Salahuddin, Saif & Aslam Attorneys at Law

Fintech & Financial Services

VASP & Digital Assets

SSA advises virtual-asset businesses on entering and operating in Pakistan under the PVARA framework.

We start with the activities the platform actually performs, map those activities to the applicable licence category or categories, and structure the regulatory pathway from NOC or Sandbox through local incorporation, licensing and operational readiness. Our role includes preparing the regulatory submissions and the supporting business, governance, compliance and operating materials required to present a coherent proposition to PVARA.

How SSA Supports the Mandate

From Regulatory Strategy to Implementation.

Our role is to turn the proposed business or transaction into the applications, documents, structures and operating arrangements required to move it forward.

The precise workstream is tailored to the product, licence category, ownership structure and stage of the business. Where a mandate also requires cross-border, technology, transactional or continuing compliance support, those elements are integrated into the engagement.

Activity Classification & Licensing Strategy

We map exchange, custody, broker-dealer, transfer and settlement, lending and borrowing, virtual-asset management, derivatives, advisory and token-related functionality against the applicable licence categories. Where a product combines activities, we identify the approvals required for each regulated component and structure the application accordingly.

NOC, Sandbox & VASP Licence Applications

SSA prepares and coordinates the NOC, Sandbox and licensing workstreams, including the business plan, corporate and ownership materials, controllers and key-individual information, regulatory forms and supporting submissions. We manage responses to regulatory observations and align the local incorporation and licensing sequence with the proposed operating model.

Governance, Prudential & Fit-and-Proper

We advise on ownership and control, board and senior-management arrangements, fit-and-proper requirements, capital and prudential requirements and the allocation of regulated functions. The objective is to ensure that the governance presented in the application is capable of operating in practice after authorisation.

AML/CFT/CPF & Financial Crime Controls

We develop and review the AML/CFT/CPF framework around the actual customer journey and transaction flows, including CDD and EDD, sanctions screening, transaction monitoring, suspicious transaction reporting, record keeping, risk classification and escalation. We also address FMU/goAML registration where applicable to the regulatory pathway.

Client Assets, Custody & Safeguarding

For exchanges, custodians and platforms controlling client assets, we advise on wallet and custody architecture, segregation, safeguarding, access and control arrangements, third-party custodians and the contractual allocation of responsibility. Client-asset protection is considered alongside technology, operational resilience and the activity-specific requirements of the licence.

Cross-Border Platforms & Pakistan Market Entry

We assess how an offshore platform reaches Pakistan, including marketing, onboarding, PKR payment rails, local affiliates, technology providers and customer access. We then structure the Pakistan-facing model so that the licensed activities, local entity and overseas group functions are clearly allocated and capable of regulatory explanation.

Our Approach

One Regulatory Proposition, Carried Through the Business.

Structure the Route

We identify the regulatory perimeter, approvals and sequencing before the application or transaction is built.

Prepare the Work Product

We prepare and coordinate the applications, business and corporate materials, policies, contracts and supporting submissions required for the mandate.

Carry It Through

We support regulatory observations, implementation, launch and subsequent changes so the legal structure remains aligned with the operating business.

Let's Talk

Discuss Your VASP & Digital Assets Requirements.

Tell us where you are in the process and what you are trying to achieve.

Talk to our Fintech team