Market / Pakistan  ·  Frontier & Gulf

Pakistan: the programme behind the licence. The licence is the easy part.

Pakistan licenses across banking, payments and exchange, the non-bank financial sector, a new virtual-asset regime, and the designated non-financial trades. A licence records that a regulator let you begin. It does not build the controls that keep you operating: the enterprise risk assessment, the screening, the reporting line into the financial intelligence unit, the independent audit that survives a supervisory visit. Its supervisors now test whether a programme works, not whether it reads well. Black Sea builds, remediates and runs that programme. Operator-side only: no software, no commission, reviewer not seller.

Request a costed plan → See how we work →
Theatre Frontier & Gulf SBP · SECP · PVARA · FBR FMU / national FIU Operational
Scroll
FRONTIER & GULF
7
Supervisory bodies
1
VA authority / PVARA
9
Sectors covered
1
FIU / FMU
02The regulatory landscape
02

No single body holds your file

Pakistan spreads financial-crime supervision across several bodies. Which one holds your file depends on what you do, and each mandate differs. We map every operator to the correct authority and build to that authority's expectations. What an examiner tests: that the programme actually works, not that it reads well.

  • SBP, State Bank of Pakistan. Banking and monetary regulator: Banking Supervision and the Banking Conduct and AML functions supervise banks and financial institutions; the Exchange Policy Department governs exchange companies, money services and remittances.
  • SECP, Securities and Exchange Commission of Pakistan. Supervises the non-bank financial sector.
  • PVARA, Pakistan Virtual Assets Regulatory Authority. Dedicated authority for a newly established virtual-asset regime.
  • ICAP and ICMAP. AML self-regulatory supervisors for their member accountants.
  • FBR DG-DNFBP. The Federal Board of Revenue's Directorate General of Designated Non-Financial Businesses and Professions supervises the designated non-financial trades.
  • SECDIV. The Strategic Export Control Division of the Ministry of Foreign Affairs governs export and dual-use controls.
  • FMU, Financial Monitoring Unit. The national financial intelligence unit: the reporting endpoint every programme here must reach.
VASP & crypto
PVARA The Pakistan Virtual Assets Regulatory Authority is the dedicated authority for virtual-asset activity and service providers. The regime is newly established and its licensing and AML rulebook is still forming. We build to the framework as published and verify current status against PVARA's own materials before relying on any requirement.
Payments & MSB
SBP The State Bank of Pakistan governs the exchange-company, money-services and remittance sector through its Exchange Policy Department. Authorised exchange companies appear on the SBP's public exchange-company list.
Banks & FIs
SBPSECP SBP Banking Supervision and its Banking Conduct and AML function supervise banks and financial institutions, listed in the SBP's directory of financial institutions. Non-bank lenders, finance and leasing companies, factoring and Modarabas answer to the SECP, whose NBFC register is public.
Funds & CSP
SECPICAPICMAP Funds, fund administration and corporate service provision sit under the SECP. ICAP and ICMAP act as AML self-regulatory supervisors for their member accountants and firms; members are searchable through the ICAP member search.
Gold & DPMS
FBR DG-DNFBP Precious-metals and precious-stones dealers are AML-supervised by the Federal Board of Revenue's Directorate General of DNFBPs. Registration with the tax authority and AML supervision arrive together, and suspicious-transaction reporting runs to the FMU.
Gaming
PTANCCIA There is no licensing regulator. Gambling is prohibited under the Prevention of Gambling Act, 1977 and provincial gambling ordinances, enforced by provincial governments and police, with online platforms blocked by the Pakistan Telecommunication Authority and the National Cyber Crime Investigation Agency. Any gaming-adjacent engagement is scoped around that prohibition, not around a licence.
Real estate & DNFBP
FBR DG-DNFBPFMU Real-estate agents and the wider designated non-financial businesses and professions are AML-supervised by the FBR DG-DNFBP, with suspicious-transaction reports landing at the Financial Monitoring Unit.
Defence & dual-use
SECDIV The Strategic Export Control Division of the Ministry of Foreign Affairs governs export and dual-use controls for strategic and defence-linked trade. This is export-control and proliferation-financing exposure, not classic AML supervision.
Art & high-value
FMU Art dealers, auction houses and high-value-goods dealers are not a designated DNFBP category in Pakistan, so there is no dedicated AML supervisor over the activity. The obligation that remains is suspicious-transaction reporting to the FMU, and that is what we build to.
Every regulator above is drawn from the verified Pakistan regulator matrix. We state what the current framework requires, verify any recent rule change or circular against the regulator's own published materials before relying on it, and never assert a specific deadline, penalty or statute number without a source.
03Who operates here, and what they must run

Pakistan is a large, cash-intensive market with heavy remittance and exchange-company flow, a fast-forming virtual-asset regime, and supervisors under sustained scrutiny on financial-crime effectiveness. That attention does not reward paperwork: it tests whether the programme works. Whether SBP-regulated, SECP-supervised, PVARA-authorised or an FBR-supervised trade, an operator is expected to hold a working programme, not a binder. What a regulated operator in Pakistan has to build and keep running:

01A documented enterprise AML/CFT risk assessment, tuned to Pakistani typologies and to the firm's actual customer base, products and geographies, that a supervisor can test.
02Customer due diligence and beneficial-ownership checks that hold up under file review, with enhanced measures for higher-risk relationships and defensible source-of-funds work.
03Sanctions and watchlist screening calibrated to real exposure and to the firm's counterparties, not a switched-on default, and transaction monitoring that produces defensible alerts and a clean path to a suspicious transaction report filed with the FMU.
04A named, competent compliance and reporting officer, a reporting function that actually functions, and independent testing, board reporting and a training programme that leaves a record.
Most enforcement does not begin with a missing licence. It begins with a programme that reads well and works badly. That is the gap we close.
04By sector here

How we serve every sector here

We serve every regulated sector in Pakistan to the same depth and the same fixed-scope discipline. Nine sectors, even weight, no flagship. Each tile is the Pakistan-specific build for that sector. If a sector is not the right fit for us, we say so before you engage.

VASP & cryptoProgramme build and screening for PVARA-facing virtual-asset activity under a regime that is still forming, including the FATF Travel Rule for transfers. Payments & MSBAML controls, agent oversight and exchange-company obligations for firms under the SBP Exchange Policy Department. Banks & FIsFull programme build, remediation and independent audit for SBP-supervised banks and SECP-supervised non-bank lenders and finance companies. Funds & CSPAML frameworks for SECP-supervised funds, administrators and corporate service providers, with ICAP and ICMAP as the accountants' AML supervisors. Gold & DPMSDealer AML programmes, source-of-funds controls and reporting into the FMU for FBR DG-DNFBP-supervised precious-metals and stones dealers. GamingNo licensing regulator. Gambling is prohibited under the Prevention of Gambling Act, 1977 and provincial ordinances. Integrity, exposure and AML-risk scoping built around that prohibition. Real estate & DNFBPAML programmes, CDD and reporting for the FBR DG-DNFBP-supervised real-estate and DNFBP perimeter. Defence & dual-useExport-control, sanctions and integrity due diligence for strategic and defence-linked trade under SECDIV. Art & high-valueNot a designated DNFBP category, so no dedicated supervisor. Provenance, source-of-funds and STR reporting controls built to the FMU obligation that remains.
All sectors → All markets →
05The five service lines, in this market
01
Licensing and new-regime programme build. The full AML/CFT and sanctions programme an SBP, SECP or PVARA file needs behind it: risk assessment, policies, controls, screening and the reporting line into the FMU, built to scope and ready for regulator review.
02
Remediation. Post-finding or post-enforcement rebuild: root-cause work, file remediation, control redesign and a plan a supervisor will accept.
03
Outsourced and bridge MLRO, plus a managed FIU function. We hold the reporting role, or bridge it, and run the line into the FMU while you recruit, restructure or scale.
04
Independent AML audit. The independent test your framework requires, delivered by senior reviewers with no stake in the outcome.
05
Sanctions, export-control and integrity due diligence. Screening, dual-use controls calibrated to Pakistan's strategic-trade exposure, and the FATF Travel Rule for virtual-asset firms.
Full scope of what we do →
06The operator-side value
Independent, conflict-free
In a market where the same advisers often sell the licence and the tooling, our independence is the point. We take no commission, hold no product and answer to the operator alone. When we sign off on a control, nothing else is riding on it.
Built for a tested supervisor
Pakistan's AML effectiveness has been under international scrutiny, and its regulators now look for evidence, not intent. We build the file, the alert history and the record that shows the programme worked.
Senior-only, fixed scope
The people who scope your programme are the people who build it. No junior hand-off. Fixed scope, fixed fee, no hourly billing. A costed plan within 48 hours.
Briefing seriesCurrent and datedA live, dated stream of frontier and Gulf compliance analysis.Insights →
Local partnersLocal legal standingLicensed local law-firm and compliance partners in our markets.Partners →
Press pickupKazakh pressIndependent coverage of our work and commentary, not paid placement.The record →
CredentialsCAMS / ICAQualified, hands on the programme. No client names, no invented cases.The firm →

Tell us the licence, the sector and where the programme stands today.

You get a costed, fixed-scope plan within 48 hours. No obligation, no sales call in disguise.
Request a costed plan → Book a briefing →