How to Register a Crypto Project in Pakistan: A Legal & Compliance Guide
Registering a crypto project in Pakistan requires a structured legal, corporate, and compliance-based approach, as the country does not yet have a dedicated crypto licensing regime. However, crypto projects can still operate lawfully and defensibly by aligning with existing corporate, AML, tax, and technology laws while preparing for future regulation.
This article explains how to legally structure and register a crypto project in Pakistan, from a regulatory and risk-management perspective.
1. Understanding Pakistan’s Crypto Regulatory Landscape
Pakistan currently does not recognize cryptocurrencies as legal tender. The State Bank of Pakistan (SBP) has issued advisories restricting banks from directly facilitating crypto transactions, but crypto ownership and blockchain development are not criminalized.
Key authorities involved include:
- State Bank of Pakistan (SBP) – Banking and payment systems
https://www.sbp.org.pk - Securities and Exchange Commission of Pakistan (SECP) – Company registration and corporate compliance
https://www.secp.gov.pk - Federal Investigation Agency (FIA) – AML and cybercrime oversight
https://www.fia.gov.pk - Federal Board of Revenue (FBR) – Taxation and reporting
https://www.fbr.gov.pk
2. Registering a Legal Entity for a Crypto Project
The first step is company incorporation, not crypto licensing.
Recommended Entity Type
Most crypto founders register as:
- Private Limited Company under the Companies Act, 2017
Company registration is done through the SECP eServices Portal:
https://eservices.secp.gov.pk
Business Object Clause (Critical)
The company’s Memorandum of Association should carefully define activities such as:
- Blockchain software development
- Digital asset research
- Token infrastructure development
- Web3 platforms and decentralized applications
Avoid direct language like “cryptocurrency exchange” or “investment services” unless properly structured.
3. Structuring the Crypto Project (Onshore + Offshore Model)
Due to regulatory uncertainty, many Pakistani crypto projects adopt a dual-structure model:
- Pakistan entity → Technology development, support, research
- Offshore entity (e.g., UAE, BVI, Estonia) → Token issuance, exchange listings, fundraising
This structure helps mitigate regulatory risk while remaining compliant with Pakistani law.
4. AML, KYC, and Compliance Obligations
Even without a crypto law, Pakistan is a FATF-compliant jurisdiction, meaning AML controls are mandatory.
Crypto projects should implement:
- Customer identification (KYC)
- Transaction monitoring
- Wallet screening
- Sanctions checks
FATF standards:
https://www.fatf-gafi.org
Failure to adopt AML measures may trigger investigation by the FIA Cyber Crime Wing:
https://www.fia.gov.pk/cyber-crime-wing
5. Tax Registration and Reporting (FBR Compliance)
Crypto projects must register with the Federal Board of Revenue (FBR) for:
- NTN (National Tax Number)
- Sales tax (if applicable)
- Corporate income reporting
FBR portal:
https://www.fbr.gov.pk
Crypto income, token revenue, and consulting income may be taxable depending on classification.
6. Token Issuance & Whitepaper Legal Review
If the project involves a token or coin, a legally reviewed whitepaper is essential.
Key legal considerations:
- Avoid profit guarantees
- Clarify utility vs investment nature
- Include risk disclosures
- Avoid public fundraising targeting Pakistan without approvals
Poorly structured tokens may be classified as unregistered securities, triggering enforcement risk.
7. Banking & Payment Challenges
Due to SBP restrictions, Pakistani banks generally do not support crypto transactions directly. Common solutions include:
- Foreign payment gateways
- Offshore banking
- Crypto-friendly jurisdictions for fiat ramps
SBP advisories:
https://www.sbp.org.pk/dfs/circulars.asp
8. Future Outlook: Pakistan’s Emerging Crypto Framework
Pakistan has recently shown movement toward:
- National crypto policy discussions
- Blockchain adoption initiatives
- Regulatory sandboxes
This suggests that early compliance positioning will give projects a strong advantage once formal licensing frameworks are introduced.
Conclusion: Legal Registration Is About Structure, Not Permission
While Pakistan does not yet issue crypto licenses, crypto projects can be legally registered, structured, and operated through:
- Proper company incorporation
- AML/KYC compliance
- Tax registration
- Offshore token structuring
- Clear legal documentation
As a crypto lawyer, the key advice is simple:
Do not wait for regulation—prepare for it.
The information provided in this article is for general informational purposes only and does not constitute legal or financial advice.
Author & Crypto Consultant
Shahid Jamal Tubrazy (Crypto & Fintech Law Consultant)
Shahid Jamal Tubrazy, a certified top expert in Crypto Law from Duke University, is a leading authority in the cryptocurrency and blockchain space. As a seasoned Fintech lawyer, he offers a full spectrum of services, including licensing, legal guidance for ICOs, STOs, DeFi, and DAOs, as well as specialized expertise in crypto mediation, negotiation, and mergers and acquisitions. With a proven track record and published works on Blockchain Regulation and Cryptocurrency Laws, Shahid provides unparalleled insights into the complexities of the fintech world, ensuring compliance and strategic success. 🌐💼 #CryptoLaw #Fintech #Blockchain #LicenseServices #CryptoMediator #MergersAndAcquisitions #CryptoCompliance #FrozenAssetsrecovery.
EMAIL: shahidtubrazy@gmail.com
Website: https://cyberlawconsult.wixsite.com/cryptolawyer
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