Authorizing Bank Accounts for PVARA-Licensed VASPs and Their Customers

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BPRD Circular Letter No. 10

Authorizing Opening of Bank Accounts to PVARA s NOC/Licensed VASPs and their Customers

37819

The Presidents/ Chief Executives SBP Regulated Entities Dear Sir/Madam, Authorizing Opening of Bank Accounts to PVARA’s NOC/Licensed VASPs and their Customers Please refer to the BPRD Circular No. 03 of 2018 dated April 06, 2018, regarding Prohibition of Dealing in Virtual Currencies/Tokens. 2. The Virtual Assets Act, 2026 has been enacted, pursuant to which, Pakistan Virtual Asset Regulatory Authority (PVARA) has been established as the statutory authority responsible for the licensing, regulation, supervision and oversight of virtual asset activities in Pakistan. 3. In view of the foregoing, it has been decided to replace the BPRD Circular No. 03 of 2018 dated April 06, 2018 with the following instructions with immediate effect. Moreover, subject to strict compliance with the conditions outlined herein, SBP Regulated Entities (REs) may open bank accounts of entities duly licensed by PVARA as Virtual Asset Service Providers (VASPs): a) Prior to onboarding a VASP or initiating any activity with it, REs shall obtain and retain, on record, a copy of the VASP’s valid license issued by PVARA and independently verify its authenticity from PVARA. b) REs shall open separate transactional accounts i.e. Client Money Accounts (CMAs) for settlement of authorised transactions of licensed VASPs, where applicable, based on VASP’s business model to deliver permissible services to their clients. Strict segregation between CMAs and other types of accounts of VASPs shall be ensured and commingling of VASP funds with those of their clients shall be strictly prohibited. c) CMAs shall be PKR denominated, non-remunerative accounts for the purpose of executing authorised transactions of licensed VASPs. Further, cash deposits and cash withdrawals shall not be permitted in CMAs. Moreover, funds maintained in CMAs shall not be used as collateral or security to provide any form of financing or credit facilities to VASPs. 4. In addition to the Customer Due Diligence (CDD) requirements under Regulation-2 of the Anti-Money Laundering, Combating the Financing of Terrorism & Countering Proliferation Financing (AML/CFT/CPF) Regulations for SBP’s Regulated Entities (REs), REs must ensure the following: a) REs shall conduct complete due diligence of the VASP and gather sufficient information about the VASP to understand the nature and scope of its business, specific activities it conducts, customer onboarding process, customer base, and the geographic markets in which it operates. b) REs shall make appropriate amendments to their Customer Risk Profiling (CRP) model to account for risks posed by VASPs. Using the amended CRP model, the REs shall appropriately risk-rate the VASPs and ensure that risk-based controls and monitoring mechanisms are effectively implemented. c) REs shall monitor its relationship with VASP(s) on an ongoing basis and report any suspicious transaction to FMU as per the requirements of Anti-Money Laundering Act, 2010. d) REs shall ensure compliance with all the relevant laws and regulations including but not limited to Anti-Money Laundering Act, 2010 and SBP’s AML/CFT/CPF Regulations. 5. Banks may also open limited-purpose accounts of entities holding NOCs issued by PVARA enabling them to complete formalities for obtaining a license from PVARA. Only upon the grant of a license by PVARA, the bank can extend additional services (including virtual assets-related transactional activity) subject to strict compliance with the instructions as outlined above. 6. REs shall not invest, trade or hold virtual assets using their own funds or customer deposits. 7. REs shall remain responsible for compliance with all applicable SBP regulations including foreign exchange regulations and any arrangement with a VASP shall not absolve them of such responsibility. 8. Please acknowledge receipt.

Yours sincerely,

Syed Mansoor Ali Director

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Authorizing Opening of Bank Accounts to PVARA s NOC/Licensed VASPs and their Customers