How We Work

From Market Entry to Long‑Term Legal Partnership

We support fintechs and financial businesses throughout their lifecycle, combining commercial advice, regulatory expertise and dispute resolution under one roof.

Many of our clients are already licensed in another jurisdiction, such as the UAE, Hong Kong, China, the European Union or the United Kingdom. We act for them before a Pakistani licence plan exists, during an application, and after a licence has been granted. One team stays on the matter from planning through to supervision.

Turnkey Solutions Market entry and licensing
Retainer & Commercial Advisory Continuing and standalone counsel
Integration Banks, payment rails, APIs and cross-platform integration partnerships
Regulatory Compliance & Supervision Post-licence support and compliance

Market entry and licensing

Turnkey Solutions

SSA takes a business from the decision to enter Pakistan to a licensed, operating company. We decide which licence the product needs, structure who owns and controls it, and run the application through every approval stage.

Most clients instruct from outside Pakistan, with a product built for another market. We establish which Pakistani licence it needs before anything is filed, because the wrong choice means an unsuitable entity or capital base, or a launch the regulator later treats as outside the licence.

Discuss Your Market Entry

Scope of the Mandate

Perimeter and Route

We map which parts of the product need a licence, from which regulator, and whether one entity can hold them. The answer sets the capital, the timeline and who approves the launch.

Sponsors and Structure

We structure who owns and controls the licensed company, and how a foreign parent holds it. Regulators test every sponsor, director and key executive, so we settle the structure before incorporation.

The Application Case

We build the business plan and financial model to hold up under scrutiny, and align the policies, architecture and governance behind them so that every document says the same thing. Inconsistency between documents is what draws observations.

Approval Stages

We take each licence through its stages, and stay on the file through observations, pilot conditions and the final licence, not only to submission.

Fintech Models We Take Through

We start from how the product operates, because that decides the licence, and one product can fall under more than one regulator.

Digital Lending and Nano Loans
- SECP
We settle the lender of record, who owns the customer, and app review before launch.
Buy Now, Pay Later and Device Financing
- SECP
We structure where title and the financing sit, dealer collections, device locking and vendor exposure.
Earned Wage Access
- SECP
We determine whether the advance is a loan, and how repayment runs through the employer’s payroll.
Wallets and E-Money
- SBP
We set up customer money in bankruptcy-remote trust accounts, and take technology and outsourcing through review before the pilot.
Payment Gateways and Acquiring
- SBP
We design scheme and settlement, draft participant agreements and meet data residency rules.
Virtual Asset Exchanges and Custody
- PVARA
- FMU
We structure on and off ramps, custody architecture, Travel Rule screening and segregated client assets.
Stablecoins and Crypto-Linked Cards
- PVARA
- SBP
We establish whether a pegged token may be issued, and how a crypto card spans virtual asset, banking, foreign exchange and anti-money laundering law.
Embedded Finance and Bank Partnerships
- SECP
- SBP
We settle who holds the licence, the customer and the data, and what the licensee may outsource.

Super Apps and Multi-Licence Groups

Many of our clients are building one product on several licences: a wallet with lending, a payment application with an exchange, a bank with embedded partners. SSA designs the group as a whole. We decide which entity holds which licence, how customer data and funds move between them, and how each regulator’s conditions apply to the shared platform.

The Entity Map

Which activity sits in which licensed company, what must stay separate, and where the group can share a function.
The Shared Platform

One application and one customer relationship across several licences, with consent, data and disclosures handled consistently for each.
Flows Between Entities

Intra-group funding, fee sharing and outsourcing between licensees, with the approvals each of them needs.
Sequencing

Applications filed in an order that keeps each regulator’s file consistent with the others, and with what the group tells its home regulator.

Pakistani Licences We Take Clients Through

For each licence we prepare the filings, manage the regulator’s review and carry the file through every stage.

Licence	How it runs	What decides it
NBFC SECP	No-objection certificate, incorporation, then the licence. Each lending app also clears SECP’s app review.	Sponsor strength, fit and proper approval of directors and key executives, and a lending model the policies support
Electronic Money Institution SBP	In-principle approval, a pilot, then the final licence	Paid-up capital, a security deposit with the State Bank, trust accounts for customer funds, and the technology and outsourcing framework
PSO / PSP SBP	In-principle approval, a pilot, then final authorisation under the PSO/PSP Rules 2014	Capital, scheme and settlement design, data residency, and merchant and participant agreements
Digital Bank SBP	Staged licensing under SBP’s digital bank framework, for new sponsors and for EMIs, microfinance banks and banks converting	Sponsor track record, technology and risk capability, and whether the business is new or a conversion
Microfinance Bank SBP	Five stages: no-objection certificate, incorporation, licence, commencement of business and first branch	The entry route, the capital tier, and how sponsor shares are held
Virtual Assets PVARA	Application through PVARA’s portal, with a sandbox route for novel products	The licence category, a Pakistani company, capital and financial resources, safeguarding of client assets, AML/CFT readiness and banking access for client money

International Licences and Their Pakistani Counterparts

Business	Pakistan	United Arab Emirates	Hong Kong	European Union	United Kingdom
Lending	NBFC licence (SECP)	Finance company licence (CBUAE)	Money lender licence (Licensing Court)	National consumer credit licence	FCA consumer credit authorisation
Wallets and e-money	Electronic Money Institution (SBP)	Stored value facility (CBUAE)	Stored value facility licence (HKMA)	E-money institution (national authority)	Authorised e-money institution (FCA)
Payments	PSO / PSP authorisation (SBP)	Payment service provider licence (CBUAE)	Designated payment system or stored value licence (HKMA)	Payment institution (national authority)	Authorised payment institution (FCA)
Digital banking	Digital bank licence (SBP)	Bank licence (CBUAE)	Virtual bank licence (HKMA)	Credit institution authorisation (ECB or national authority)	Bank authorisation (PRA and FCA)
Virtual assets	VASP licence (PVARA)	VASP licence (VARA in Dubai, FSRA in Abu Dhabi)	VATP licence (SFC)	Crypto-asset service provider authorisation under MiCA	Cryptoasset registration (FCA)

Continuing and standalone counsel

Retainer & Commercial Advisory

SSA acts as outside counsel to licensed fintech businesses once the licence is granted. We keep you informed of regulatory change, build and maintain your compliance framework, and handle the contracts and decisions that arise as the business runs.

A retainer is one way to engage us, and it is not required. It works because we already know the licence, the product and the contracts. We check each new partner, price change or clause against the licence conditions before anyone commits. A single mandate gives you the same team for one transaction or one regulatory question.

Discuss Ongoing Counsel

What the Retainer Covers

We act across every regime we work in, for the licence you hold. Litigation, court and tribunal appearances and complex cross-border transactions are engaged separately.

Regulatory Updates

We tell you what changed and what to do about it.

New circulars, directives and rule changes reviewed as they issue
The policies and procedures that must change, and by when
Briefings whenever a development affects your business

Compliance Framework

We build the framework and keep it current.

Anti-money laundering and counter-terrorist financing
Data protection and privacy
Labour law compliance
Corporate governance and board practice

Contracts & Negotiation

We handle the legal work of running the business day to day.

Drafting, vetting and review of contracts with partners, vendors, banks and agents
Negotiation with counterparties, with the licence conditions in view
Amendments and renewals as commercial terms change

Product Expansion

We answer whether it needs approval before it goes live.

New products, prices, partners and model changes
Expansion into new services, such as escrow, inward remittance or API integrations
Company formation and related projects

Ownership & Corporate Matters

We keep the corporate record in step with the licence.

Capital raises, share transfers and group restructurings
Incoming shareholders and controllers, with approval timed before closing
Board and shareholder resolutions, appointments and constitutional documents

Workforce Management

We protect the business in how it hires and runs its team.

Employment agreements with data protection, confidentiality, work-product and non-compete terms
Code of conduct and whistleblowing arrangements
Staff and key-role appointments checked against licence requirements

Licensed Business on Retainer

Documents We Draft

Among other things, we draft the documents a licensed fintech business runs on, each set against the conditions of its licence.

Agreements

We draft and negotiate the contracts a licence depends on.

Card scheme and payment network participation
Escrow and trust account
Remittance
Co-lending and receivables purchase
Banking-as-a-service and embedded finance partnership
Liquidity provider and market maker
Custody and sub-custody
Stablecoin issuance, reserve and redemption

Technology and Vendor Agreements

We contract the systems and providers the business runs on.

Hosting, software licence and application programming interface integration
Source code ownership and work-for-hire terms
Service levels and downtime
Outsourcing and business process outsourcing
Telecom and bank partner agreements

Terms and Conditions

We write what customers and merchants agree to.

Wallet and account terms
Credit facility and instalment terms
Exchange and custody terms of service
Merchant terms of participation
Fee schedules and key facts statements
Terms of use with privacy notices

Policies

We draft the policies the regulator expects to see.

Compliance policy and manual
Anti-money laundering and counter-terrorist financing
Risk management
Customer onboarding
Consumer protection and grievance redressal
Information security and data privacy
Corporate governance framework

Employment Documents

We protect the business in how it hires.

Employment agreements with data protection, confidentiality, work-product and non-compete terms
Code of conduct
Whistleblowing policy

Corporate Approvals

We paper the decisions the licence requires.

Board and shareholder resolutions for filings, appointments and capital actions
Constitutional documents aligned to the licensed activities
Director and executive appointment files with committee charters

Licensing Documentation

We prepare what the regulator reads first.

Business plans and financial models
Sponsor and director fit and proper filings
Governance and organisation documents
Preparation papers for regulator interviews

Regulatory Submissions

We write to the regulator on the client’s behalf.

Responses to observation letters
Approval requests for products, apps, directors and shareholding changes
Foreign exchange loan requests
Special-case requests

Opinions and Notices

We put our advice and the client’s position in writing.

Opinions on regulatory treatment
Memoranda on partnership and product structures
Legal notices and replies
Settlement documents

Banks, payment rails, APIs and cross-platform integration partnerships

Integration

SSA puts a licensed business’s financial and technology infrastructure into operation: the banks, payment networks and technology providers it depends on, and the contracts between them, from planning through deployment.

A licence is one part of a working fintech business. Our lawyers build the legal framework around it, and our ecosystem and integrations team carries the approved business plan through to operational readiness. That team has set up the operating systems of large fintech companies in Pakistan from scratch.

Discuss Your Integration

The Ecosystem Around a Licence

We build the systems, banks, channels and teams a licence depends on, as part of the mandate.

Technology Partners

We connect the systems a licence needs before it can trade.

Vendor and platform selection
Processor and gateway integrations
Integration scoping and testing

Payment Gateway Solutions

We set up where customer and merchant money sits, and how it moves.

Collection and settlement accounts
Safeguarding and trust structures for customer funds
Fund paths with licensed institutions

Telecom & AI Aggregation

We arrange the channels through which a business reaches its customers.

Enterprise notifications
OTP and SMS
Voice lines

Cross Platform Integrations

We source and contract the institutions and providers a business sits beside.

Banks and licensed financial institutions
Fintechs and payment service providers
Distribution and merchant partners

Operational Readiness

We stand up the working business a licensed company runs on once approval is in hand.

Operating systems from the first day
Local management and compliance teams
Premises, staffing and reporting workflows for the pilot

Cross Border Architecture

We run a Pakistani business for a group that sits elsewhere.

Intra-group service and technology agreements
Transfers of staff and functions between group entities
Coordination across markets and languages

Licensed Fintech Business or Group

Integration Starts Before the Licence

Stage One

Exploring Pakistan

Before a licence plan exists, we map the banks, partners and channels a business would depend on, alongside the route and the structure.
Stage Two

Applying for a Licence

We identify partners and scope integrations while the regulator reviews the file, so that contracts do not delay the pilot.
Stage Three

Already Licensed

We keep partners, integrations and the local team in step with the business, and execute each new product.

Post-licence support and compliance

Regulatory Compliance & Supervision

SSA keeps licensed businesses in good standing with their regulators. That means dealing with the regulator directly, getting approvals before changes take effect, and running the continuing obligations of the licence.

A licence carries conditions that continue after it is granted, and regulators treat a missed approval or a late return as a supervisory matter. We map each client’s obligations and approval triggers from the day the licence is granted, so that the business knows what must be approved before it acts.

Discuss Your Supervisory Position

Supervisory Engagement

Inspections and Observations

We respond to inspection findings and observation letters against what the licence file already says, so the business does not contradict its own filings.

Representation Before the Regulator

SSA acts for the client in applications, clarifications and meetings with SECP, SBP and PVARA, from first filing to decision.

Interpretation and Regulatory Change

Circulars and licence conditions often leave open whether an activity needs approval. We give a reasoned position the client can act on, and put unsettled points to the regulator before the business relies on them. When a rule changes, we say what it means and what must be done by when.

Remediation

After an inspection the business has to show the fix. We agree the remedial plan with the client, test it against the licence file, and follow it to closure with the regulator.

When a Finding Escalates

If an inspection finding becomes a show-cause notice or a penalty proceeding, the same team continues under Financial Crime, AML & Enforcement Proceedings, with the full file in hand.

Going Live Under the Licence

Once approval is in hand, we set the business up to run to the regulator’s standards from its first day of operation.

Commencement Readiness

We put the approved framework to work on the first day.

Approved policies and controls deployed
Complaints mechanism and record-keeping in place
Website and app statements aligned to the licence scope

Go Live Plan

We plan for the launch going wrong.

Contingency measures and rollback strategy
Incident management after launch

Compliance Reporting

We set the regulator’s calendar for the business.

Monthly, quarterly, annual and event-based reports
Templates and internal workflows
Responsibilities and sign-off chains

Regulatory Change Adoption

We set up where customer money sits and how it is checked.

Trust, escrow or client money accounts as the regime requires
Reconciliation procedures
Bank accounts the licence requires

Customer Disclosures

We finalise what customers see before they transact.

Account or wallet terms and conditions
Privacy policy, pricing and fees
Complaints process and error resolution

Regulatory Audit

We prepare the file the regulator will ask for.

Inspection-readiness binder
Compliance registers and operational records
Support for the first supervisory review

Licence Granted

Keeping the Licence in Good Standing

We run the continuing obligations the licence carries, from anti-money laundering controls and customer funds to reporting and approval of change.

Conditions of the Licence

We track what the licence requires once it is granted.

Capital and minimum equity kept at the licence requirement
Customer and client money safeguarded in trust or segregated accounts
Key roles filled, with compliance, risk and audit functions working

Anti-Money Laundering & Counter-Terrorist Financing

We build and test the controls every licensed business must run.

Customer due diligence, and enhanced due diligence as risk changes
Sanctions screening, and Travel Rule procedures for virtual assets
Transaction monitoring and suspicious transaction reporting through goAML
Compliance officer and MLRO appointments and training
Periodic testing of the controls

Consumer Protection & Complaints

We make sure customers are told, heard and treated fairly.

Charges, key facts and terms disclosed before a customer commits
Complaint handling with escalation and response periods
Fair conduct in collections and recovery
Consent and privacy for customer data
Website, app store listings and marketing reviewed against transparency standards

Technology, Data & Outsourcing

We keep systems and vendors within the regulator’s expectations.

Information security and technology risk controls
Cybersecurity and operational controls tested periodically
Incident reporting and business continuity testing
Vendor due diligence, outsourcing oversight and data residency

Approval Before Change

We obtain approval where acting first would itself be the breach.

New directors and key executives, after fit and proper review
Share transfers and new equity at sponsor or controlling level
New products, apps and changes to the business model
Expansion into new services, with the approval it needs

Reporting & Audit

We prepare what goes to the regulator on its calendar.

Periodic returns and event-based notifications
Audited accounts and internal audit
Inspections and post-authorisation audits met from an updated file
Reports to the Financial Monitoring Unit
Policies and procedures updated when a circular changes the rule

Licensed Fintech Business

Pakistani Regulators and Their Instruments

SECP

NBFCs, including digital lending and BNPL

NBFC (Establishment and Regulation) Rules 2003
NBFC and Notified Entities Regulations 2008
SECP Circular No. 12 of 2024, Requirements for NBFCs engaged in Digital Lending
SECP Circular No. 14 of 2024, Self-Assessment Declaration for Digital Lending App Whitelisting

SBP

EMIs, PSO/PSPs, microfinance banks and digital banks

Payment Systems and Electronic Fund Transfers Act 2007
PSO/PSP Rules 2014
Regulations for Electronic Money Institutions
Microfinance Institutions Ordinance 2001
Licensing and Regulatory Framework for Digital Banks

PVARA

Virtual asset service providers

Virtual Assets Act 2026
Pakistan Virtual Asset Services Regulations, 2026
Pakistan Virtual Asset Activity Specific Regulations, 2026

Across Regimes

The FMU, company law and foreign exchange

Companies Act 2017
Anti-Money Laundering Act 2010
Foreign Exchange Regulation Act 1947

Available at any stage, or independently

Financial Crime, AML & Enforcement Proceedings

SSA represents financial businesses in financial crime and anti-money laundering investigations, regulatory enforcement, cybercrime proceedings and the disputes that follow. It can be engaged at any stage, or independently.

Fintech disputes rarely stay in one forum. A settlement dispute can become a regulatory inquiry, and a data incident can become a cybercrime complaint. We hold the licence work, the regulatory position and the commercial contracts, so a position taken in one forum is taken with the others in view.

Discuss a Proceeding

Types of Matter

Regulatory Enforcement

We represent the business in inspection findings, show-cause notices and penalty proceedings before the SECP, the State Bank and PVARA, and in appeals against their orders. We weigh each step against the licence and the business’s standing with its regulator.

Financial Crime and AML Investigations

We act in inquiries into fraud, money laundering and other financial offences, including suspicious transaction reports, frozen accounts and the transaction flows behind them, from the first notice through any proceedings.

Cybercrime Proceedings

We act in complaints and defence under the Prevention of Electronic Crimes Act 2016, including electronic fraud, account takeover and unauthorised access to a platform, a wallet or a lending app.

Fintech and Commercial Disputes

We resolve frozen settlement accounts, withheld merchant payouts, failed integrations and revenue-share disagreements with banks, payment partners, vendors, merchants and investors.

Early Advice on Exposure

Where a counterparty or a regulator is moving towards a dispute, SSA assesses the position, the evidence and the options before anything is filed.

Let’s Talk

Tell Us What You Are Building

Tell us the stage you are at, whether market entry, a pending application, an operating licence or a dispute, and what you need to achieve. A senior member of the team reads every enquiry.

Talk to our Fintech team