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VIRTUAL ASSETS / REGULATORY & TRANSACTIONAL ADVISORY

Digital Assets, Blockchain & Web3

Virtual asset regulation, tokenised commercial structures and the legal architecture of decentralised technologies.

Digital assets and blockchain technology — Ninety Two ChambersNINETY TWO CHAMBERS / SPECIALIST EXPERTISE

Begin with the
legal perimeter.

The Virtual Assets Act, 2026 establishes the statutory framework governing virtual assets and virtual asset service providers in Pakistan. The Pakistan Virtual Assets Regulatory Authority (PVARA) is responsible for licensing and supervision within that framework. The Pakistan Virtual Asset Services Regulations, 2026 and the activity-specific regulations notified on 21 August 2026 prescribe further requirements for relevant activities.

Before selecting a structure or preparing an application, the proposed activity must be examined in substance. An exchange, broker-dealer, custodian, transfer or settlement provider, adviser, asset manager or token issuer may encounter distinct regulatory obligations. An initial no-objection certificate does not itself constitute permission to offer a virtual asset service.

The analysis cannot always stop at PVARA. A product involving investment rights, banking relationships, payments or property interests may raise separate questions under companies, securities, banking, payment-systems and property law. Relevant obligations depend on the actual rights created, the parties involved and where the service is provided.

THE QUESTION WE ADDRESS
What service is being offered, to whom, and under which legal authority?
RECOGNISING THE ISSUE

Before a product
enters the market.

Regulatory design and commercial documentation should be settled before a virtual asset business makes representations to customers or investors.

  1. 01An exchange or brokerage is preparing to onboard Pakistani customers and needs to identify its licensed activities.
  2. 02A custody or settlement provider needs to allocate responsibility for access, safeguarding and recovery of client assets.
  3. 03An issuer proposes tokens linked to fiat currency, investments, commodities, property or other underlying rights.
  4. 04A decentralised protocol or foreign digital platform must assess its governance, contractual relationships and territorial regulatory exposure.
FOR THE INITIAL DISCUSSION

Bring the proposed product and revenue model, corporate ownership and governance structure, token documentation, customer jurisdictions, custody design and relevant regulator correspondence.

ENQUIRE ABOUT THIS MATTER ↗
WHERE WE ADVISE

Six connected
workstreams.

Advice is scoped to the facts, the legal classification and the applicable licensing regime.

01Virtual Assets & PVARA Regulation — Determine the service, the relevant licence category and the competent regulatory authority.↗
02Crypto Exchanges & VASP Licensing — Address permissions for exchange, brokerage, custody and transfers before offering services.↗
03Real-World Asset Tokenisation — Distinguish a digital representation from enforceable ownership and transfer rights.↗
04Web3, DeFi & Blockchain Ventures — Examine protocol governance, contractual responsibility and cross-border legal exposure.↗
05Stablecoins & Token Issuance — Review issuer obligations, reserves, redemption and regulatory classification.↗
06Digital Asset Compliance & Investigations — Address customer due diligence, sanctions, safeguarding and supervisory response.↗

Define the right
behind the token.

Asset tokenisation may involve a record of a contractual claim, a beneficial interest, a security, a payment entitlement or an ownership arrangement. The creation or transfer of a token does not by itself transfer title to land, perfect a security interest, assign a receivable or establish an enforceable right against an issuer.

The underlying asset, title or custody arrangements, rights granted to holders, transfer restrictions, defaults, insolvency treatment and available remedies must be addressed in the governing documents. For structures representing property or investment interests, the relevant formalities and regulatory classification require independent analysis.

Where investor capital is pooled, returns are promised or token rights resemble securities, the transaction should be examined under the applicable financial and corporate regimes rather than assuming that a virtual-asset classification resolves every question.

THE TRANSACTIONAL TEST
What enforceable right remains if the issuer or platform fails?