypaisa (operating through PSO Telenor Microfinance Bank) followed Federal Investigation Agency notices, after the agency traced transactions exceeding PKR 119.93 billion in gambling-application-linked flows moving through mobile-wallet aggregators. JazzCash is reported to have closed over one hundred aggregator accounts, with some reporting putting the figure as high as three hundred, while Easypaisa aggregator and merchant settlements were delayed. This confirms that mobile-wallet aggregators remain a live supervisory target in Pakistan and that the May 2026 framework has teeth in practice, not only on paper. #### Other Developments State Bank launches a remittance-incentive scheme funded by the banking industry. The State Bank of Pakistan unveiled the Pasban Remittance Reward Scheme under EPD Circular Letter No. 14 of 2026, with annual prize funding of PKR 16 billion contributed by the Pakistan Banks Association. The first draw is scheduled for 15 January 2027, covering remittances sent between October and December 2026. The scheme succeeds an earlier subsidised remitter-incentive arrangement and arrives against a backdrop of rising inward remittance volume, with Q1 FY27 remittances of approximately 10.9 billion US dollars, up roughly 14 percent year on year. #### Cross-Monitor Connections The same aggregator-closure event that anchors this period's licensing and market-access reading carries a parallel illicit-finance dimension, fed through the Sentinel intelligence channel: the Federal Investigation Agency's trace of gambling-linked transaction flows through JazzCash and Easypaisa is the financial-crime reading of the identical enforcement action described above as a licensing and supervisory development. The two readings are not in tension; they describe the same facts from different vantage points, one asking what the payment-system supervisory consequence is, the other asking what the money-laundering exposure is. No further analysis of the underlying illicit-finance mechanism belongs here; the originating gambling-sector context sits outside this monitor's remit entirely. #### Outlook The most immediate marker to watch is whether JazzCash and Easypaisa aggregator and merchant channels affected by the October 2026 closures are restored, and on what conditions; no restoration timeline has yet been published. A second marker is whether the enforcement pattern seen here against mobile-wallet aggregators extends to other payment-intermediary categories under the May 2026 framework, which would confirm a broader supervisory tightening cycle rather than an isolated gambling-linked action. On the remittance side, the first draw of the Pasban Remittance Reward Scheme on 15 January 2027 will be the first concrete test of whether the new prize-based incentive structure measurably affects formal remittance volume relative to the 14 percent year-on-year growth already recorded in Q1 FY27. 6 earlier updates not shown here. ###### Standing brief · as of 7 July 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal Pakistan's payments regulatory architecture has crossed a threshold this cycle: the Virtual Assets Act 2026, passed by Parliament in March 2026, confers permanent statutory status on the Pakistan Virtual Assets Regulatory Authority (PVARA), succeeding the July 2025 Virtual Assets Ordinance that had been promulgated by presidential decree under Article 89; Section 74 of the new Act deems prior NOCs and licences issued under the ordinance-era regime to remain valid. This is a decisive reversal of the 2018-2025 crypto-ban era, and it is being operationalised on the banking side in parallel: State Bank of Pakistan (SBP) Circular No. 10 of 2026, issued in April 2026, permits regulated banks to open accounts for PVARA-licensed virtual asset service providers subject to segregated Client Money Accounts, while continuing to bar banks from investing in, trading, or holding virtual assets with either their own or customer funds. The new Act also draws a clear technical line for what is permissible: algorithmic stablecoins are explicitly prohibited, while fiat- or asset-backed stablecoin-like tokens are permitted under licensing and reserve requirements, though the implementing reserve and redemption rulebook has not yet been published. Taken together, these developments mark a coordinated liberalisation of both the virtual-asset licensing perimeter and the bank-VASP interface that had been separated since the 2018 ban era. The regulatory opening is already drawing capital and commercial activity. Pakistan's Ministry of Finance signed a memorandum of understanding with Binance in December 2025 to explore tokenisation of up to $2 billion in state-owned assets, an exploratory arrangement running alongside PVARA's issuance of preliminary no-objection certificates to Binance and HTX. Venture investment has followed: Andreessen Horowitz led a $12.9 million funding round for ZAR, a Pakistani startup building a dollar-backed stablecoin aimed at mass adoption through retail agents and kiosks, a landmark stablecoin-focused raise even as the broader fintech venture market contracted sharply. The combination of permanent statutory footing for the regulator, a formal bank-access channel, and inbound institutional capital is the single most consequential development in this baseline cycle for Pakistan's payments environment. #### Other Developments Beneath the virtual-asset headline, Pakistan's conventional payments architecture continues to evolve unevenly. The non-bank e-money sector remains structurally thin eight years into its licensing regime: of the electronic money institutions licensed under the State Bank's 2019 EMI Regulations, revised in June 2023, six remain live as of December 2025, four have exited the market, and six sit at in-principle-approval or pilot stage, with only SadaPay and NayaPay having reached commercial scale. That attrition sits alongside a parallel digital-bank licensing track: five applicants received No Objection Certificates in January 2023 under the January 2022 Digital Bank framework, but their progression to full commercial licensing remains unconfirmed in available research three years on. Customer-fund protection, meanwhile, stands on a settled footing: e-money proceeds must sit in a segregated Trust Account with a licensed bank, reinforced by a rule requiring banks and microfinance banks to compensate customers within two business days for verified cyber-fraud or online-banking-fraud losses, alongside mandated EMVCo 3-D Secure implementation for card payments. Instant-payments infrastructure continues to mature. Raast, the central bank's real-time payment system, saw its Participation Criteria formalised in February 2025 across 44 onboarded entities, and a parallel central bank digital currency pilot is running alongside the new virtual-asset framework, though its scope and timeline remain sparsely disclosed. Cross-border reach is also extending: NayaPay's December 2025 partnership with Alipay+ enables global QR-based payment acceptance, building on an earlier April 2024 Ant Group tie-up and supplementing the Roshan Digital Account, which has long anchored non-resident remittance inflows through correspondent-banking arrangements and held over $5.2 billion in deposits by late 2022. Scheme infrastructure remains stable, with 1LINK, the domestic PSO/PSP operator of the PayPak card scheme, securing Mastercard Card Personalization Bureau certification in December 2025. Market structure, however, shows divergence: JazzCash and Easypaisa continue to dominate the mobile-wallet landscape with over 15 million active users apiece, even as fintech equity funding contracted 31.5% year-on-year in 2025 to just $5 million across three rounds, a contraction only partly offset by continued strategic investment such as VEON's $20 million injection into Mobilink Microfinance Bank in January 2026 and Mashreq's September 2025 launch of a full-service digital retail bank in Islamabad. Operational resilience is also being reinforced, if incrementally. The State Bank's 2017 IT security and risk-management framework, which requires banks to establish Security Operations Centers, conduct regular audits, and report major cyber incidents, has been extended by a 2026 Cyber Shield strategy aimed at moving the sector from basic prevention toward institutional resilience and recovery capability, an explicit acknowledgment that legacy systems remain in use across many banks. Settlement infrastructure sits on a similarly established footing: the PRISM real-time gross settlement system, operating under the PRISM RTGS Rules 2008 issued pursuant to the Payment Systems and Electronic Fund Transfers Act 2007, has functioned as Pakistan's large-value settlement backbone since 2008, with 1LINK serving as a special participant for electronic clearing settlement since July 2018. On enforcement and redress, the State Bank's practice of quarterly disclosure continues, with Rs465.08 million in penalties imposed on ten banks for the quarter ended December 2023 for CDD/KYC, foreign-exchange and AML/CFT lapses, the most recent such disclosure surfaced this cycle, alongside a standing EMI licensing-enforcement precedent in TAG's licence revocation following its collapsed Samba Bank acquisition attempt. Consumer redress runs through a tiered structure culminating in Banking Mohtasib Pakistan, an independent statutory ombudsman that processed over 25,000 complaints and delivered Rs1.26 billion in monetary relief in 2023. On merchant acquiring, a Rs3.5 billion government subsidy programme running from September 2025 through June 2026 has been reimbursing merchants for low-value P2M QR transactions in an economy where more than 85% of transactions remain cash-based, though that programme window has now lapsed as of this cycle's retrieval date with no confirmed follow-on phase. #### Cross-Monitor Connections Two threads in this cycle carry direct cross-monitor relevance for the illicit-finance desk. Pakistan exited the FATF grey list in October 2022 and has remained off both the blacklist and grey list through the 19 June 2026 FATF list update, spanning six consecutive plenaries, a Sentinel-fed data point carried here as payments-context provenance only. Continuing reports of digital-wallet misuse by proscribed organisations, including Jaish-e-Mohammad, are flagged as touching Pakistan's 2018/2021 FATF commitments despite the grey-list exit, and commentary warns that renewed FATF pressure could damage correspondent-banking relationships and jeopardise the IMF Extended Fund Facility given its own AML/CFT conditionalities. Both signals have been routed to FIM as cross-monitor flags; WPM's own analytical interest is confined to the structural correspondent-banking access implications for Pakistan's payments sector, not an independent illicit-finance assessment. #### Outlook The trajectory across Pakistan's payments environment this cycle is one of liberalisation running ahead of implementation detail. The Virtual Assets Act 2026 and its bank-access circular establish the legal architecture for a licensed digital-asset economy, but the reserve and redemption rulebook that will determine how fiat-backed stablecoins actually operate remains unpublished, and the current commercial-licensing status of the 2023 digital-bank NOC cohort needs verification before it can be treated as resolved. Watch for three things over the coming cycles: publication of PVARA's reserve and redemption rulebook, confirmation of whether any of the five digital-bank NOC holders convert to commercial licences, and whether the lapsed P2M subsidy programme is renewed given the economy's continued reliance on cash. The correspondent-banking and FATF-adjacent vulnerability flagged in this cycle also bears monitoring, since any deterioration would compound the access asymmetry already visible between bank-channel and non-bank EMI participants in Pakistan's payments market. Read full brief · 1721 words ###### Latest update · 25 October 2026 #### Regulatory Status Pakistan's payment-intermediary supervisory environment tightened materially this period. The State Bank of Pakistan's May 2026 payment-intermediary and aggregator framework was enforced in practice for the first time in October 2026, when Federal Investigation Agency notices led to account closures at JazzCash's Payment System Operator entity (Mobilink Microfinance Bank) and Easypaisa's Payment System Operator entity (Telenor Microfinance Bank). The trigger was a traced transaction value exceeding PKR 119.93 billion in gambling-application-linked flows; JazzCash closed over one hundred aggregator accounts, with reporting ranging up to three hundred, and Easypaisa aggregator and merchant settlements were delayed. Six major payment companies are reported to be affected overall. Separately, the State Bank unveiled the Pasban Remittance Reward Scheme under EPD Circular Letter No. 14 of 2026, an industry-funded remittance incentive carrying a PKR 16 billion annual prize pool, with its first draw set for 15 January 2027 and arriving against Q1 FY27 remittance growth of roughly 14 percent year on year to approximately 10.9 billion US dollars. #### Outlook The near-term marker for Pakistan is whether the JazzCash and Easypaisa channels affected by the October 2026 closures are restored, and under what conditions; no restoration timeline has been published. The Pasban Remittance Reward Scheme's first draw on 15 January 2027 is the next scheduled milestone for the remittance-incentive side of the market, and will offer the first indication of whether the industry-funded prize model measurably affects formal remittance flow. 3 earlier updates not shown here. ###### Standing brief · as of 7 July 2026 Written before the update above. Where they differ, the update is the more recent position. #### Regulatory Status Pakistan's payments regulatory architecture rests on the Payment Systems and Electronic Fund Transfers Act 2007, administered by the State Bank of Pakistan, with non-bank e-money issuance licensed under the 2019 EMI Regulations, revised June 2023, via a three-stage In-Principle, Pilot, and Commercial Operations process. A parallel Digital Bank framework, launched January 2022, issued No Objection Certificates to five applicants in January 2023, though their path to commercial licensing remains unconfirmed. This cycle's most consequential development is the Virtual Assets Act 2026, which confers permanent statutory status on the Pakistan Virtual Assets Regulatory Authority, succeeding the July 2025 ordinance, while SBP Circular No. 10 of 2026 opens bank accounts to licensed virtual asset service providers under segregated Client Money Accounts. Instant-payments infrastructure continues to mature through Raast, whose Participation Criteria were formalised in February 2025 across 44 entities, alongside a parallel central bank digital currency pilot. Settlement runs through the PRISM RTGS system operating since 2008, with 1LINK serving as a special participant since July 2018, and correspondent-banking access sits against a backdrop of continuing FATF-adjacent scrutiny even though Pakistan has remained off the FATF grey and black lists since October 2022. Consumer protection runs through a tiered redress structure culminating in Banking Mohtasib Pakistan, reinforced by a two-business-day cyber-fraud reimbursement mandate for banks and microfinance banks. #### Outlook Pakistan's regulatory direction is unambiguously liberalising on virtual assets while remaining structurally cautious on correspondent-banking exposure; the jurisdiction's risk profile is assessed as elevated and escalating, driven jointly by the pace of virtual-asset market opening and the persistence of FATF-adjacent vulnerability. Verification of the digital-bank NOC cohort's commercial-licensing status and publication of PVARA's reserve and redemption rulebook are the two clearest items to track into the next cycle. Read full brief · 557 words × 14 of 14 modules Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### W1aLicensing, Authorisation & Market Access1 judgment1 gapConfirmedconfirmed 2026-07-04▾# Pakistan's payment-institution regime is governed by the PSEFT Act 2007 (SBP Payment Systems Department), covering PSOs, PSPs and EMIs. A new adjacent VASP licensing perimeter opened in 2026 under PVARA, interoperating with the SBP-licensed payments perimeter via SBP Circular 10/2026 permitting bank accounts for PVARA-licensed VASPs. Key judgment — Probable · impact HIGH The October 2026 FIA enforcement action against JazzCash and Easypaisa aggregator channels represents the first visible enforcement materialisation of SBP's May 2026 payment-intermediary tightening, signalling that mobile-wallet aggregators remain a live supervisory target in Pakistan. claims: wpm-2026-W43-001 Open gap — wpm-int-1 No restoration timeline or final resolution for JazzCash/Easypaisa gambling-linked aggregator suspensions located this cycle. no under-indexing note recorded Horizon · 2026-09-05 (± a quarter) PVARA NOC filing deadline for pre-existing VASPs Adopted, not yet in force · Tier 3 source Standing sub-brief · as of 7 July 2026 287 words · last cycle 2026-10-25 #### Licensing, Authorisation & Market Access Pakistan's non-bank e-money issuance is licensed under the 2019 EMI Regulations, revised 21 June 2023, through a three-stage process, In-Principle Approval, Pilot, and Commercial Operations, under Section 24 of the Payment Systems and Electronic Fund Transfers Act 2007. The State Bank of Pakistan (SBP) administers this regime directly, and it sits alongside a parallel Digital Bank framework launched in January 2022. Under that framework, SBP issued No Objection Certificates to five successful digital-bank applicants, selected from 20 applications received by 31 March 2022, in January 2023, the first stage of a multi-stage process running from NOC to incorporation, in-principle approval, pilot, and finally commercial licence. The current commercial-licensing status of these five entities as of this cycle is not confirmed in available research, and NOC issuance should not be read as equivalent to a full commercial licence. The EMI cohort itself shows material churn. As of December 2025, six EMIs remain live, SadaPay, NayaPay, Keenu, Finja (acquired by OPay), OneZapp/EP Systems, and Digitt+/Akhtar Fuiou, four have exited the market, Careem, Checkout.com, TAG, and CMPECC, and six more sit at in-principle-approval or pilot stage. Only SadaPay and NayaPay have reached commercial scale after eight years of the licensing regime's existence, an attrition pattern that reflects thin merchant-discount economics and sustained competition from telco-backed mobile wallets such as JazzCash and Easypaisa. #### Outlook The near-term watch items for this module are whether any of the five digital-bank NOC holders convert to full commercial licences, and whether further EMI-cohort attrition or consolidation follows the pattern already seen in TAG's, Careem's and Checkout.com's exits. Verification of the digital-bank pipeline against SBP's register should be treated as a priority gap before the current standing position is relied upon. Read full sub-brief · 287 words Periodic update · new data 2026-10-25 #### Licensing, Authorisation & Market Access The State Bank of Pakistan's payment-intermediary and aggregator framework, dated May 2026, produced its first visible enforcement materialisation in October 2026. Account closures occurred at JazzCash, operating through its Payment System Operator licence held by Mobilink Microfinance Bank, and at Easypaisa, operating through its Payment System Operator licence held by Telenor Microfinance Bank. The trigger was a Federal Investigation Agency probe that traced transactions exceeding PKR 119.93 billion in gambling-application-linked flows moving through mobile-wallet aggregators; JazzCash closed more than one hundred aggregator accounts following FIA notices, with some reporting putting the figure as high as three hundred, while Easypaisa aggregator and merchant settlements were delayed. Six major payment companies are reported to be affected by the broader action. The structural significance of this development is that the May 2026 framework, until this point a paper tightening of licensing and conduct standards for payment intermediaries, has now been shown to carry real enforcement consequence when a specific illicit-flow trigger (in this case, gambling-linked transaction volume) is identified. For non-bank payment-institution and e-money-institution licensees operating aggregator models in Pakistan, the practical lesson is that aggregator-level account closures can follow directly from a law-enforcement referral rather than requiring a separate State Bank supervisory finding in the first instance. No restoration timeline for the affected JazzCash and Easypaisa channels had been published as of the most recent reporting, meaning the duration and ultimate resolution of this disruption remains open. #### Outlook The marker to watch is whether the JazzCash and Easypaisa aggregator and merchant channels affected by the October 2026 closures are restored, and under what conditions. A second marker is whether this enforcement pattern, triggered by a law-enforcement referral rather than a routine supervisory review, is applied to other payment-intermediary or aggregator licensees under the same May 2026 framework, which would indicate a broader tightening cycle for the licensing and market-access environment rather than an isolated gambling-linked action. 5 earlier distinct update(s) Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Pakistan's non-bank and digital-bank market-access landscape continued to liberalise this period. Raqami Islamic Digital Bank Limited was declared a Scheduled Bank from 6 February 2026 under the State Bank of Pakistan's Digital Retail Bank licence category, and the institution then progressed to a full commercial-operations licence in May 2026, becoming Pakistan's first fully Shariah-compliant digital retail bank. This progression from in-principle to full commercial licensing status illustrates the pathway SBP's digital-bank licensing framework is designed to follow, from a Scheduled Bank declaration through to full commercial authorisation. Alongside this bank-licensed development, SBP's public electronic money institution register, last updated 2 September 2026, names seven EMIs now in full commercial operation: NayaPay, Finja/OPay, SadaPay, Akhtar Fuiou/Digitt+, E-Processing Systems/OneZapp, Wemsol/Keenu, and YAP Pakistan. This roster represents the current state of Pakistan's licensed non-bank electronic money sector as reflected in SBP's own register, though the register itself was accessed through a secondary compilation rather than directly this period, and the regulator's own primary listing was not independently re-verified. Taken together, the Raqami digital-bank progression and the expanded EMI roster indicate continued market-access liberalisation across both the bank-PSP and non-bank PI/EMI licensing tracks in Pakistan, with SBP actively processing and publishing licence-status changes across both categories during this period. #### Outlook Whether additional digital-bank licensees progress through the same Scheduled-Bank-to-commercial-operations pathway Raqami has now completed, and whether the EMI roster continues to expand beyond the seven currently listed, are the questions to track for market-access purposes in the coming period. Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Pakistan's payments-market-access landscape shifted materially this cycle through two connected regulatory actions. The State Bank of Pakistan's Circular No. 10 of 2026 authorised commercial banks to open and maintain accounts for PVARA-licensed virtual asset service providers, formally ending a seven-year prohibition on bank facilitation of crypto-linked accounts. This is a confirmed development, corroborated directly by SBP circular language quoted in independent reporting, and it represents a bank-side market-access change: banks (the bank_psp side of the bank-PSP vs non-bank-PI/EMI distinction) are now permitted, subject to AML/KYC/CFT conditions, to service a category of non-bank licensed entity that was previously excluded from formal banking relationships entirely. On the non-bank side, the Pakistan Virtual Assets Regulatory Authority opened its own licensing portal on 22 August 2026, establishing sandbox, no-objection-certificate and full-licence routes for virtual asset service providers — a distinct non-bank licensing perimeter (nonbank_pi_emi) running in parallel to the bank-side circular. Pre-existing VASP operators face a 5 September 2026 deadline to file for an NOC. Both developments are confirmed and reasonably well corroborated (T3-sourced), though direct retrieval of the underlying SBP circular text and PVARA statute was not achieved this cycle. Read together, they represent the formal joining of Pakistan's bank-side and non-bank-side payments-market-access regimes for the crypto sector for the first time. #### Outlook Whether banks move promptly to open accounts for PVARA-licensed VASPs following the Circular, and whether PVARA's NOC deadline produces visible compliance or enforcement outcomes, are the two clearest near-term markers for this module. Periodic update · new data 2026-09-08 #### Licensing, Authorisation & Market Access The State Bank of Pakistan now permits banks to open accounts for virtual-asset firms licensed by the Pakistan Virtual Assets Regulatory Authority, reversing its prior restrictive de-risking posture toward the sector. This is reported at Confirmed confidence but rests on a single trade-press source, with the interpreter flagging that no primary SBP circular text corroborating the reversal has yet been retrieved this cycle. The practical effect, if the reversal holds as reported, is significant for market access: a licensed VASP under Pakistan's Virtual Assets Act 2026 that previously could not obtain basic banking services can now do so, removing a structural bottleneck that has historically constrained crypto-sector market entry even where a licensing pathway exists on paper. This development was corroborated in substance, though not in primary-source form, by reporting from the Pakistan Fintech Forum IV, where a participant described banks as now able to open accounts for PVARA-licensed firms, something that was not possible before. The consistency between the two reports, from different secondary sources describing the same underlying policy shift, raises confidence in the directional finding even though neither reaches Tier 1 status. The bank/non-bank distinction is directly implicated here: this reversal applies to banks opening accounts for VASPs, a bank-side access question, and is distinct from the non-bank PI/EMI compliance obligations addressed separately under the Technology Risk Management Framework. Market access for a PVARA-licensed VASP therefore now depends on two separate regulatory tracks converging: continued PVARA licensure and this SBP-side banking access reversal. #### Outlook The key signal to track next cycle is whether the State Bank of Pakistan publishes a primary circular formalising this reversal, which would move the finding from a single-source trade-press report to a directly verifiable regulatory instrument. Until that corroboration arrives, market participants should treat the reported policy reversal as probable but not yet fully confirmed at the primary-source level. Periodic update · new data 2026-08-25 #### Licensing, Authorisation & Market Access State Bank of Pakistan's licensing pipeline for Electronic Money Institutions and Payment System Operators processed multiple new entrants this cycle. SBP granted in-principle approval to Toko Lab Pvt Ltd as an Electronic Money Institution and to Accept Technologies, trading as PayMob, as a Payment System Operator and Payment Service Provider, while granting pilot-operations approval to HubPay Pvt Ltd as an Electronic Money Institution. This High-confidence, T1-sourced finding, drawn directly from an SBP press release, evidences three distinct stages within a single licensing sequence, in-principle approval, pilot operations, and eventual full commercial launch, and confirms that the non-bank side of Pakistan's payments market-access regime is actively processing applicants. Alongside market entry sits a specific prudential safeguard governing how non-bank licensees may hold customer funds: Electronic Money Institutions are required to hold a segregated Trust Account with a licensed bank for all customer e-money float, kept distinct from the EMI's own operating funds, a direct requirement of SBP's EMI Regulations. This safeguarding structure is the mechanism that allows SBP to extend licensed status to non-bank entities without exposing customer float to the EMI's own commercial risk, and it sits at the centre of the bank-versus-non-bank distinction that runs through Pakistan's payments licensing architecture: EMIs and PSOs are licensed and supervised as a category distinct from banks, yet are required to park customer funds within the banking system itself. A further, Assessed-confidence, dated data point illustrates how this licence-class distinction plays out commercially: industry reporting indicates that JazzCash and Easypaisa operate under the Payment System Operator category while NayaPay operates under the Electronic Money Institution category, meaning the two licence classes remain functionally distinct market segments even though both fall within SBP's non-bank payment-institution supervisory umbrella. This is a short dated dashboard-tier observation rather than a standalone finding, sourced from an industry blog rather than a primary SBP statement. #### Outlook The near-term marker to watch is whether Toko Lab, PayMob, and HubPay progress beyond their current approval stages toward full commercial launch, which would confirm that this cycle's approvals reflect a functioning licensing pipeline rather than an isolated batch. A further marker is whether additional EMI or PSO approvals follow in subsequent cycles, which would indicate whether SBP's non-bank market-access regime is expanding at a sustained pace. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Pakistan's legal and regulatory perimeter for virtual-asset activity was reset this cycle by the enactment of the Virtual Assets Act 2026, which converts the Pakistan Virtual Assets Regulatory Authority (PVARA) from a temporary presidential-ordinance body into a permanent statutory regulator. PVARA now holds licensing, suspension, and revocation power over virtual asset service providers, and the Act establishes criminal penalties for unlicensed operation. This finding is rated Assessed confidence: it is corroborated across multiple crypto trade-press outlets, but no primary legislative gazette text was retrieved this cycle, so the statutory detail rests on secondary reporting rather than direct primary-source verification. A specific market-access consequence of the Act is the Section 70 transitional provision: virtual asset service providers already active in Pakistan before the Act's commencement have a six-month grace period to obtain a PVARA licence or must cease operations. This creates a defined compliance deadline where none previously existed, converting Pakistan's prior unregulated space into one with a formal cutoff for licensing. This grace-period finding is itself rated Assessed, sourced from legal commentary rather than independently corroborated primary legislative text, and is a distinct market-access fact from the Act's headline enactment. PVARA has moved to operationalise the licensing perimeter it has just been granted: a draft Pakistan Virtual Asset Services Regulations 2026, together with ten activity-specific handbooks covering distinct licence categories, is out for public consultation, with comments closing 2 July 2026 at 4:00 PM Pakistan Standard Time. This is a direct, high-confidence, primary-source finding drawn from PVARA's own consultation notice, and it is the clearest indicator that the licensing regime remains at an interim stage, operators currently hold, at most, a no-objection certificate rather than a full licence, and the activity-specific detail that would define full licensing has not yet been finalised. A further legal-perimeter consequence of the Act is that virtual asset service providers are now deemed financial institutions under the AML Act 2010, which brings with it inherited obligations including the Travel Rule and proof-of-reserves requirements once PVARA's supervisory framework is operational. This is recorded here as a legal-perimeter fact establishing scope, rather than as an assessment of enforcement in practice. For firms assessing market entry, the practical sequencing is now clearer than at any point since the 2018-era restrictions: the licensing perimeter is fixed in statute, the transitional deadline is fixed by section, and the only open variable is the substantive content of the activity-specific handbooks, which will determine the compliance burden attached to each licence category once finalised. #### Outlook The determinative near-term marker is the 2 July 2026 close of PVARA's consultation on the draft Regulations and handbooks; finalisation would convert the current interim no-objection-certificate regime into a full licensing architecture with activity-specific conditions. A second marker is the practical effect of the Section 70 grace period as its expiry approaches: whether PVARA enforces the cessation requirement against operators that have not obtained a licence, or extends the transitional window, will materially shape the market-access picture for both incumbent and prospective virtual-asset firms in Pakistan. Evidence 8 Sources and findings (8) - T1[https://www.sbp.org.pk/psd/2019/C1-Annex-A.pdf](https://www.sbp.org.pk/psd/2019/C1-Annex-A.pdf)retrieved 2026-07-04 - T1[https://www.readkong.com/page/regulations-for-electronic-money-institutions-9802339](https://www.readkong.com/page/regulations-for-electronic-money-institutions-9802339)retrieved 2026-07-04 - T2[https://pkrevenue.com/state-bank-revises-regulations-to-enhance-scope-of-electronic-money-institutions/](https://pkrevenue.com/state-bank-revises-regulations-to-enhance-scope-of-electronic-money-institutions/)retrieved 2026-07-04 - T1[https://www.sbp.org.pk/dfs/Digital-Bank-Regulatory.html](https://www.sbp.org.pk/dfs/Digital-Bank-Regulatory.html)retrieved 2026-07-04 - T3[https://www.fintechfutures.com/digital-banking/state-bank-of-pakistan-names-five-successful-digital-bank-applicants](https://www.fintechfutures.com/digital-banking/state-bank-of-pakistan-names-five-successful-digital-bank-applicants)retrieved 2026-07-04 - T3[https://profit.pakistantoday.com.pk/2025/12/10/mapping-emis-in-pakistan-since-2020-6-live-4-face-death-and-6-at-ipa-or-pilot](https://profit.pakistantoday.com.pk/2025/12/10/mapping-emis-in-pakistan-since-2020-6-live-4-face-death-and-6-at-ipa-or-pilot)retrieved 2026-07-04 - T3[https://digitalpakistan.pk/emi-license-pakistan-in-2026/](https://digitalpakistan.pk/emi-license-pakistan-in-2026/)retrieved 2026-07-04 - T3[https://www.ibanet.org/the-legal-landscape-for-fintech-in-pakistan](https://www.ibanet.org/the-legal-landscape-for-fintech-in-pakistan)retrieved 2026-07-04 ### W1bConduct, Safeguarding & PromotionsConfirmedconfirmed 2026-07-04▾# Customer-fund safeguarding via mandatory segregated Trust Account; Branchless Banking Regulations place ultimate agent liability on the principal institution; conduct sits within PS&EFT Act 2007 and SBP's BC&CPD. Standing sub-brief · as of 7 July 2026 191 words · last cycle 2026-07-04 #### Conduct, Safeguarding & Financial Promotions Customer funds collected against e-money issuance in Pakistan must be placed into a segregated Trust Account with a licensed bank, held distinct from the EMI's own funds, under the EMI Regulations administered by the State Bank of Pakistan. This mechanism is the core customer-fund-protection architecture for the non-bank e-money sector and applies uniformly across the EMI cohort regardless of individual institutions' commercial scale. Conduct obligations extend into fraud redress. Banks and microfinance banks must compensate customers within two business days for verified financial loss due to cyber crime or online banking fraud, a rule paired with a mandated EMVCo 3-D Secure implementation for card payments. Together, the Trust Account safeguard and the two-day reimbursement mandate form the standing conduct baseline for Pakistan's payments sector, though financial-promotion enforcement actions specific to payments and e-money conduct, as distinct from AML/KYC enforcement, remain under-indexed in available research this cycle. #### Outlook The safeguarding and conduct baseline appears settled and unlikely to shift materially in the near term, but the under-indexing of financial-promotion enforcement is a bias-correction flag worth tracking should SBP publish more granular conduct-specific enforcement data in future disclosures. Read full sub-brief · 191 words no periodic updates on record for this sub-brief Evidence 7 Sources and findings (7) - T1[https://www.readkong.com/page/regulations-for-electronic-money-institutions-9802339](https://www.readkong.com/page/regulations-for-electronic-money-institutions-9802339)retrieved 2026-07-04 - T3[https://khalidzafar.com/licensing-procedure-and-conditions-for-emis-electronic-money-institutions/](https://khalidzafar.com/licensing-procedure-and-conditions-for-emis-electronic-money-institutions/)retrieved 2026-07-04 - T1[https://www.sbp.org.pk/bprd/2019/C10-Branchless-Banking-Regulations.pdf](https://www.sbp.org.pk/bprd/2019/C10-Branchless-Banking-Regulations.pdf)retrieved 2026-07-04 - T1[https://www.app.com.pk/business/sbp-issues-framework-for-branchless-banking-agent-acquisition-and-management/](https://www.app.com.pk/business/sbp-issues-framework-for-branchless-banking-agent-acquisition-and-management/)retrieved 2026-07-04 - T2[https://www.brecorder.com/news/4652556](https://www.brecorder.com/news/4652556)retrieved 2026-07-04 - T3[https://khalidzafar.com/emi-electronic-money-institutions/](https://khalidzafar.com/emi-electronic-money-institutions/)retrieved 2026-07-04 - T2[https://iclg.com/practice-areas/digital-business-laws-and-regulations/pakistan](https://iclg.com/practice-areas/digital-business-laws-and-regulations/pakistan)retrieved 2026-07-04 ### W2Stablecoins & Digital Moneylimited signalProbableconfirmed 2026-07-04▾# Virtual Assets Act 2026 (successor to July 2025 Ordinance) grants PVARA permanent statutory status; algorithmic stablecoins prohibited, fiat/asset-backed tokens permitted under licensing/reserve rules; SBP authorises bank accounts for licensed VASPs (Apr 2026); CBDC pilot ongoing. Standing sub-brief · as of 7 July 2026 229 words · last cycle 2026-10-18 #### Stablecoins & Digital Money The Virtual Assets Act 2026, passed by Parliament in March 2026, confers permanent statutory status on the Pakistan Virtual Assets Regulatory Authority, succeeding the July 2025 Virtual Assets Ordinance that had been promulgated by presidential decree under Article 89; Section 74 of the new Act deems prior NOCs and licences valid under the successor regime. This is the clearest reversal yet of the 2018-2025 crypto-ban era, moving Pakistan from an ordinance-based interim posture to a permanent statutory footing for virtual-asset regulation. The banking interface has been opened in parallel. SBP Circular No. 10 of 2026, issued in April 2026, permits regulated banks to open accounts for PVARA-licensed virtual asset service providers subject to segregated Client Money Accounts, while continuing to bar banks from investing in, trading, or holding virtual assets with either their own or customer funds. On the product side, the Act prohibits algorithmic stablecoins outright, while permitting fiat- or asset-backed stablecoin-like tokens under licensing and reserve requirements; the implementing reserve and redemption rulebook has not yet been published, leaving a material gap in how the regime will function in practice. #### Outlook Watch for publication of PVARA's reserve and redemption rulebook, which will determine whether fiat-backed stablecoin issuance can proceed on a fully specified basis, and for any indication of how the Ministry of Finance's exploratory tokenisation discussions with Binance translate into concrete transactions. Read full sub-brief · 229 words Periodic update · new data 2026-10-18 #### Stablecoins & Digital Money Pakistan's digital-money regulatory architecture advanced this cycle through two connected mechanisms. PVARA's licensing regulations include dedicated licence categories for Fiat-Referenced Token Issuance and Asset-Referenced Token Issuance, establishing distinct regulatory tracks for fiat-backed and asset-backed token issuers rather than treating stablecoin issuance as an undifferentiated subset of general virtual-asset activity. Alongside this, the State Bank of Pakistan's Circular Letter No. 10 of 2026 introduced a phased framework permitting PVARA-licensed virtual-asset service providers to hold segregated client-money bank accounts, replacing the previous restrictions that had effectively isolated the digital-asset sector from conventional banking access. The combination of a dedicated stablecoin-issuance licensing track and a banking-access bridge is a structurally significant pairing. Many emerging digital-asset frameworks establish issuance licensing without resolving the parallel banking-access question, leaving licensed issuers unable to maintain the fiat reserves or client-money segregation that a credible stablecoin regime requires in practice. Pakistan's approach, at least as described in current reporting, addresses both halves of that problem together: an issuance licence under PVARA's framework and a banking channel under the State Bank's circular. However, this finding rests on secondary reporting rather than a directly retrieved PVARA or State Bank primary text, and the operational detail of reserve composition, redemption mechanics, and disclosure requirements for fiat-referenced and asset-referenced token issuers has not been independently confirmed. This is best read as an emerging rather than settled architecture. The licence categories exist on paper and the banking circular has been reported, but no issuer has yet been confirmed as operating under a full Fiat-Referenced or Asset-Referenced Token Issuance licence, since PVARA's full licensing phase, covering stablecoin issuers alongside other virtual-asset service providers, remains pending into the fourth quarter of 2026. The practical test of this framework will come once an actual issuer begins operating under one of these categories and the segregated-account mechanism is observed functioning as described. #### Outlook The next material marker for Pakistan's stablecoin-adjacent framework will be the first issuer licensed under either the Fiat-Referenced or Asset-Referenced Token Issuance category, expected as part of PVARA's broader move to full licensing in the fourth quarter of 2026. Confirmation of the reserve, redemption, and disclosure requirements attached to each category, ideally from PVARA's own gazetted regulatory text, would resolve a current gap in independently verified detail. The State Bank's segregated-account circular should also be watched for its practical operation once licensed providers begin using it, since a circular permitting an arrangement is not the same as that arrangement functioning at scale. Evidence 7 Sources and findings (7) - T2[https://complyfactor.com/pakistan-virtual-assets-act-2026-complete-guide-to-pvara-licensing-and-compliance/](https://complyfactor.com/pakistan-virtual-assets-act-2026-complete-guide-to-pvara-licensing-and-compliance/)retrieved 2026-07-04 - T2[https://fafen.org/pvar-ordinance-is-crypto-now-legal-in-pakistan/](https://fafen.org/pvar-ordinance-is-crypto-now-legal-in-pakistan/)retrieved 2026-07-04 - T1[https://www.pakistantoday.com.pk/2026/04/15/sbp-legalises-virtual-assets-under-new-law](https://www.pakistantoday.com.pk/2026/04/15/sbp-legalises-virtual-assets-under-new-law)retrieved 2026-07-04 - T3[https://issra.pk/insight/2026/adopting-cryptocurrency-in-pakistan-prospects-and-concerns/insight.php](https://issra.pk/insight/2026/adopting-cryptocurrency-in-pakistan-prospects-and-concerns/insight.php)retrieved 2026-07-04 - T3[https://sumsub.com/blog/crypto-in-pakistan/](https://sumsub.com/blog/crypto-in-pakistan/)retrieved 2026-07-04 - T3[https://www.ccn.com/news/crypto/pakistan-crypto-ban-regulation-passes-virtual-assets-act-2026/](https://www.ccn.com/news/crypto/pakistan-crypto-ban-regulation-passes-virtual-assets-act-2026/)retrieved 2026-07-04 - T3[https://www.coinconnect.site/pvara-guide](https://www.coinconnect.site/pvara-guide)retrieved 2026-07-04 ### W3Operational Resilience & Critical InfraConfirmedconfirmed 2026-07-04▾# SBP's Technology Risk Management Framework for Payment Institutions (Oct 2025) sets cyber-risk-control, governance and incident-reporting requirements for PSOs/PSPs/EMIs, with a 31 March 2026 compliance deadline. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/pakistan/) Horizon · 2026-03-31 (± a quarter) SBP Technology Risk Management Framework compliance deadline Adopted, not yet in force · Tier 3 source Standing sub-brief · as of 7 July 2026 104 words · last cycle 2026-09-14 #### Operational Resilience & Critical Infrastructure SBP's 2017 IT security and risk-management framework requires banks to establish Security Operations Centers, conduct regular audits, and report major cyber incidents to SBP, forming the foundational resilience baseline for Pakistan's banking sector. That baseline has been extended by the 2026 Cyber Shield strategy, which moves resilience posture beyond basic prevention toward institutional resilience and recovery capability, an explicit response to the fact that legacy systems remain in use across many banks. #### Outlook The near-term question is implementation pace: whether Cyber Shield's recovery-capability objectives translate into measurable reductions in incident-response times, given the legacy-systems constraint the strategy itself acknowledges. Read full sub-brief · 104 words Periodic update · new data 2026-09-28 #### Operational Resilience & Critical Infrastructure Pakistan's operational-resilience regulatory floor for payment institutions tightened materially this cycle. The State Bank of Pakistan's Technology Risk Management Framework for Payment Institutions, issued in October 2025, sets a 31 March 2026 compliance deadline for cyber-risk-control, governance and incident-reporting preparedness, applying across both bank and non-bank participants — payment service operators, payment service providers and electronic money institutions alike. This is a confirmed development, though the underlying source tier is lower (a payments-industry commentary source rather than direct SBP text), meaning the framework's existence and deadline are well established while its granular technical-control content is not yet independently verified in this evidence base. Alongside this cyber-resilience framework, the SBP's Raast Participation Criteria, introduced in early 2025, set functional and technical requirements for direct scheme participation — applicable to banks, electronic money institutions, payment system operators and payment service providers alike. This is a T1-sourced, confirmed finding drawn from the SBP Payment Systems Department's own reference material, and it establishes the baseline technical bar for any entity, bank or non-bank, seeking to connect directly to Pakistan's instant-payment rail rather than accessing it indirectly through a sponsoring participant. #### Outlook The 31 March 2026 compliance deadline for the Technology Risk Management Framework is the clearest near-term marker: confirmed enforcement or supervisory action against non-compliant payment institutions following that deadline would sharpen this module's currently framework-existence-level picture into a tested operational reality. 2 earlier distinct update(s) Periodic update · new data 2026-09-08 #### Operational Resilience & Critical Infrastructure The State Bank of Pakistan's Technology Risk Management Framework for Payment Institutions carried a compliance deadline of 31 March 2026, requiring payment system operators, payment service providers and electronic money institutions to demonstrate adequate cyber-risk controls, technology governance, business continuity planning and incident-reporting capability. That deadline has now passed within this baseline reporting window, meaning the non-bank payment-institution sector in Pakistan is now expected to be operating under these resilience obligations as a matter of ongoing compliance rather than forward planning. This is explicitly a non-bank PI/EMI-facing obligation: the framework targets payment system operators, payment service providers and electronic money institutions specifically, distinct from the prudential and operational-resilience expectations that apply to banks under separate supervisory frameworks. The distinction matters because it means the resilience bar for non-bank payment institutions in Pakistan has been formally codified and dated, giving supervisors and counterparties a fixed reference point against which to assess a given PI or EMI's compliance posture going forward. The underlying source for this deadline is a Tier 4 vendor commentary source rather than a primary SBP publication, and the interpreter assigns Probable rather than Confirmed confidence accordingly. Nonetheless, the substantive fact that a formal compliance deadline for technology-risk controls has now passed is a meaningful operational-resilience marker for the jurisdiction, independent of the precision of its sourcing. #### Outlook The development to watch next cycle is whether the State Bank of Pakistan follows the passed deadline with visible supervisory action, such as public enforcement notices or a compliance-status disclosure, against payment institutions that failed to meet the 31 March 2026 deadline. Absent such follow-up, market observers should treat the deadline as procedurally passed but its practical enforcement bite as currently unverified. Periodic update · new data 2026-08-25 #### Operational Resilience & Critical Infrastructure State Bank of Pakistan issued a Technology Risk Management Framework for Payment Institutions in October 2025, requiring cyber-risk controls, technology governance, business continuity planning, and incident-reporting readiness, with institutions expected to demonstrate readiness by 31 March 2026. This is a Probable-confidence finding, sourced from secondary reporting rather than the primary SBP text, and it applies across both bank and non-bank payment institutions alike, treating operational-resilience obligations as a function of payment-system participation rather than of institutional charter type. The framework's timing is notable set against this cycle's licensing activity: several non-bank entrants, including Toko Lab, PayMob, and HubPay, received in-principle or pilot-operations approval this cycle, meaning the resilience framework's 31 March 2026 deadline arrives while these newly approved institutions are still working through their own licensing sequence. The deadline therefore functions as a compliance cliff that applies uniformly across the payments sector regardless of how recently an institution obtained its licence. #### Outlook The principal marker to watch is whether payment institutions, and particularly newly licensed non-bank entrants, demonstrate compliance with the framework's cyber-risk, governance, business-continuity, and incident-reporting requirements by the 31 March 2026 deadline. Confirmation of the primary SBP text for this framework, beyond the secondary reporting available this cycle, would also materially strengthen confidence in the finding's precise scope. Evidence 6 Sources and findings (6) - T3[https://www.mindofcyber.com/2025/10/05/cybersecurity-of-pakisthan/](https://www.mindofcyber.com/2025/10/05/cybersecurity-of-pakisthan/)retrieved 2026-07-04 - T2[https://www.dawn.com/news/1448345](https://www.dawn.com/news/1448345)retrieved 2026-07-04 - T2[https://www.brecorder.com/news/4652556](https://www.brecorder.com/news/4652556)retrieved 2026-07-04 - T2[https://www.dataguidance.com/news/pakistan-sbp-issues-circular-cyber-resilience-amid](https://www.dataguidance.com/news/pakistan-sbp-issues-circular-cyber-resilience-amid)retrieved 2026-07-04 - T3[https://photonews.com.pk/sbp-cyber-shield-strategy/](https://photonews.com.pk/sbp-cyber-shield-strategy/)retrieved 2026-07-04 - T2[https://thepaypers.com/payments/news/sbp-issues-guidelines-to-safeguard-banks-against-cyber-crimes](https://thepaypers.com/payments/news/sbp-issues-guidelines-to-safeguard-banks-against-cyber-crimes)retrieved 2026-07-04 ### W4Scheme & Network ComplianceConfirmedconfirmed 2026-07-04▾# 1LINK operates the dominant interbank switch, PCI DSS certified, connecting members to Visa/Mastercard/UnionPay/JCB; PayPak is PK's domestic scheme; 2016 card-security regulations mandate EMV. Standing sub-brief · as of 7 July 2026 115 words · last cycle 2026-07-04 #### Scheme & Network Compliance 1LINK, Pakistan's first fully licensed PSO/PSP since 2015, operates PayPak, the domestic card scheme launched in 2016, is PCI DSS certified, and connects member banks to Visa, Mastercard, UnionPay and JCB. This positions 1LINK as the central switch through which nearly all card-scheme compliance obligations flow for Pakistani issuers and acquirers. In December 2025, 1LINK secured Mastercard Card Personalization Bureau certification, supporting PayPak, Mastercard, UnionPay International, and co-badged card issuance for over ten banks, the most recent scheme-compliance development in the market. #### Outlook 1LINK's certification trajectory suggests continued consolidation of card-personalisation and bureau services under a single domestic switch; watch for whether additional international schemes seek similar co-badging arrangements through 1LINK. Read full sub-brief · 115 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T3[https://grokipedia.com/page/1link](https://grokipedia.com/page/1link)retrieved 2026-07-04 - T2[https://1link.net.pk/](https://1link.net.pk/)retrieved 2026-07-04 - T2[https://1link.net.pk/faqs](https://1link.net.pk/faqs)retrieved 2026-07-04 - T3[https://joshandmakinternational.com/payment-systems-and-electronic-fund-transfers-act-2007/](https://joshandmakinternational.com/payment-systems-and-electronic-fund-transfers-act-2007/)retrieved 2026-07-04 - T3[https://digitalpakistan.pk/1link-achieves-mastercard-card-bureau-certification/](https://digitalpakistan.pk/1link-achieves-mastercard-card-bureau-certification/)retrieved 2026-07-04 ### W5Payment Corridor DynamicsProbableconfirmed 2026-07-04▾# RDA anchors overseas-remittance corridors via correspondent banking; Raast beginning cross-border extension via NayaPay-Alipay+ QR interoperability. Standing sub-brief · as of 7 July 2026 119 words · last cycle 2026-07-04 #### Payment Corridor Dynamics The Roshan Digital Account, launched in September 2020, channels non-resident Pakistani inflows via correspondent banking arrangements, with deposits reaching over $5.2 billion by end-October 2022, making it the anchor mechanism for Pakistan's inbound remittance corridor. NayaPay partnered with Alipay+ in December 2025 to enable global QR-based payment acceptance, extending a domestic EMI's cross-border reach beyond its earlier Ant Group consumer-zone partnership announced in April 2024, signalling an emerging second wave of corridor development beyond the traditional correspondent-bank channel. #### Outlook Watch for whether NayaPay's Alipay+ interoperability is replicated by other EMIs or extended into Raast itself, which would mark a structural shift in how Pakistan's remittance corridors are built, away from correspondent-bank-only channels and toward QR-based interoperability. Read full sub-brief · 119 words no periodic updates on record for this sub-brief Evidence 6 Sources and findings (6) - T3[https://en.wikipedia.org/wiki/Roshan_Digital_Account](https://en.wikipedia.org/wiki/Roshan_Digital_Account)retrieved 2026-07-04 - T1[https://www.sbp.org.pk/rda/index.html](https://www.sbp.org.pk/rda/index.html)retrieved 2026-07-04 - T3[https://www.pakistanconsulateny.org/roshan-digital-accounts](https://www.pakistanconsulateny.org/roshan-digital-accounts)retrieved 2026-07-04 - T2[https://tribune.com.pk/story/2570322/sbp-to-use-raast-for-govt-payments](https://tribune.com.pk/story/2570322/sbp-to-use-raast-for-govt-payments)retrieved 2026-07-04 - T3[https://tracxn.com/d/companies/nayapay/__G2o0yIVhDANG_pkerCcfCBoCY664Oir9jqPYwy6-SqA](https://tracxn.com/d/companies/nayapay/__G2o0yIVhDANG_pkerCcfCBoCY664Oir9jqPYwy6-SqA)retrieved 2026-07-04 - T1[https://www.comcec.org/wp-content/uploads/2021/07/Pakistan-4.pdf](https://www.comcec.org/wp-content/uploads/2021/07/Pakistan-4.pdf)retrieved 2026-07-04 ### W6Industry Structure & Commerciallimited signalProbableconfirmed 2026-07-04▾# JazzCash/Easypaisa dominate mobile wallets; fragmented ~six-EMI cohort; fintech funding contraction (-31.5% YoY) alongside continued strategic bank-fintech investment. Standing sub-brief · as of 7 July 2026 125 words · last cycle 2026-09-05 #### Industry Structure & Commercial Dynamics JazzCash, operated by Mobilink Microfinance Bank, and Easypaisa, operated by Telenor Microfinance Bank, each have over 15 million active users, dominating Pakistan's wallet landscape ahead of a fragmented cohort of roughly six EMIs. That dominance sits against a contracting venture market: 2025 equity funding through November totalled only $5 million across three rounds, a 31.51% year-on-year drop from 2024, even as strategic investment continued, illustrated by VEON's $20 million injection into Mobilink Bank in January 2026 to support its Islamic banking expansion. #### Outlook The divergence between contracting venture funding and continued strategic bank-telco investment suggests consolidation around incumbent, balance-sheet-backed players rather than new entrant formation; watch for whether any of the six-EMI cohort's remaining pilot-stage entrants secure comparable strategic backing. Read full sub-brief · 125 words Periodic update · new data 2026-09-08 #### Industry Structure & Commercial Dynamics Pakistan Fintech Forum IV brought together the State Bank of Pakistan, the Securities and Exchange Commission of Pakistan, the Pakistan Digital Authority and the Pakistan Virtual Assets Regulatory Authority, signalling coordinated four-regulator engagement across the fintech and crypto perimeter. The notable structural development is that PVARA now sits alongside the three previously established payments-adjacent regulators on the national fintech policy stage, a visible sign that crypto-asset regulation has moved from a peripheral to a mainstream position within Pakistan's fintech regulatory architecture. At the same forum, the SBP Deputy Governor urged banks and fintechs to accelerate the expansion of digital credit, a public statement signalling continued regulator-level support for digital-financial-services growth rather than a retrenchment. Read together with the reported banking-access reversal for PVARA-licensed VASPs, this forum represents a coherent signal of a regulatory environment actively working to integrate crypto-adjacent fintech activity into the mainstream financial system rather than isolating it. Both findings from this forum are sourced from trade-press and industry-media reporting rather than official regulator communiques, and are assessed at Probable confidence. The forum itself, however, is a real convening event whose composition, four regulators appearing together, is itself the substantive structural signal, independent of the precision of the individual quotes attributed to participants. #### Outlook The signal to track next cycle is whether this four-regulator coordination produces a joint statement, memorandum of understanding, or coordinated rulemaking process, which would convert an observed convening pattern into a documented structural commitment. Absent such a follow-through document, the forum should be read as evidence of regulatory-level coordination intent rather than a confirmed institutional arrangement. Evidence 5 Sources and findings (5) - T3[https://impakter.com/how-pakistans-fintech-boom-is-changing-online-commerce/](https://impakter.com/how-pakistans-fintech-boom-is-changing-online-commerce/)retrieved 2026-07-04 - T3[https://tracxn.com/d/explore/fintech-startups-in-pakistan/__OOMGzIeyZYPyvEWpfn5a944aEy78_lJ8i3yxi2iu-K8](https://tracxn.com/d/explore/fintech-startups-in-pakistan/__OOMGzIeyZYPyvEWpfn5a944aEy78_lJ8i3yxi2iu-K8)retrieved 2026-07-04 - T3[https://www.fintechfutures.com/keyword/pakistan](https://www.fintechfutures.com/keyword/pakistan)retrieved 2026-07-04 - T3[https://tribune.com.pk/story/2580132/pakistans-fintech-bet-pays-off-in-a-new-era-for-south-asian-finance](https://tribune.com.pk/story/2580132/pakistans-fintech-bet-pays-off-in-a-new-era-for-south-asian-finance)retrieved 2026-07-04 - T3[https://profit.pakistantoday.com.pk/2025/12/10/mapping-emis-in-pakistan-since-2020-6-live-4-face-death-and-6-at-ipa-or-pilot](https://profit.pakistantoday.com.pk/2025/12/10/mapping-emis-in-pakistan-since-2020-6-live-4-face-death-and-6-at-ipa-or-pilot)retrieved 2026-07-04 ### W7Legal & LitigationProbableconfirmed 2026-07-04▾# SBP's quarterly enforcement-penalty disclosure practice and EMI licence-revocation precedents (TAG, Paymax, Careem) establish the litigation/enforcement baseline. Standing sub-brief · as of 7 July 2026 119 words · last cycle 2026-07-04 #### Legal & Litigation SBP imposed Rs465.08 million in penalties on 10 banks for the quarter ended 31 December 2023, including UBL at Rs114.19 million, Standard Chartered Pakistan at Rs58.38 million, and Mobilink Microfinance Bank at Rs14.64 million, for CDD/KYC, foreign-exchange, AML/CFT and branchless-banking violations; this remains the most recent quarterly enforcement disclosure surfaced this cycle. Separately, TAG's EMI licence was revoked by SBP after its attempted acquisition of Samba Bank collapsed, while Paymax requested closure in October 2023 and Careem withdrew its licence the same year. #### Outlook No more recent quarterly enforcement disclosure than the December 2023 data point has surfaced; watch for SBP's next published penalty round as a signal of whether enforcement intensity is increasing or steady. Read full sub-brief · 119 words no periodic updates on record for this sub-brief Evidence 3 Sources and findings (3) - T1[https://www.brecorder.com/news/40286427/enforcement-action-sbp-imposes-over-rs465mn-in-penalties-on-10-banks](https://www.brecorder.com/news/40286427/enforcement-action-sbp-imposes-over-rs465mn-in-penalties-on-10-banks)retrieved 2026-07-04 - T3[https://profit.pakistantoday.com.pk/2024/02/17/turkish-fintech-unicorn-papara-set-to-acquire-sadapay-in-possible-50mn-deal/](https://profit.pakistantoday.com.pk/2024/02/17/turkish-fintech-unicorn-papara-set-to-acquire-sadapay-in-possible-50mn-deal/)retrieved 2026-07-04 - T3[https://fafen.org/pvar-ordinance-is-crypto-now-legal-in-pakistan/](https://fafen.org/pvar-ordinance-is-crypto-now-legal-in-pakistan/)retrieved 2026-07-04 ### W8Merchant Acquiring & RiskProbableconfirmed 2026-07-04▾# Merchant acquiring runs through 1LINK's switch; government/SBP subsidise P2M Raast adoption against a >85% cash-based economy. Standing sub-brief · as of 7 July 2026 106 words · last cycle 2026-07-04 #### Merchant Acquiring & Risk A Rs3.5 billion subsidy programme, running from September 2025 through June 2026 as part of a three-year plan, has reimbursed merchants at 0.5% of P2M QR transaction value or Rs100, whichever is lower, in an economy where over 85% of transactions remain cash-based. That programme window has now lapsed as of this cycle's July 2026 retrieval date, with no confirmed follow-on phase. #### Outlook Whether the subsidy is renewed or converted into a permanent scheme will be a key determinant of merchant-acquiring penetration given the depth of the underlying cash-based economy; a published high-risk-MCC acquiring treatment schedule for Pakistani acquirers also remains unlocated. Read full sub-brief · 106 words no periodic updates on record for this sub-brief Evidence 3 Sources and findings (3) - T3[https://grokipedia.com/page/1link](https://grokipedia.com/page/1link)retrieved 2026-07-04 - T2[https://tribune.com.pk/story/2570322/sbp-to-use-raast-for-govt-payments](https://tribune.com.pk/story/2570322/sbp-to-use-raast-for-govt-payments)retrieved 2026-07-04 - T2[https://www.brecorder.com/news/40385692/pakistans-digital-transformation-sbp-plans-to-route-govt-payments-through-raast](https://www.brecorder.com/news/40385692/pakistans-digital-transformation-sbp-plans-to-route-govt-payments-through-raast)retrieved 2026-07-04 ### W9Product Innovation & Market DevelopmentConfirmedconfirmed 2026-07-04▾# SBP's April 2026 circular ends the 2018 blanket prohibition on bank-crypto dealing, creating Pakistan's first formal bank-to-VASP funding bridge, though banks remain barred from trading, holding or investing in crypto themselves and VASP accounts must be segregated PKR-only. Horizon · 2028 (± more than a year) SBP National Financial Inclusion Strategy target: 75% adult financial inclusion Adopted, not yet in force · Tier 3 source Horizon · 2028 (± more than a year) SBP National Financial Inclusion Strategy target: 75% adult financial inclusion Adopted, not yet in force · Tier 3 source Horizon · 2026-06 (± a quarter) Government full digitisation of payments target Proposed · Tier 4 source Standing sub-brief · as of 7 July 2026 111 words · last cycle 2026-10-25 #### Product Innovation & Market Development Raast, launched in January 2021 with P2P capability added in February 2022 and P2M/QR in March 2022, is the central pillar of Pakistan's digital payments infrastructure; SBP formalised the Raast Participation Criteria in February 2025, covering 44 onboarded entities. In parallel, SBP is piloting a Central Bank Digital Currency alongside the new virtual-asset regulatory framework, though pilot scope and timeline detail remain sparse in available disclosure. #### Outlook The next disclosure to watch for is scope and timeline detail on the CBDC pilot, alongside any expansion of Raast's Participation Criteria beyond the current 44 onboarded entities as adoption widens under the National Financial Inclusion Strategy's 2028 target. Read full sub-brief · 111 words Periodic update · new data 2026-10-25 #### Product Innovation & Market Development The State Bank of Pakistan unveiled the Pasban Remittance Reward Scheme, formalised under EPD Circular Letter No. 14 of 2026. The scheme is funded by an annual prize pool of PKR 16 billion, contributed by the Pakistan Banks Association rather than by the State Bank directly, and succeeds an earlier subsidised remitter-incentive arrangement. The first draw is scheduled for 15 January 2027 and will cover remittances sent through formal banking channels between October and December 2026. The scheme arrives against a backdrop of continued growth in formal inward remittance volume: Q1 of fiscal year 2027 recorded remittances of approximately 10.9 billion US dollars, an increase of roughly 14 percent year on year. The structural logic of a prize-draw incentive, funded collectively by the banking industry rather than subsidised directly from the public purse, represents a shift in how Pakistan's formal remittance channel competes for volume against informal transfer mechanisms, placing the cost of incentivisation on participating banks rather than on the state budget. #### Outlook The first draw of the Pasban Remittance Reward Scheme on 15 January 2027 will be the first concrete test of whether the new prize-based incentive structure produces a measurable effect on formal remittance volume relative to the 14 percent year-on-year growth already recorded in Q1 FY27 before the scheme's prize mechanism had taken effect. Whether the industry-funded model proves durable, or whether banks seek to renegotiate their contribution to the PKR 16 billion annual pool, is a secondary marker for the product's longer-term structure. 4 earlier distinct update(s) Periodic update · new data 2026-10-18 #### Product Innovation & Market Development The State Bank of Pakistan opened the second cohort of its Regulatory Sandbox on 2 October 2026, with applications open through 30 November 2026. The announced thematic scope covers artificial intelligence in financial services, payment innovations, and inward remittances, positioning the sandbox as the central near-term vehicle through which the State Bank intends to engage with next-generation financial-service proposals. This is a confirmed, directly dated development reported by the State Bank's own announcement. The sandbox's explicit inclusion of inward remittances alongside artificial intelligence and payments is notable for a jurisdiction where remittance inflows represent a structurally significant share of foreign-exchange receipts. A sandbox track oriented toward remittance innovation signals State Bank interest in exploring technology-driven improvements to a corridor that matters disproportionately to Pakistan's external accounts relative to many other sandbox jurisdictions' typical emphasis on domestic retail payments alone. The AI theme, separately, reflects a broader regional and global pattern of central banks opening experimental space for AI-driven financial products ahead of settling on codified supervisory treatment for such products. As with any sandbox cohort, the practical significance will depend on which applicants are selected and what products emerge from the cohort's operation, neither of which is yet known. The sandbox itself is an experimental, time-bound regulatory space rather than a market-wide product authorisation, so its immediate effect is confined to whichever participants are admitted following the 30 November 2026 application deadline. #### Outlook The selection outcome following the 30 November 2026 application deadline will be the next concrete marker, indicating which specific AI, payments, or remittance-innovation proposals the State Bank considers worth incubating. Given the remittance-corridor emphasis in the announced scope, a selected cohort with genuine remittance-technology participants would be a signal worth tracking for its potential effect on Pakistan's inward-remittance processing landscape. Periodic update · new data 2026-09-28 #### Product Innovation & Market Development Pakistan's instant-payments infrastructure continued to show rapid growth and liberalisation momentum this cycle. Raast, the State Bank of Pakistan's instant-payment rail, reportedly processed 742.1 million transactions worth Rs23.3 trillion in the January-March 2026 quarter, with digital-payments penetration reported at 92% of transactions nationally as of March 2026. This is a probable-confidence finding resting on a single, lower-tier source without independent corroboration this cycle, so the specific figures should be read as indicative of a strong growth trajectory rather than as fully verified statistics. A parallel government initiative reinforces the same liberalisation direction: the government mandated that all shops display QR codes and set a June 2026 deadline for full digitisation of government payments, explicitly targeting at least two million Raast person-to-merchant-enabled merchants. This is also a probable-confidence, single-source finding, but it is directionally consistent with the reported instant-payments growth and represents a concrete, dated policy target rather than an aspirational statement alone. Together, these developments point to sustained government and central-bank push toward ubiquitous digital and instant-payments acceptance at the merchant level in Pakistan. #### Outlook Independent corroboration of the reported Raast volume and penetration statistics, and visible progress (or slippage) against the June 2026 full-digitisation deadline for government payments and the two-million-merchant QR target, are the clearest markers to watch for continued liberalisation momentum in this module. Periodic update · new data 2026-08-25 #### Product Innovation & Market Development The Raast Participation Criteria, published by State Bank of Pakistan in early 2025, set functional and technical requirements for direct participation by banks, Electronic Money Institutions, Payment System Operators, and Payment Service Providers in SBP's real-time instant-payment system. This is a Probable-confidence finding, and its significance lies in extending Raast's access model beyond banks alone: a licensed EMI or PSO that meets the published functional and technical requirements can participate directly in the rail rather than relying solely on an indirect, bank-intermediated connection. This development sits alongside this cycle's licensing activity in a mutually reinforcing way: as SBP licenses additional non-bank EMIs and PSOs, such as Toko Lab, PayMob, and HubPay this cycle, the Raast Participation Criteria supply the technical pathway by which those newly licensed entities could seek direct rail access rather than remaining dependent on bank intermediation for instant-payment functionality. #### Outlook The marker to watch is whether any of this cycle's newly approved non-bank licensees, or other existing EMIs and PSOs, actually complete the process of becoming direct Raast participants under the published criteria, which would confirm that the criteria are producing real access changes rather than remaining a procedural formality. Periodic update · new data 2026-08-11 #### Product Innovation & Market Development The State Bank of Pakistan lifted its seven-year prohibition on bank-crypto dealings this cycle, issuing BPRD Circular Letter No. 10 of 2026 on 14 April 2026. The circular permits licensed banks to open and maintain accounts for virtual asset service providers holding a PVARA no-objection certificate or full licence, replacing the April 2018 directive that had barred such relationships outright. The permitted accounts are structurally narrow rather than a general opening: they must be segregated and PKR-only, and banks themselves remain barred from proprietary crypto trading or holding. This is rated High confidence, corroborated by multiple independent secondary outlets converging on the same circular number and date, though no primary State Bank circular text was retrieved verbatim this cycle. This is the first formal bank-to-VASP funding bridge Pakistan has had since the 2018 ban, and it is a product-innovation development in the sense that it creates, for the first time, a defined and licit path for fiat funds to move between the banking system and virtual-asset service providers operating under a PVARA licence or no-objection certificate. The bank-side and VASP-side halves of this bridge are both now defined: banks may hold segregated PKR accounts for licensed or NOC-holding VASPs, and VASPs inherit AML Act 2010 financial-institution status once PVARA's supervisory apparatus is operational. The bridge's terms leave open questions that this cycle's evidence does not resolve: how banks will conduct day-to-day due diligence on the VASPs they are now permitted to bank, whether the PKR-only and segregation requirements will be interpreted narrowly or broadly in practice, and how the arrangement interacts with the draft Pakistan Virtual Asset Services Regulations 2026 once finalised. These are the practical variables that will determine whether the bridge functions as a meaningful new product-development channel or as a narrow, lightly used exception. #### Outlook Watch for any supplementary SBP guidance clarifying account-administration practice under the new circular, and for whether the finalised Regulations, consultation closing 2 July 2026, impose additional bank-facing conditions on the VASP accounts the circular has newly permitted. The interaction between the banking-sector circular and the VASP-licensing statute is the single variable most likely to determine how much real product innovation this bridge enables versus how narrowly it remains confined to a small set of NOC-holding VASPs. Evidence 6 Sources and findings (6) - T3[https://en.wikipedia.org/wiki/Raast](https://en.wikipedia.org/wiki/Raast)retrieved 2026-07-04 - T1[https://www.sbp.org.pk/dfs/Raast-P2M.html](https://www.sbp.org.pk/dfs/Raast-P2M.html)retrieved 2026-07-04 - T2[https://profit.pakistantoday.com.pk/2025/02/22/sbp-sets-participation-criteria-for-raast-payment-system/](https://profit.pakistantoday.com.pk/2025/02/22/sbp-sets-participation-criteria-for-raast-payment-system/)retrieved 2026-07-04 - T3[https://fintechnews.ae/pakistan/](https://fintechnews.ae/pakistan/)retrieved 2026-07-04 - T3[https://issra.pk/insight/2026/adopting-cryptocurrency-in-pakistan-prospects-and-concerns/insight.php](https://issra.pk/insight/2026/adopting-cryptocurrency-in-pakistan-prospects-and-concerns/insight.php)retrieved 2026-07-04 - T2[https://cbpn.currencyresearch.com/blog/2026/01/23/pakistans-journey-toward-a-digital-payments-ecosystem](https://cbpn.currencyresearch.com/blog/2026/01/23/pakistans-journey-toward-a-digital-payments-ecosystem)retrieved 2026-07-04 ### W10Consumer Protection & APP FraudConfirmedconfirmed 2026-07-04▾# Tiered redress (CMU -> Sunwai -> Banking Mohtasib) with statutory backing; two-day cyber-fraud reimbursement mandate in force. Standing sub-brief · as of 7 July 2026 126 words · last cycle 2026-07-04 #### Consumer Protection & APP Fraud Banking Mohtasib Pakistan, an independent statutory ombudsman under the Federal Ombudsmen Institutional Reforms Act 2013, processed over 25,000 complaints and delivered Rs1.26 billion in monetary relief in 2023; escalation to the Mohtasib is available if a bank's Complaint Management Unit fails to resolve a complaint within 45 days, though microfinance-bank customers are excluded and must approach SBP directly. Banks and microfinance banks are separately required to compensate customers within two business days for verified cyber-fraud or online-banking-fraud losses, a direct APP-fraud reimbursement analogue to PSR-style rules seen elsewhere. #### Outlook The tiered CMU-to-Mohtasib redress structure appears stable; the more material open question is whether microfinance-bank customers' direct-to-SBP escalation route delivers comparable outcomes to the statutory ombudsman channel available to full bank customers. Read full sub-brief · 126 words no periodic updates on record for this sub-brief Evidence 6 Sources and findings (6) - T1[https://www.bankingmohtasib.gov.pk/](https://www.bankingmohtasib.gov.pk/)retrieved 2026-07-04 - T1[https://sunwai.sbp.org.pk/faq.html](https://sunwai.sbp.org.pk/faq.html)retrieved 2026-07-04 - T3[https://smartchoice.pk/blog/2022/01/the-banking-ombudsman-banking-mohtasib-of-pakistan/](https://smartchoice.pk/blog/2022/01/the-banking-ombudsman-banking-mohtasib-of-pakistan/)retrieved 2026-07-04 - T2[https://www.brecorder.com/news/4652556](https://www.brecorder.com/news/4652556)retrieved 2026-07-04 - T3[https://www.faysalbank.com/quick-links/complaint-lodgment-process](https://www.faysalbank.com/quick-links/complaint-lodgment-process)retrieved 2026-07-04 - T1[https://www.sbp.org.pk/cpd/cpd-com.asp](https://www.sbp.org.pk/cpd/cpd-com.asp)retrieved 2026-07-04 ### W11AML/CFT & Financial Crime1 gapSourced from Sentinel.gi ↗Probableconfirmed 2026-07-04▾# Pakistan exited the FATF grey list Oct 2022, remained off-list through Feb 2026 plenary and 19 June 2026 update; residual digital-wallet misuse risk flagged. Open gap — wpm-int-2 No W2/W8/W12 developments for PK found this cycle despite active search. Emerging-market payments infrastructure under-coverage persists; W2/W8/W12 thin for PK. Standing sub-brief · as of 7 July 2026 139 words · last cycle 2026-10-25 #### AML/CFT & Financial Crime This module is sourced from Sentinel.gi, the Financial Intelligence Monitor's illicit-finance feed, and is carried here as payments-context provenance rather than original illicit-finance analysis. Pakistan exited the FATF grey list in October 2022 and has remained off both the blacklist and grey list through the 19 June 2026 FATF list update, spanning six consecutive plenaries. Continuing reports of digital-wallet misuse by proscribed organisations, including Jaish-e-Mohammad, are flagged by Sentinel as touching Pakistan's 2018/2021 FATF commitments despite the grey-list exit; readers seeking the underlying illicit-finance assessment should consult the Sentinel feed directly. #### Outlook Pakistan's off-list status has now held for six consecutive plenaries; the residual digital-wallet-misuse signal is the item most likely to affect that status, and any deterioration would be expected to surface first in the Sentinel feed rather than in WPM's own payments research. Read full sub-brief · 139 words Periodic update · new data 2026-10-25 #### AML/CFT & Financial Crime Intelligence fed through the Sentinel channel reports that the Federal Investigation Agency traced transactions exceeding PKR 119.93 billion in gambling-application-linked flows moving through mobile-wallet payment aggregators operated by JazzCash and Easypaisa. More than one hundred JazzCash aggregator accounts were closed following FIA notices, with some reporting putting the figure as high as three hundred, and Easypaisa aggregator and merchant settlements were delayed. This finding is attributed to the Sentinel feed and is surfaced here as the financial-crime dimension of the same enforcement action discussed under licensing and market access; the underlying illicit-finance analysis, including the gambling-sector context and any crypto-layering dimension, is not re-analysed here and belongs to dedicated illicit-finance monitoring. For payment institutions and e-money institutions operating aggregator models with exposure to Pakistani payment corridors, this development is relevant primarily as a reminder that mobile-wallet aggregator channels are an active surface for law-enforcement referral in Pakistan, and that such referrals can translate directly into account-level closures at the operator level without an intervening public enforcement notice from the financial regulator itself. #### Outlook The principal marker to watch from a financial-crime perspective is whether any further account closures or aggregator-level restrictions follow at JazzCash, Easypaisa, or other mobile-wallet operators as the Federal Investigation Agency's investigation proceeds. Readers seeking deeper analysis of the illicit-finance mechanism itself, including any crypto-asset or layering dimension referenced in connection with this investigation, should consult dedicated illicit-finance coverage; this module's treatment is limited to the financial-crime signal as it bears on payment-system risk. Evidence 8 Sources and findings (8) - T3sentinel.pjlaw.com.pk/v4i3-108-116 - T?FIM (sentinel.gi) per-JID baseline profile — Pakistan — Pakistan operates under the Anti-Money Laundering Act 2010 (as amended), with the Financial Monitoring Unit (FMU) as FIU, State Bank of Pakistan and SECP as sectoral AML/CFT supervisors, and a 2025-created Pakistan Virtual Assets Regulatory Authority (PVARA) for crypto. Delisted from FATF grey list October 2022; remains in APG enhanced follow-up on residual technical-compliance gaps. - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: sourcing-thinness - T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: Government of Pakistan (Prime Minister-chaired Task Force, incl. national AML/CFT authority) — Migrant-smuggling financial networks - T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-001) — Sanctions: OFAC listing - T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-001) — Enforcement: OFAC (U.S. Department of the Treasury) — Imran Asghar (Pakistani national, linked to Arkan Mars Petroleum DMCC) - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: enforcement-absence - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure ### W12Correspondent Banking, Settlement & AccessProbableconfirmed 2026-07-04▾# PRISM RTGS (since 2008) with 1LINK as special participant; RDA correspondent-fee arrangements; FATF-history-linked de-risking exposure flagged as a live vulnerability. Standing sub-brief · as of 7 July 2026 138 words · last cycle 2026-07-04 #### Correspondent Banking, Settlement & Access PRISM RTGS Rules 2008, issued under the Payment Systems and Electronic Fund Transfers Act 2007, established Pakistan's real-time gross settlement mechanism; 1LINK has served as a special participant for electronic clearing settlement since July 2018. This bank-centred settlement architecture sits against a structural access asymmetry that is the module's analytical spine: non-bank EMIs settle through sponsor banks rather than holding direct RTGS access. Commentary warns that renewed FATF pressure could damage Pakistan's correspondent banking relationships and jeopardise the IMF Extended Fund Facility given its own AML/CFT conditionalities, a structural vulnerability that compounds the existing bank-versus-non-bank access divide. #### Outlook The correspondent-banking de-risking exposure flagged this cycle is the module's central watch item; any deterioration in Pakistan's FATF-adjacent standing would be expected to widen, rather than narrow, the settlement-access gap between bank and non-bank participants. Read full sub-brief · 138 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.comcec.org/wp-content/uploads/2021/07/Pakistan-4.pdf](https://www.comcec.org/wp-content/uploads/2021/07/Pakistan-4.pdf)retrieved 2026-07-04 - T3[https://grokipedia.com/page/1link](https://grokipedia.com/page/1link)retrieved 2026-07-04 - T1[https://www.sbp.org.pk/rda/index.html](https://www.sbp.org.pk/rda/index.html)retrieved 2026-07-04 - T3[https://www.mondaq.com/money-laundering/1808758/out-of-the-shadows-but-watching-the-fatf-horizon-pakistan-fatf-and-the-ever-present-risk-of-the-grey-list](https://www.mondaq.com/money-laundering/1808758/out-of-the-shadows-but-watching-the-fatf-horizon-pakistan-fatf-and-the-ever-present-risk-of-the-grey-list)retrieved 2026-07-04 - T3[https://www.sc.com/pk/save/roshan-digital-account/](https://www.sc.com/pk/save/roshan-digital-account/)retrieved 2026-07-04 ### W13Commercial Intelligence (M&A, Investment & Product)limited signalProbableconfirmed 2026-07-04▾# Virtual-asset market entry (Binance/HTX NOCs, MoF-Binance tokenisation MoU), continued strategic bank-fintech investment (VEON-Mobilink), new digital-bank entrant (Mashreq), and a16z-led ZAR stablecoin raise dominate commercial activity amid overall funding contraction. Standing sub-brief · as of 7 July 2026 213 words · last cycle 2026-10-18 #### Commercial Intelligence (M&A, Investment & Product) VEON invested $20 million in Mobilink Bank in January 2026 to support the microfinance bank's Islamic banking expansion, a strategic telco-into-bank investment continuing the consolidation trend visible in the broader market. Andreessen Horowitz led a $12.9 million funding round for ZAR, a Pakistani startup developing a dollar-backed stablecoin designed for mass adoption through retail agents and kiosks, a landmark stablecoin-focused venture round amid an overall fintech funding contraction. Mashreq launched its full-service digital retail bank, Mashreq Bank Pakistan, in Islamabad in September 2025, marking a foreign-bank digital entrant into Pakistan's licensed digital-bank cohort. The Ministry of Finance signed a memorandum of understanding with Binance in December 2025 to explore tokenisation initiatives covering up to $2 billion in state-owned assets, alongside PVARA issuing preliminary no-objection certificates to Binance and HTX; the value of the collapsed TAG-Samba Bank acquisition attempt was not publicly disclosed, and this MoU likewise is not yet a binding transaction, its status remaining exploratory and preliminary. #### Outlook Virtual-asset market entry, via the Binance/HTX preliminary NOCs and the Ministry of Finance tokenisation MoU, together with the a16z-led ZAR stablecoin raise, dominate the trailing-twelve-month commercial picture; watch for whether the MoF-Binance exploration converts into a binding tokenisation transaction and whether further foreign-bank digital entrants follow Mashreq's lead. Read full sub-brief · 213 words Periodic update · new data 2026-10-18 #### Commercial Intelligence & Fintech Two discrete commercial developments mark Pakistan's digital-asset sector this cycle. Binance and HTX are reported to be continuing their progression toward full virtual-asset-service-provider licensing under PVARA, building on no-objection certificates received in December 2025. Separately, PVARA has disclosed exploratory engagement with Pakistan's Ministry of Finance on sovereign debt tokenization, specifically proposals for digital Eurobond issuances and tokenization of Naya Pakistan Certificates. The Binance and HTX progression is a specific, named commercial event rather than a structural market-wide trend: these are two identified exchange operators moving through a defined regulatory pathway, from no-objection certificate to full licence, within PVARA's established framework. No financial terms or transaction values have been publicly disclosed in connection with this progression, and no primary filing from either exchange has been independently retrieved; the finding rests on consistent secondary reporting describing their regulatory status. The sovereign debt tokenization disclosure is a distinct and arguably more structurally significant development, since it involves a state actor, the Ministry of Finance, directly exploring digital-asset infrastructure for public-debt instruments in partnership with the virtual-asset regulator. This is described as exploratory rather than committed: no issuance timeline, instrument structure, or transaction value has been disclosed, and the finding should be read as a disclosed area of interest rather than an active government debt-tokenization programme. #### Outlook The Binance and HTX licensing progression should be watched for confirmation of actual full-licence issuance, which would be the clearest marker of PVARA's licensing pathway functioning in practice for internationally active exchange operators. The sovereign debt tokenization exploration with the Ministry of Finance remains at an early, undisclosed-terms stage, and its next marker would be any public confirmation of a concrete issuance structure or pilot transaction, neither of which has yet been reported. 1 earlier distinct update(s) Periodic update · new data 2026-10-11 #### Commercial Intelligence & Fintech Pakistan's Q3 2026 fintech funding activity was dominated by a single large, foreign-domiciled deal. Reported total Pakistani startup funding for the quarter reached USD 74.7 million across five deals, with Fasset, a UAE-headquartered crypto and tokenisation platform carrying a substantial Pakistan user base, accounting for an estimated 91 percent of that total through a USD 68 million Series C round at a USD 1 billion post-money valuation. Fasset itself is incorporated in the United Arab Emirates rather than Pakistan, meaning the round is a Pakistan-relevant commercial event by virtue of the platform's user base and market exposure rather than a Pakistan-domiciled transaction in the formal sense; lead-investor identities for the round were not disclosed in the reporting available. A smaller, domestically domiciled development also surfaced this quarter. Qist Bazaar, a buy-now-pay-later fintech operating in Pakistan, raised PKR 500 million, approximately USD 1.8 million, through a privately placed, unrated Sukuk instrument, reported as the first tranche of a planned recurring institutional-debt programme. This is a debt-capital event rather than an equity funding round, and represents a materially smaller commercial development than the Fasset round, but is notable as a domestically structured Islamic-finance debt instrument being used for fintech capital-raising. The concentration of this quarter's reported funding total in one large, foreign-domiciled, crypto-adjacent round rather than across a broader base of domestic fintech companies is itself a market-structure signal: Pakistan's reported fintech investment activity this quarter was not broad-based, and the headline total figure should be read with that concentration in mind. #### Outlook Whether Q4 2026 funding activity broadens beyond a single dominant round, and whether Qist Bazaar's planned recurring Sukuk programme proceeds to a second tranche, are the near-term questions for Pakistan's fintech commercial-intelligence picture. Evidence 7 Sources and findings (7) - T3[https://www.fintechfutures.com/keyword/pakistan](https://www.fintechfutures.com/keyword/pakistan)retrieved 2026-07-04 - T3[https://tribune.com.pk/story/2580132/pakistans-fintech-bet-pays-off-in-a-new-era-for-south-asian-finance](https://tribune.com.pk/story/2580132/pakistans-fintech-bet-pays-off-in-a-new-era-for-south-asian-finance)retrieved 2026-07-04 - T3[https://fintechnews.ae/pakistan/](https://fintechnews.ae/pakistan/)retrieved 2026-07-04 - T2[https://www.dawn.com/news/1961913](https://www.dawn.com/news/1961913)retrieved 2026-07-04 - T3[https://tracxn.com/d/companies/nayapay/__G2o0yIVhDANG_pkerCcfCBoCY664Oir9jqPYwy6-SqA](https://tracxn.com/d/companies/nayapay/__G2o0yIVhDANG_pkerCcfCBoCY664Oir9jqPYwy6-SqA)retrieved 2026-07-04 - T3[https://www.fintechfutures.com/keyword/pakistan](https://www.fintechfutures.com/keyword/pakistan)retrieved 2026-07-04 - T3[https://tracxn.com/d/explore/fintech-startups-in-pakistan/__OOMGzIeyZYPyvEWpfn5a944aEy78_lJ8i3yxi2iu-K8](https://tracxn.com/d/explore/fintech-startups-in-pakistan/__OOMGzIeyZYPyvEWpfn5a944aEy78_lJ8i3yxi2iu-K8)retrieved 2026-07-04 No modules match. Filters combine as OR inside a group and AND across groups. Reset all filters ## Provenance and declared absence Disclosure model: module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. Sentinel-fed modules receive no special rendering treatment. sentinel_feed is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. Family taxonomy is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. Suppressed by doctrine: derived risk score; per-module RAG traffic light. Not shown on this page. 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