SBP Circular No. 10 of 2026: Banks Now Authorized to Open Accounts for PVARA-Licensed VASPs

The Paradigm Shift in VASP Banking

For years, Virtual Asset Service Providers (VASPs) in Pakistan have operated in a financial vacuum, often excluded from the mainstream banking sector due to stringent Anti-Money Laundering (AML) and Countering Financing of Terrorism (CFT) concerns. SBP Circular No. 10 of 2026 marks a decisive regulatory pivot. By formalizing the banking relationship for entities holding a license under the Pakistan Virtual Asset Regulatory Authority (PVARA), the State Bank of Pakistan has effectively provided the missing link for institutionalizing the digital asset sector.

Understanding the Compliance Threshold

This authorization is not an automatic entitlement for every crypto-related business. It is explicitly conditional upon the acquisition of a valid PVARA license. Banks are mandated to treat these accounts as 'High-Risk' categories under the current AML/CFT framework. Consequently, businesses should prepare for enhanced due diligence (EDD) protocols that go beyond standard Corporate Account openings.

Required Documentation and Pre-requisites

To ensure a seamless onboarding experience, your organization must align its corporate records with the following requirements:

• Valid PVARA License: The primary instrument of authority.
• Corporate Governance Proof: Up-to-date company registration in Pakistan records, including certified copies of Form-II and Form-A/C from the SECP.
• Financial Transparency: Audited financial statements and a clear declaration of beneficial ownership.
• AML/CFT Policy Manual: A documented, board-approved internal framework detailing transaction monitoring and suspicious activity reporting (SAR) capabilities.
• Tax Compliance Status: Verification of active NTN and STN status with the FBR.

Strategic Implementation: A Step-by-Step Guide

The transition from operation to banking requires a meticulous approach to avoid rejection or account freezing.

1. Corporate Alignment: Ensure your entity is correctly structured. Whether you are a Private Limited company or an AOP, ensure your constitutional documents reflect 'Virtual Asset Services' as a principal object.
2. Tax and Regulatory Housekeeping: Before approaching a bank, ensure all your corporate legal services and tax filings are up to date. Banks will cross-reference your business activity against your declared business lines in your NTN registration.
3. Bank Selection: Approach banks that have established digital asset desks or specialized compliance teams accustomed to the requirements of the Financial Action Task Force (FATF) standards.
4. Submission of EDD Pack: Prepare a comprehensive dossier including the PVARA license, proof of operational address, and detailed source of funds (SoF) disclosures.

Common Risks and Mitigation

Many businesses falter due to inadequate internal controls. A common mistake is failing to link the digital wallet infrastructure with the corporate bank account. Your compliance framework must prove that the bank account is used exclusively for operational expenses, fiat on/off-ramping, and regulatory capital requirements, rather than commingling funds.

If your application faces administrative delays or arbitrary rejection despite full compliance, you may need to pursue formal engagement with the bank’s compliance department or seek legal intervention to address procedural irregularities.

Professional Consultation

The intersection of PVARA regulations and SBP mandates requires a sophisticated understanding of both corporate law and financial regulation. Whether you are in the process of company registration in Pakistan or restructuring an existing entity to meet these new standards, professional oversight is critical to managing your risk profile.

We advise all prospective VASP applicants to conduct a pre-application audit of their corporate governance and AML protocols. To ensure your business meets the rigorous standards of SBP Circular No. 10 of 2026, contact our advisory team for a comprehensive review of your compliance posture.