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Virtual Assets Act 2026 · Regulations notified 21 August 2026

AML CFT built for PVARA licensing.

Pakistan now licenses VASPs. Your AML CFT program is part of the test. We help you pass it.

10
License
categories
3
Routes to a
license
goAML
FMU registration
before licensing
In short

What AML CFT controls does a VASP in Pakistan need?

A PVARA-licensed virtual asset service provider needs customer due diligence, sanctions and NACTA screening, PEP checks, risk-based customer scoring, transaction monitoring and STR reporting to the FMU through goAML. FPM AML-CHECK provides each of these controls, and FPM can co-source the compliance function during the sandbox.

Updated
What PVARA Will Look For

What PVARA checks. How we cover it.

Every control in your application, mapped.

Control PVARA expectsHow FPM AML-CHECK covers it
Customer identification and verificationCNIC and passport OCR, passive and active liveness, face match, contactless fingerprint capture, via SDK or API
Sanctions and TFS screeningUNSC and NACTA lists refreshed every 24 hours, SROs every 3 hours, plus global sanctions. Ongoing re-screening of the full customer base
PEP and adverse media screeningNine categories of domestic PEPs with associates, FPM reputational risk data, optional global PEPs
Risk-based approachConfigurable customer risk model for individuals and entities, with EDD triggers and documented rationale
Transaction monitoringRules for fiat on-ramp and off-ramp patterns, velocity, pass-through, mule indicators and high-risk counterparties
Suspicious transaction reportingCase files built for your Compliance Officer's STR decision and filing on goAML
Record keepingScreening records and decisions retained for five years with full audit trail
Outsourcing disclosure and oversightA defined service scope, reporting and SLAs your Board can oversee and disclose in the application
VASP Risk

Where VASP risk hits first.

Remote onboarding

No branch. No face to face. Liveness does the work.

Mule and nominee accounts

Borrowed CNICs. Blocked identities. Shared devices.

Fast fiat movement

Deposit, convert, withdraw. All within hours.

Proscribed persons

Schedule IV names under new spellings.

Cross-border exposure

Users and counterparties in high-risk places.

On-chain exposure

Wallet alerts from your analytics, in one case flow.

For sandbox and NOC applicants

Don't build it alone. Co-source it.

Technology, operations and people. From a regulated institution, in compliance since 2019.

You keepBoard responsibility, your Compliance Officer, the STR decision
We runThe platform, daily reviews, case files, reporting
You exitWith a function that is documented, tested and ready for the license review
Questions

VASP questions, answered.

Does PVARA require an AML CFT program before licensing?

Yes. An AML CFT compliance program is a licensing requirement. Applicants on the NOC track register with the Financial Monitoring Unit, and KYC and AML controls are assessed even at the sandbox stage.

Who is responsible for AML CFT at a VASP?

The Board. PVARA's licensing framework keeps responsibility for AML CFT/CPF and market integrity controls with the Board, including oversight of any outsourcing.

Does FPM AML-CHECK do on-chain wallet analytics?

FPM AML-CHECK covers the customer side: identity, screening, risk scoring and fiat-side monitoring. Pair it with a blockchain analytics provider for wallet screening. We scope that connection with you.

Can FPM run our AML CFT function during the sandbox?

Yes. Our co-sourcing service supplies the technology, the operations and trained staff, while your Board and Compliance Officer keep accountability.

Preparing a PVARA application?

Talk to us before you submit. Not after.