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The wait is officially over for the crypto industry in Pakistan. The Pakistan Virtual Asset Regulatory Authority (PVARA) has formally opened applications for No Objection Certificates (NOCs) for Virtual Asset Service Providers (VASPs).
This development follows the enactment of the PVARA No Objection Certificate Regulations 2025, which came into force earlier this week on December 2, 2025. The authority is now assessing applications on a rolling basis, marking a massive shift toward a regulated digital asset ecosystem in the country.
PVARA has formally opened NOC applications for crypto exchanges, effective 2nd December. Applications are being received and assessed on a rolling basis as part of Pakistan’s ongoing digital asset regulatory rollout.
All applicable regulations, eligibility criteria, and…
— Pakistan Crypto Council (@cryptocouncilpk) December 8, 2025
If you are a crypto exchange or service provider looking to operate in Pakistan, here is everything you need to know about the new framework.
PVARA: The Gateway to Licensing
The issuance of an NOC is now the mandatory first step for any VASP seeking to operate locally. Securing this certificate grants an applicant two critical permissions:
- Approval for AML Registration on the Financial Monitoring Unit’s (FMU) goAML portal.
- Permission to incorporate a local entity within Pakistan.
This creates a “phased regulatory pathway”. Once an applicant receives the NOC and completes registration, they can provide specific “AML-Registered Services” even before obtaining a full license.
However, this privilege applies strictly to four specific service categories:
- Broker-Dealer Services
- Custody Services
- Exchange Services
- Virtual Asset Derivative Services
Strict Governance & “Fit & Proper” Standards
PVARA has set a high bar for leadership and governance. Applicants must maintain a robust team of “Key Individuals”, including a CEO, CFO, Compliance Officer, and a Money Laundering Reporting Officer (MLRO).
Crucially, all Key Individuals must pass strict “Fit and Proper” standards regarding their integrity, competence, and financial soundness. The Authority explicitly disqualifies anyone convicted of financial offences, fraud, or those subject to bankruptcy proceedings.
Furthermore, PVARA keeps a close watch on ownership. Any person holding 20% or more of the voting power or share capital is classified as a “Controller” and must also be approved.
Heavy Focus on AML Compliance by PVARA
To secure an NOC, applicants must prove they have a fully operational Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) framework.
Your compliance systems must be ready from day one. The regulations require:
- Real-time Monitoring: Systems capable of detecting suspicious activity in real-time or near real-time.
- Sanctions Screening: Immediate screening of all customers against domestic and UN sanctions lists.
- Data Retention: All AML/CFT records must be stored securely for a minimum of seven years.
- No Outsourcing Core Functions: You generally cannot outsource critical duties like MLRO responsibilities or transaction monitoring. PVARA requires you to keep these “AML-critical functions” in-house to ensure effective oversight.
The Application Timeline
The process is designed to be efficient but thorough. Applicants must submit Form A1 along with supporting documentation, such as their AML policies and financial statements.
Once you submit your application, PVARA has committed to issuing a decision, either granting the NOC or refusing it, within 60 calendar days.
Successful applicants must then move quickly. You will need to incorporate your local company and eventually submit a full licensing application within three months of the future VASP licensing regulations being promulgated.
All forms and detailed regulations are available on the official PVARA website.
