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  "title": "Virtual Assets Act, 2026",
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  "text": "Page 1 of 35 \r\n \r\n \r\n \r\n \r\nTHE VIRTUAL ASSETS ACT, 2026 \r\n                                            \r\n                                                           CONTENTS \r\n \r\nChapter I \r\nPRELIMINARY \r\n1.  Short title, extent, commencement \r\n2.  Scope of application \r\n3.  Definitions \r\n4.  Extraterritorial application \r\n5.  Relationship with other laws \r\nChapter 2 \r\nPAKISTAN VIRTUAL ASSETS REGULATORY AUTHORITY \r\n6.  Establishment of the Authority \r\n7.  Composition of Authority \r\n8.  Procedures of the Authority \r\n9.  Objectives, functions and powers of the Authority \r\n10.  Delegation of powers \r\n11.  Appointment and Functions of Chairperson \r\n12.  Appointment and Functions of Managing Director \r\n13.  Appointment of Officers, Staff, Consultants, Advisors and other personnel \r\n14.  Pakistan Virtual Asset Regulatory Authority Fund \r\n\r\n \r\nPage 2 of 35 \r\n \r\n15.  Budget, Finance and Audit \r\n16.  Code of conduct \r\n17.  Inter-agency cooperation and information-sharing \r\nChapter 3 \r\nLICENSING OF VIRTUAL ASSET SERVICE PROVIDERS AND ISSUANCE OF VIRTUAL \r\nASSETS \r\n18.  Categories of virtual asset services \r\n19.  Application for License \r\n20.  Fit-and-proper criteria \r\n21.  Grant, refusal and terms of license \r\n22.  Ongoing obligations of licensees \r\n23.  Variation, suspension and revocation of license \r\nChapter-4 \r\nPRUDENTIAL REQUIREMENTS, SAFEGUARDING AND CUSTODY \r\n24.  Segregation of customer assets \r\n25.  Minimum financial resource requirements \r\n26.  Custody standards and key-management controls \r\n27.  Proof-of-reserves and audit obligations \r\n28.  Reserve custodians \r\n29.  Customer safeguard or compensation mechanism \r\nChapter-5 \r\nFIAT-REFERENCED AND ASSET-REFERENCED TOKENS \r\n30.  Initial Virtual Asset Offerings \r\n31.  Issuance Requirements for Fiat-Referenced Tokens \r\n32.  Issuance Requirements for Asset-Referenced Tokens \r\n33.  Significant issuers \r\nChapter-6 \r\nCYBERSECURITY, SANDBOX AND INNOVATION \r\n34.  Cybersecurity and operational resilience \r\n \r\nPage 3 of 35 \r\n \r\n35.  Regulatory sandbox \r\n36.  Oversight of blockchain technology adoption \r\n37.  Regulation of Virtual Asset Mining Activities \r\n38.  Establishment of Strategic Digital Wallet Company \r\n39.  Data localization framework \r\n40.  Data segregation and protection of sensitive information \r\nChapter-7 \r\nMARKET CONDUCT, CONSUMER PROTECTION \r\n41.  Duty of integrity and fair dealing \r\n42.  Obligations of issuers of Virtual Assets \r\n43.  Marketing and conduct restrictions \r\n44.  Conflict-of-interest management \r\n45.  Complaint-handling and dispute resolution \r\nChapter-8 \r\nANTI-MONEY LAUNDERING, COUNTERING OF TERRORISM FINANCING AND \r\nCOUNTERING OF PROLIFERATION FINANCING \r\n46.  Application of Anti-Money Laundering Act, 2010 \r\n47.  Travel rule and record-keeping obligations \r\n48.  Real-time data access and reporting \r\n49.  Data Privacy Obligations for Licensed entities \r\nChapter-9 \r\nProhibitions \r\n50.  Prohibition of unlicensed Virtual Asset services \r\n51.  Prohibition on Initial Virtual Asset Offerings \r\n52.  Prohibition of market manipulation and insider trading \r\n53.  Prohibition on Algorithmic tokens \r\nChapter-10 \r\nENFORCEMENT, OFFENCES AND PENALTIES \r\n54.  Criminal offences \r\n \r\nPage 4 of 35 \r\n \r\n55.  Liability of officers of bodies corporate \r\n56.  Power to Investigate \r\n57.  Powers of Authorized Officer \r\n58.  Prosecution of offences \r\n59.  Administrative sanctions \r\n60.  Emergency intervention powers \r\n61.  Power to prevent access to unlicensed virtual asset services \r\nChapter-11 \r\nAPPEALS \r\n62.  Establishment of the virtual assets appellate tribunal \r\n63.  Jurisdiction \r\n64.  Appeal \r\n65.  Appeal to Supreme Court \r\nChapter-12 \r\nMISCELLANEOUS \r\n66.  Tax Compliance \r\n67.  Power to make Rules \r\n68.  Powers to make regulations \r\n69.  Officers to be Public Servants \r\n70.  Transitional provisions \r\n71.  Power of the Federal Government to issue policy directives \r\n72.  Annual and special reports of the Authority \r\n73.  Removal of difficulties \r\n74.  Savings \r\nSCHEDULE-I \r\n \r\n \r\n \r\n \r\nPage 5 of 35 \r\n \r\nTHE VIRTUAL ASSETS ACT, 2026 \r\nACT NO. XIII OF 2026 \r\n[4th March, 2026] \r\nAN \r\nACT \r\nto establish a regulatory Authority for the licensing, regulation and supervision of Virtual Assets and \r\nVirtual Asset Service Providers \r\nWHEREAS it is expedient to establish a dedicated Virtual Assets Regulatory Authority to \r\nlicense, regulate and supervise Virtual Assets and Virtual Asset Service Providers, in order to ensure \r\ninvestor protection, transparency and market integrity in Pakistan; \r\nAND WHEREAS, it is necessary to provide a comprehensive legal framework to empower the \r\nAuthority to combat money laundering, terrorist financing, proliferation financing and other illicit \r\nactivities involving Virtual Assets, in accordance with international standards, and to provide for matters \r\nconnected therewith or ancillary thereto; \r\nIt is hereby enacted as follows: - \r\nChapter I \r\nPRELIMINARY \r\n1. Short title, extent, commencement .—(1) This Act Shall be called the Virtual Assets Act, \r\n2026. \r\n(2) It extends to the whole of Pakistan. \r\n(3) It shall come into force at once. \r\n2. Scope of application.—(1) This Act shall apply to— \r\n(a)  any Virtual Asset Service Provider that carries on, or holds itself out as carrying \r\non, a Virtual Asset Service in or from Pakistan; and \r\n(b)  any Issuer that offers, originates or distributes, on its own behal f, a Virtual Asset \r\nin or from Pakistan. \r\n(2) For the avoidance of doubt, this Act shall not apply to the following digital representations of \r\nvalue or rights, insofar as they meet the conditions stated below— \r\n(a)  closed-ecosystem or closed -loop digital tokens, including any digital \r\nrepresentation of value or rights that, by design, technical architecture, or \r\nenforceable system controls, satisfies all of the following conditions— \r\n \r\nPage 6 of 35 \r\n \r\n(i)  is usable or redeemable solely within a restricted digital platform, \r\necosystem, application, or network administered by the issuer or operator; \r\n(ii)  is not transferable outside such platform, ecosystem, application, or \r\nnetwork, whether directly or indirectly; \r\n(iii)  is not exchangeable for fi at currency or legal tender outsi de such \r\necosystem; \r\n(iv)  is not redeemable for real-world goods or services outside such ecosystem; \r\n(v)  is not convertible into, exchangeable for, or interoperable with any other \r\nVirtual Asset; \r\n(vi)  is not saleable, tradable, or transferable on any external market, exchange, \r\nor secondary trading venue; or \r\n(vii)  is not designed, marketed, or used for payment, investment, or value -\r\ntransfer purposes beyond such ecosystem. \r\n(b)  securities, derivatives, collective investment schemes, depositary receipts, or \r\nother traditional financial instruments that fall within the regulatory jurisdiction \r\nof the State Bank of Pakistan or the Securities and Exchange Commission of \r\nPakistan; \r\n(c)  digital representations of fiat currency issued by the State Bank of Pakistan or any \r\ncentral bank or monetary authority of another sovereign jurisdiction; \r\n(d)  a non -fungible token that is not used for payment or investment and does not \r\nrepresent, reference, or derive value from any security, commodity, financial \r\nasset, or other regulated instrument; \r\n(e)  any non -fungible token or digital collectible that does not constitute a Virtual \r\nAsset, having regard to its substance, function, or economic effect; or  \r\n(f)  any other digital representation of value or rights expressly excluded by the  \r\nAuthority. \r\n3. Definitions.—(1) In this Act, unless there is anything repugnant in the subject or context: \r\n(i)  “Asset-Referenced Token ” means a Virtual Asset that represents, directly or \r\nindirectly, ownership rights, claims, or economic interests, including entitlements \r\nto receive or share income, returns, or other economic benefits, in respect of one \r\nor more underlying assets, or is designed to maintain a stable value by reference \r\nto such underlying assets. \r\n(ii)  “Authority” or “PVARA” means the Pakistan Virtual Asset Regulatory Authority \r\nestablished under this Act; \r\n \r\nPage 7 of 35 \r\n \r\n(iii) “Blockchain” or “Distributed Ledger Technology” or “DLT” means a technology \r\nthat en ables a distributed ledger, an i nformation repository that records \r\ntransactions or data across mu ltiple nodes in a synchronized manner using \r\ncryptography to ensure integrity, tamper-resistance, immutability, and consensus \r\namong participants, as may be further defined by Regulations; \r\n(iv)  “Chairperson” means the Chairperson of the Authority appointed under this Act; \r\n(v)  “Controller” means a Person who, alone or together with associates, holds or is \r\nentitled to exercise twenty percent (20%) or more of the voting power, ownership \r\ninterest, or share capital of a Licensee, or otherwise exercises significant influence \r\nor control over its management or policies, whether directly or indirectly; \r\n(vi)  “Customer” means any natural or legal person who obtains or uses a Virtual Asset \r\nService from a Licensee, or who enters into a business or contractual relationship \r\nwith a Licensee for the provision of such service, whether on a one-off or ongoing \r\nbasis; \r\n(vii) “Customer Assets ” means Virtual Assets and fiat currency belonging to a \r\ncustomer that a Virtual Asset Service Provider holds, safeguards, or otherwise has \r\ncustody or control over on that cus tomer’s behalf, and excludes assets owned by \r\nthe Virtual Asset Service Provider; \r\n(viii) “Division concerned ” means the Cabinet Division as defined in the Rules of \r\nBusiness, 1973; \r\n(ix) “Fiat-Referenced Token” means a Virtual Asset that purports to maintain a stable \r\nvalue relative to a single Official Currency of any country and is redeemable at \r\npar value by its Issuer; \r\n(x)  “High-Quality Liquid Assets” or “HQLA” means such high-quality liquid assets \r\nas may be prescribed by Regulations; \r\n(xi)  “Inside information” means non-public information likely to affect virtual asset \r\nprices if disclosed, including client orders, trading intentions, or decisions related \r\nto issuance or facilitation, as may be further defined by regulations; \r\n(xii)  “Insiders” include Controller, officers, directors, employees, or affiliates of \r\nissuers or Virtual Asset Se rvice Providers with access to i nside information; \r\nfamily members; o r other persons obtaining such i nformation unlawfully or \r\nthrough employment, and as may be further prescribed by Regulations. \r\n(xiii)  “Issuer” means the legal Person that originates or creates a Virtual Asset and \r\nretains primary control over its initial supply, reserve assets (if any) or on -chain \r\ngovernance, and may distribute such Virtual Asset as part of its initial offering, \r\nand that bears the ongoing obligations as prescribed by the Authority. \r\n \r\nPage 8 of 35 \r\n \r\nExplanation: A Person is not an Issuer solely because it markets, advertises, \r\npromotes, facilitates secondary-Market trading (including third-party brokerage, \r\ndistribution or exchange), or provides technical development or maintenance \r\nservices without control over issuance, supply or reserve assets. \r\n(xiv)  “Initial Virtual Asset Offering ” means a method of raising funds b y an Issuer \r\nthrough the public offering of Virtual Assets in exchange for funds or other Virtual \r\nAssets or anything of commercial value, subject to the limitations and disclosure \r\nrequirements Prescribed under this Act; \r\n(xv)  “Key Individual” means any natural Person who occupies or performs - whether \r\non a full-time, part-time, acting or outsourced basis - one or more of the positions \r\nlisted below in relation to a licensee \r\n(a)  director (executive or non-executive) registered under the Companies Act, \r\n2017 (XIX of 2017) \r\n(b)  Managing Director; \r\n(c)  chief financial officer; \r\n(d)  chief operating officer; \r\n(e)  head of internal audit; \r\n(f)  head of compliance; \r\n(g)  money-laundering reporting officer (MLRO) or equivalent AML, CFT or \r\nCPF complia nce officer designed under the AML, CFT and CPF \r\nRegulations issued pursuant to the Anti-Money Laundering Act 2010 (VII \r\nof 2010); \r\n(h)  head of risk management; \r\n(i)  head of information-security and cyber-security; or \r\n(j)  any other position that the Authori ty, by written notice to the Licensee, \r\ndeclares to be a Key Individual. \r\n(xvi)  “Licensee” means a person who holds a license under this Act; \r\n(xvii)  Market Manipulation or Market Abuse means any act, practice or course of \r\nconduct that: \r\n(a)  gives false or misleading signals as to the supply, demand or price of one \r\nor more Virtual Assets; \r\n(b)  secures the price of Virtual Assets at an abnormal or artificial level; or \r\n \r\nPage 9 of 35 \r\n \r\n(c)  employs any device, deception or artificial means to interfere with the \r\nnormal operation of supply and demand in Virtual Asset markets, as may \r\nbe further defined by Regulations. \r\n(xviii)  “Managing Director” means the Managing Director of the Authority, appointed \r\nunder this Act; \r\n(xix)  “Virtual Asset Mining” means the process of validating or verifying transactions \r\nand recording them on a distributed ledger or blockchain network, using \r\ncomputational or other consensus mechanisms, and, in return, earning virtual \r\nassets, transaction fees, or other rewards. \r\n(xx)  “Non-Fungible Token ” or “NFT” means a unique, non -interchangeable digital \r\nrepresentation of value or rights recorded on a distributed ledger or similar \r\ntechnology, where each token is distinguishable from every other token; \r\n(xxi)  “Official or Fiat Curre ncy” means a currency issued by the central bank or \r\nmonetary authority of a country that is recognized as legal tender under the laws \r\nof that country; \r\n(xxii)  “Person” means a natural or legal Person; \r\n(xxiii) “Prescribed” means prescribed by Rules or Regulations made under this Act; \r\n(xxiv) “Regulations” means Regulations made under this Act; \r\n(xxν) “Rules” means Rules made under this Act; \r\n(xxvi) “Segregated Reserve” means a pool of reserve assets that is kept separate from the \r\nIssuer’s own assets, held in the name of the Issuer, or in a trust or special vehicle \r\nfor the benefit of token holders, and under custody, with independent custodian or \r\nregulated financial institution, approved by the authority, so that the Issuer or its \r\ncreditors cannot claim the ass ets. The Authority may, by Regulations, prescribe \r\nadditional requirements regarding the types of assets, custody arrangements, \r\naudits, attestations, disclosures, and other safeguards; \r\n(xxvii) “Shariah Advisory Committee” means the committee constituted by the Authority \r\nfor advice on Shariah matters; \r\n(xxviii) “Special Court ” means a court notified by the Federal Government to take \r\ncognizance of offence as mentioned under this Act; \r\n(xxix) “Sponsor” means a person or group of persons who has contributed initial capital \r\nto establish the company or hold a controlling shareholding therein, whether \r\ndirectly or indirectly; \r\n(xxx)  “Tribunal” means a Tribunal constituted under this Act; \r\n(xxxi)  “Virtual Asset” means a digital representation of value that can be digitally traded \r\nor transferred and used for payment or investment purposes, but does not include \r\n \r\nPage 10 of 35 \r\n \r\ndigital representations of fiat currency, securities or other financial assets \r\nregulated under any other law except where represented, issued, or transferred \r\nusing distributed ledger technology. For the avoidance of doubt, Virtu al Assets \r\nare not legal tender; \r\n(xxxii) ”Virtual Asset services” means the categories of services set out in section 18 of \r\nthis Act; and \r\n(xxxiii) “Virtual Asset Service Provider” means any Person who, as a business, provides \r\none or more Virtual Asset Services to third parties on a professional basis. \r\n(2) All other words and expressions not defined in this Act but defined in the State Bank of \r\nPakistan Act, 1956 (XXXIII of 1956), the Securities Act, 2015, (III of 2015) the Anti-Money Laundering \r\nAct, 2010 (VII of 2010), or the Companies Act, 2017 (XIX of 2017) shall, unless the context otherwise \r\nrequires, have the meanings assigned to them in those Acts. \r\n4. Extraterritorial application. —(1) For the purposes of investigation and enforcement under \r\nthis Act, the Authority may exercise its powers extraterritorially to the fullest extent permitted by law. \r\n(2) In order to facilitate enforcement under this section and the effective regulation of Virtual \r\nAsset Services with cross-border implications, the Authority may enter into agreements or arrangements \r\nwith regulatory authorities and law enforcement agencies in other jurisdictions for mutual assistance, \r\ninformation sharing, and the recognition and enforc ement of regulatory decisions, and shall, by \r\nRegulations, prescribe the conditions under which a Virtual Asset Service conducted outside Pakistan \r\nshall or shall not be deemed to be offered or marketed to Persons in Pakistan. \r\n(3) The Authority shall, where applicable, align its extraterritorial enforcement practices with \r\nmutual legal assistance treaties and international cooperation frameworks, including those of the \r\nFinancial Action Task Force and International Organization of Securities Commissions (IOSCO). \r\n5. Relationship with other laws. —(1) The provisions of this Act are in addition to, and not in \r\nderogation of, any other law for the time being enforce. In the event of any inconsistency with any other \r\nlaw, other than the Foreign Exchange Regulation Act, 1947 (VII of 1947), this Act shall prevail except \r\nas provided below. \r\n(2) Where any law prescribes measures relating to data protection, data governance, or \r\ncybersecurity, financial secrecy or cross -border transfer of personal data, such provisions shall pr evail \r\nand be complied with by the Authority and Licensees. \r\n(3) The regulation and supervision of Virtual Assets, Virtual Asset Service Providers, \r\ntokenization of real-world assets, and blockchain technology shall vest primarily in the Authority under \r\nthis Act, in coordination with other relevant regulators where applicable. \r\n \r\n \r\n \r\n \r\nPage 11 of 35 \r\n \r\nChapter-2 \r\nPAKISTAN VIRTUAL ASSETS REGULATORY AUTHORITY \r\n6. Establishment of the Authority.—(1) After the commencement of this Act, an authority shall \r\nbe established to be known as the Pakistan Virtual Assets Regulatory Authority, which shall carry out \r\nthe purposes of this Act. \r\n(2) The Authority shall be a body corporate with perpetual succession and a common seal and \r\nmay sue and be sued in its name. \r\n(3) The Authority shall be autonomous  in the performance of its functions and exercise of its \r\npowers, subject to this Act. \r\n(4) The headquarters of the Authority shall be at Islamabad, and it may set up as many offices \r\nacross Pakistan as required. \r\n7. Composition of Authority.— (1) The Authority shall consist of the following, namely:— \r\n(a)  Chairperson - to be appointed by the Federal Government \r\n(b)  the Secretary, Ministry of Finance; \r\n(c)  the Secretary, Ministry of Law and Justice; \r\n(d)  the Governor, State Bank of Pakistan; \r\n(e)  the Chairperson, Securities and Exchange Commission of Pakistan; \r\n(f)  the Chairman, National AML-CFT Authority; \r\n(g)  the Chairperson, Pakistan Digital Authority; and \r\n(h)  two independent directors with proven expertise and a strong track record \r\npossessing expertise relevant to Virtual Asset markets, digital technology, digital \r\nfinance, appointed by the Federal Government in the manner Prescribed. \r\n(2) The members of the Authority, other than ex-officio members, shall hold office for a term of \r\nthree years and shall be eligible for one further term of three years. \r\n(3) The Authority shall determine its own policy and strategic direction and approve its budget \r\nand Regulations. \r\n8. Procedures of the Authority. —(1) The Authority may meet any time on requisition of the \r\nChairperson or at requisition of at least fifty percent of the members. Provided however, the Authority \r\nshall meet at least twice a year. \r\n(2) The quorum of the Authority's meeting shall be at fifty percent of the total membership with \r\nthe mandatory presence of the (a) (b) and (d) as mentioned in section 7. \r\n(3) A meeting of the Authority shall be presided over by the Chairperson. In the absence of the \r\nChairperson, a member nominated by the Chairperson shall preside over the meeting. \r\n \r\nPage 12 of 35 \r\n \r\n(4) All decisions in the meeting shall be made with majority of the present members. \r\n9. Objectives, functions and powers of the Authority.—(1) The Authority shall:— \r\n(a)  license, regulate and supervise Virtual Asset Service Providers and issuers in \r\naccordance with the provisions of this Act and any Rules or Regulations made \r\nthereunder, \r\n(b)  protect customers and investors and the Integrity of Pakistan's Virtual Asset \r\nmarkets by establishing and enforcing appropriate safeguards and conduct of \r\nbusiness requirements, prudential, operational-resilience, risk -management \r\nstandards, and measures to prevent money laundering, terrorist financing and \r\nother illicit use of Virtual Assets; \r\n(c)  attract investment and encourage companies operating in the fields of Virtual \r\nAssets to base their business in Pakistan; \r\n(d)  promote responsible innovation, digital financial inclusion and the development \r\nof compliant Virtual Asset markets within a framework that manages risks and \r\nsupports financial stability and market integrity; \r\n(e)  promote, develop, govern, and regulate the adoption, deployment, and scalable \r\nuse of blockchain technology and distributed ledger technology across Pakistan; \r\n(f)  assess, determine, and classify any Virtual Asset, service, activity, offering, \r\nIssuer, or service provider based on its substantive features, underlying function, \r\nmethod of use, or economic effect, irrespective of the nomenclature, structure, or \r\ndesignation assigned to it. Such classification may include, but is not limited to \r\nthe determination of whether an asset is a Virtual Asset, whether a Person qualifies \r\nas a Virtual Asset Service Provider, or whether an offering constitutes a financial \r\nactivity within the scope of this Act subject to consultation with the State Bank of \r\nPakistan or the Securities and Exchange Commission of Pakistan where the asset \r\nexhibits characteristics falling within their respective mandates; \r\n(g)  coordinate with the Financial Monitoring Unit, National AML and CFT \r\nAuthority, other relevant authorities and law enforcement agencies to co mbat \r\nmoney laundering, terrorist financing, and other illicit activities associated with \r\nVirtual Assets, in accordance with the Anti-Money Laundering Act, 2010 (VII of \r\n2010), other applicable laws, and international standards; \r\n(h)  advise the Federal Government, on its own motion or upon request, on regulatory, \r\nsupervisory, technical or emerging risk matters relating to Virtual Assets, digital-\r\nasset markets, tokenisation, stablecoin structures, blockchain, DLT, cyber-risks or \r\nany matter connected with its mandate under this Act; and \r\n(i)  do all such acts as may be necessary or incidental to the discharge of its functions \r\nand to achieve its objectives under this Act and other applicable laws. \r\n \r\nPage 13 of 35 \r\n \r\n(2) For the purposes of sub-section (1), and without prejudice to the generality of the foregoing, \r\nthe Authority may— \r\n(a)  make Regulations, standards, directives, guidelines, handbooks and circulars, or \r\nany other instrument, consistent with the objectives of this  Act and other \r\napplicable laws; \r\n(b)  set prudential, conduct operational resilience, risk -management, cybersecurity, \r\ndata protection & technical standards; \r\n(c)  issue, vary, suspend or revoke licenses, approvals or directives under this Act and \r\nprescribe conditions for such actions; \r\n(d)  prescribe licensing conditions, eligibility criteria, renewal requirements and any \r\nadditional obligations for Licensees; \r\n(e)  conduct on-site inspections and off-site monitoring of Licensees and other entities \r\nto ensure compliance with this Act and relevant Rules and Regulations; \r\n(f)  require Licensees to furnish information, documents and data in the manner and \r\ntimeframe reasonably Prescribed by Regulations; \r\n(g)  ensure compliance of data -protection, data -governance and cyber security \r\nobligations by Virtual Asset Service Providers subject to supervisory follow-up; \r\n(h)  impose administrative sanctions in accordance with the provisions of this Act and \r\nany Rules or Regulations made thereunder; \r\n(i)  apply to court for civil or criminal remedies as provided under any applicable law; \r\n(j)  levy such fees, charges and penalties as may be Prescribed by Rules; \r\n(k)  operate regulatory sandboxes in a transparent and accountable manner; \r\n(1)  enter into cooperation or mutual assistance arrangements with domestic and \r\nforeign regulators and law enforcement agencies to facilitate Information sharing \r\nand coordinated action, including mutual recognition of Regulations and licenses; \r\n(m)  conduct public education and awareness initiatives to promote informed \r\nparticipation in the Virtual Asset ecosystem; and \r\n(n)  constitute as many committees as deemed necessary to conduct its functions under \r\nthis Act. \r\n10. Delegation of powers.—The Authority may delegate any of its powers and functions to the \r\nManaging Director, subject to such terms, conditions, and limitations as it may deem appropriate. \r\n11. Appointment and Functions of Chairperson.— (1) The Chairperson of the Authority shall \r\nbe appointed by the Federal Government on such terms and conditions as it may deem fit. The \r\nChairperson shall have demonstrable expertise in digital finance or technology and a minimum of three \r\n \r\nPage 14 of 35 \r\n \r\nyears' relevant professional experience, and shall be eligible for re-appointment for maximum two terms \r\non such term or terms as the Federal Government may determine. \r\n(2) The Chairperson shall provide overall guidance, direction, and oversight of the Authority. \r\n(3) The Chairperson shall only be removed prior to the expiry of the term for gross misconduct \r\nor incapacity following a show cause notice and opportunity to be heard. \r\n(4) The Chairperson may resign by writing to the Prime Minister. \r\n12. Appointment and Fun ctions of Managing Director. —(1) The Authority shall  appoint a \r\nManaging Director for a term of three years, extendable for a further maximum of two term of three \r\nyears only. \r\n(2) The Managing Director shall be a person of proven integrity and competence, and shall meet \r\nsuch qualifications, criteria, and requirements as may be prescribed by Regulations. \r\n(3) The Managing Director shall act as Secretary of the Authority for its pr oceedings but shall \r\nnot have voting rights unless specifically authorized. \r\n13. Appointment of Officers, Staff, Consultants, Advisors and other personnel. —(1) The \r\nAuthority may, from time to time, create and sanction such posts, prescribe required qualifica tions and \r\nexperience, and determine terms of service through Regulations as required. \r\n(2) The Authority may, through a transparent and competitive process prescribed by Regulations, \r\nappoint such employees, officers, consultants, and technical or professional advisers as are necessary for \r\nthe performance of its functions and the exercise of its powers under this Act. \r\n(3) The Authority may, as prescribed by Regulations, request any Ministry, Division, public \r\nauthority, public entity or autonomous or regulatory body to assign an official with requisite expertise to \r\nthe Authority for such period as may be mutually agreed. \r\n14. Pakistan Virtual Asset Regulatory Authority Fund. —(1) There shall be established a \r\nlapsable fund, vested in and administered and controlle d by the Authority, to be known as the Pakistan \r\nVirtual Asset Regulatory Authority Fund, for meeting expenditures in connection with the performance \r\nof the functions and operations of the Authority under this Act. \r\n(2) Subject to the provisions of the Public Finance Management Act, 2019 (V of 2019), the Fund \r\nshall consist of— \r\n(a)  funds provided by the Federal Government for salaries, infrastructure, \r\nadministrative, operational, and other expenses, including the day -to-day \r\nfunctioning of the Authority; \r\n(b)  loans or funds obtained from the Federal Government, any Provincial \r\nGovernment, a local authority or any other entity with the approval of the \r\nAuthority; \r\n(c)  grants made by the Federal Government; \r\n \r\nPage 15 of 35 \r\n \r\n(d)  aids, grants, donations, or loans raised or obtained by the Authority from domestic \r\nand international agencies, in consultation with the Division to which the business \r\nof finance stands allocated and other relevant Divisions; \r\n(e)  contributions from multilateral organisations, international agencies, and \r\nphilanthropic organisations for purposes consistent with the objectives of the \r\nAuthority, to be managed in accordance with regulations ensuring tr ansparency \r\nand good governance; \r\n(f)  all sums or property which may in any manner become payable to or vested in the \r\nAuthority in connection with the exercise of its powers or performance of its \r\nfunctions; \r\n(g)  income from investments and assets of the Authority; \r\n(h)  NOC, licensing, supervision, renewal or other fees received by the Authority; \r\n(i)  penalties, fines, settlements, and other recoveries imposed or realized under this \r\nAct or any Rules or Regulations made thereunder; \r\n(j)  charges for services rendered by the Authority, including sandbox participation \r\nand other prescribed services; and \r\n(k)  any other source as may be prescribed. \r\n(3) The Fund shall be managed and operated in such manner as may be prescribed by Regulations. \r\n(4) The Fund shall be maintained in such manner and with such institutions as the Authority may \r\ndetermine, subject to any requirements prescribed by Regulations. \r\n(5) The Pakistan Virtual Asset Regulatory Authority Fund may be expended for— \r\n(a)  paying any expenditure lawfully incurred by the Authority; \r\n(b)  payment of salaries and other remunerations payable to the chairperson, Managing \r\nDirector, Officers, employees, consultants, and advisers of the Authority; \r\n(c)  paying any other expenses, costs or expenditures properly incurred or approved \r\nby the Authority in the performance of its functions or the exercise of its powers \r\nunder this Act; \r\n(d)  purchasing or hiring equipment, machinery and other materials, acquiring land \r\nand constructing buildings, and carrying out any other work or undertakings in \r\nconnection with the performance of its functions or the exercise of its powers \r\nunder this Act; \r\n(e)  repayment of any loans or advances obtained under this Act, together with any \r\nassociated interest, charges or fees; \r\n \r\nPage 16 of 35 \r\n \r\n(f)  meeting any financial obligations or liabilities that arising out of the performance \r\nof the functions of the Authority under this Act; \r\n(g)  funding strategic and enabling projects or initiatives necessary to support the \r\nobjective of this Act or to enhance the operational capabilities of the Authority \r\nand its stakeholders; \r\n(h)  meeting expenses relating to investigations, inspectio ns, enforcement actions, \r\nlegal proceedings, arbitration, mediation, and dispute resolution, including court \r\nfees, expert fees, and legal costs; and \r\n(i)  capacity-building, research, training, certification, and i nternational cooperation \r\nactivities, including participation in regional or international regulatory forums. \r\n15. Budget, Finance and Audit. —(1) The Authority shall, in respect of each financial year, \r\nprepare and approve its budget in accordance with the procedure prescribed through Rules. \r\n(2) The budget statement shall specifically state the estimated receipts and expenditure and the \r\nsums which are to be required from the Federal Government during the next financial year. \r\n(3) The Authority shall maintain complete and accurate books of accounts of its receipts of funds \r\nand expenditure. \r\n(4) At the end of each financial year, the accounts of the Authority shall be audited by the Auditor \r\nGeneral of Pakistan and by a firm of Chartered Accountants nominated by the Auditor General of \r\nPakistan. \r\n(5) The Author ity shall produce such accounts, books and documents and  furnish such \r\nexplanations and information as the auditors may require for the purpose of audit. \r\n(6) Copies of the auditor's report on the accounts shall be provided to the Authority. \r\n(7) The Authorit y shall submit an annual report of the fund under this section to the Prime \r\nMinister through the concerned Division within ninety days of the close of each financial year, including \r\naudited financial statements and performance against approved objectives, and such other matters as the \r\nAuthority may consider necessary for transparency and accountability. \r\n16. Code  of conduct. —(1) The Chairpe rson, Members of the Authority i ncluding ex-officio \r\nMembers, Managing Director, officers and employees of the Authority, shall, in the performance of their \r\nfunctions, act with integrity, impartiality, confidentiality and in good faith, and shall avoid any conflict \r\nof interest, whether direct or indirect. \r\n(2) The Authority shall prescribe, by Regulations, a Code of Conduct applicable to the \r\nChairperson, Members of the Authority, Managing Director, officers and employees of the Authority, \r\nincluding provisions relating to , disclosure of interests, conflict man agement, restrictions on personal \r\ntrading in Virtual Assets, confidentiality, and post-tenure obligations. \r\n \r\nPage 17 of 35 \r\n \r\n(3) Any violation of the provisions of this section or the Code of Conduct prescribed thereunder \r\nshall constitute misconduct and shall result in remo val from office or service, as the case may be, and \r\nthe initiation of disciplinary proceedings. \r\n17. Inter-agency cooperation and information-sharing.—(1) For the effective regulation and \r\nsupervision of Virtual Assets and Virtual Asset Service Providers, an d to prevent their misuse, the \r\nAuthority shall cooperate and share supervisory and enforcement information, in a timely and secure \r\nmanner, with the State Bank of Pakistan, the Securities and Exchange Commission of Pakistan, We \r\nFinancial Monitoring Unit, th e Federal Investigation Agency, the Federal Board of Revenue, and any \r\nother competent regulatory or law-enforcement agencies or bodies. \r\n(2) The Authority may, with the prior approval of the Federal Government, enter into cooperation \r\narrangements or information-sharing arrangements with foreign regulatory or supervisory authorities for \r\ncross-border supervision, enforcement and mutual assistance relating to Virtual Assets and Virtual \r\nAssets Service Providers. \r\n(3) The Authority may establish one or more inter-agency coordination mechanisms, including a \r\nregulatory coordination committee, comprising representatives of relevant public authorities, to facilitate \r\npolicy coordination, information -sharing, supervision, enforcement, and risk mitigation in relation to \r\nVirtual Assets and Virtual Asset Service Providers. \r\nChapter 3 \r\nLICENSING OF VIRTUAL ASSET SERVICE PROVIDERS AND ISSUANCE OF VIRTUAL \r\nASSETS \r\n18. Categories of virtual asset services. —The following constitute Virtual Asset Services and \r\nshall be subject to licensing and regulation under this Act: \r\n(a)  all services as specified in Schedule I; and \r\n(b)  any other service as may be notified by the Federal Government and subsequently \r\nincluded in Schedule I of this Act. \r\n19. Application for License. —(1) Any Person intending to incorporate a company, under the \r\nCompanies Act, 2017 (XIX of 2017) or any other law for the time being in force, with the primary \r\nobjective of engaging in Virtual Asset Services shall first apply to the Authority for a No -Objection \r\nCertificate before commencing the process of such incorporation. \r\n(2) An application for a No -Objection Certificate under sub -section (1) shall be made in such \r\nform and manner, accompanied by such information and fee as may be prescribed by the Authority. \r\n(3) Upon review of an application for No-Objection Certificate, the Authority may, having regard \r\nto the objects of this Act and the need to ensure the integrity of the Virtual Asset market, grant the \r\napproval or certificate, subject to any conditions, or refuse the application, providing written reasons for \r\nrefusal. \r\n \r\nPage 18 of 35 \r\n \r\n(4) An application for a license, following incorporation of the company, shall be made to the \r\nAuthority in such form and manner as may be prescribed. It shall be accompanied by- \r\n(a)  the prescribed fee, which shall be non-refundable unless otherwise determined by \r\nthe Authority; and \r\n(b)  such information and documents as may be prescribed or required by the \r\nAuthority. \r\n20. Fit-and-proper criteria.—(1) The Authority shall determine whether a Controller, Sponsor, \r\nChief Executive Officer and Director is fit and proper in accordance with criteria prescribed by \r\nRegulations. \r\n(2) The fit-and-proper criteria shall apply to all Key Individuals. It shall be the responsibility of \r\nthe applicant for a license or the lice nsee to assess and maintain the fitness and propriety of other key \r\nindividuals not mentioned in sub -section (1), and to submit a written undertaking to the Authority \r\nconfirming compliance and ongoing maintenance thereof. \r\n(3) The Authority may refuse, suspend or revoke a license where any Controller, Sponsor or Key \r\nIndividual fails to meet the prescribed fit-and-proper criteria. \r\n(4) Fit-and-proper criteria shall be continuing in nature, and any person subject to such criteria \r\nshall notify the Authority of any matter that may affect their fitness and propriety. \r\n(5) The Authority shall prescribe additional requireme nts for corporate Controllers, i ncluding \r\nassessment of the corporate behaviour, i ntegrity and track record of Controller and ultimate beneficial \r\nowners. \r\n(6) Every Licensee shall maintain a registered office in Pakistan and ensure that at least one Key \r\nIndividual ordinarily resident in Pakistan is vested with operational and decision -making authority \r\nsubject to conditions prescribed. \r\n21. Grant, refusal and terms of license.—(1) Subject to this Act and any Rules or Regulations \r\nmade thereunder, the Authority may— \r\n(a)  grant a license, subject to such terms and conditions as it may deem appropriate; \r\nor \r\n(b)  refuse the application, providing the applicant w ith written reasons for such \r\nrefusal. \r\n(2) The Authority may, on a case-by-case basis, grant a provisional or a limited-scope licence to \r\nan applicant, subject to such terms and conditions as may be prescribed. \r\n(3) A license granted to a Virtual Asset Service Providers shall specify the Virtual Asset Services \r\nthat is permitted to undertake and shall remain in force unless suspended or revoked. \r\n \r\nPage 19 of 35 \r\n \r\n(4) The Authority shall maintain and publish an up -to-date register of Licensees on its official \r\nwebsite. The registe r shall include, at a minimum, the name, license number, permitted services and \r\ncurrent regulatory status of each Licensee. \r\n22. Ongoing obligations of licensees.—A Licensee shall, at all times— \r\n(a)  maintain the prescribed minimum paid-up capital and financial resources; \r\n(b)  comply with this Act and all Rules, Regulations, directives and guidelines issued \r\nby the Authority; \r\n(c)  submit such periodic returns, reports and audited financial statements as may be \r\nprescribed; \r\n(d)  obtain the prior approval of the  Authority for any material change in control or \r\nbusiness, in the manner prescribed; \r\n(e)  maintain risk-management, compliance and cybersecurity systems in accordance \r\nwith applicable legal and regulatory requirements including adherence to data \r\nprivacy standards; and \r\n(f)  pay such supervision, renewal or other fees as may be prescribed. \r\n23. Variation, suspension and revocation of license. —(1) The Authority may, by way of \r\nwritten notice and after providing an opportunity of being heard, vary, suspend or revo ke a license if it \r\nis found that— \r\n(a)  the Licensee has contravened any provisions of this Act or any other applicable \r\nlaws, or any terms or condition of its license; \r\n(b)  the Licensee is insolvent or no longer satisfies the fit-and-proper criteria; \r\n(c)  the Licensee has ceased to carry on the Virtual Asset Service for which it is \r\nlicensed; or \r\n(d)  such action is necessary or expedient in the public interest, including for the \r\nprotection of consumers, the integrity of the market, or financial stability, or \r\n(e)  the license was obtained by fraud, misrepresentation, or  concealment of material \r\nfacts. \r\n(2) Where a license is revoked, the Licensee shall immediately cease the provision of Virtual \r\nAsset Services, and the Authority may notify the Securities and Excha nge Commission of Pakistan to \r\ninitiate winding-up or dissolution proceedings in accordance with the Companies Act, 2017 (XIX of \r\n2017) and any Regulations that may be prescribed under this Act. \r\n(3) The Authority may, by Regulations prescribe further procedu res, timelines, and safeguards \r\nfor variation, suspension, or revocation under this section. \r\n \r\n \r\nPage 20 of 35 \r\n \r\nChapter-4 \r\nPRUDENTIAL REQUIREMENTS, SAFEGUARDING AND CUSTODY \r\n24. Segregation of customer assets. —(1) A Licensee shall, at all times, hold Customer Assets \r\nin segregated accounts separate from its own assets, in the manner prescribed by Regulations. \r\n(2) Notwithstanding anything to the contrary contained in any other law for the time being in \r\nforce, Customer Assets held by a Licensee shall not form part of the Licensee’s estate in the event of its \r\ninsolvency or liquidation. \r\n(3) Licensee owes a fiduciary duty to its customers and shall at all times act honestly, fairly, and \r\nin the best interests of its customers when dealing with Customer Assets. \r\n(4) A Licensee sha ll not rehypothecate, lend, pledge, or otherwise encumber Customer Assets, \r\nwhether Virtual Assets or fiat balances, without the customer’s explicit, informed, and revocable written \r\nconsent. \r\n25. Minimum financial resource requirements. —(1) A Licensee shall,  at all times, maintain \r\nsuch minimum paid-up capital, liquid assets and financial resources not less than such amounts as may \r\nbe prescribed. \r\n(2) The Authority may, having regard to the category, size, complexity, or risk profile of a \r\nLicensee, prescribe higher financial-resource requirements. \r\n(3) The Authority may, by Regulations, prescribe additional liquidity, margin, risk-based capital \r\nor reserve requirements having regard to the risks posed by the Licensee’s activities. \r\n(4) The Authority may, in the manner prescribed by Regulations, grant conditional or risk-based \r\nexemptions from requirements under this section for limited-scope or low-risk Licensees. \r\n26. Custody standards and key -management controls. —(1) A Licensee providing custody \r\nservices for Virtual Assets shall: \r\n(a)  ensure the secure custody and protection of Virtual Assets against unauthorized \r\naccess, loss, or misuse; and \r\n(b)  maintain operational resilience, including robust disaster -recovery and business-\r\ncontinuity arrangements. \r\n(2) The Authority shall prescribe detailed technical standards, operational requirements, and audit \r\nprocedures to ensure that Licensees meet the obligations under this clause, including but not limited to, \r\nstandards for key management, custody mechanisms, and verification of assurance processes. \r\n27. Proof-of-reserves and audit obligations.—(1) A Licensee shall furnish to the Authority, at \r\nsuch intervals as may be Prescribed by Regulations, cryptographic proof -of-reserves reconciled against \r\nits liabilities to customers. \r\n \r\nPage 21 of 35 \r\n \r\n(2) A Licensee shall cause its operations to be audited annually by a firm of Chartered \r\nAccountants approved by the Division concerned. Such audit shall include a verification of the \r\nsegregation of Customer Assets as required under section 24. \r\n28. Reserve cus todians.—A custodian of reserve assets shall comply with such requirements, \r\noversight and inspection standards as may be prescribed by Regulations. \r\n29. Customer safeguard or compensation mechanism. —The Authority may, establish a \r\ncustomer-compensation or safeguard mechanism for losses arising from custodial failure, in such manner \r\nas may be prescribed by Regulations. \r\nChapter-5 \r\nFIAT-REFERENCED AND ASSET-REFERENCED TOKENS \r\n30. I nitial Virtual Asset Offerings. — (1) Only legal entities, as registered in Pakista n and \r\nmeeting the eligibility criteria prescribed by Regulations shall be permitted to conduct an Initial Virtual \r\nAsset Offering. \r\n(2) The Authority may prescribe, by Regulations, the conditions, disclosure requirements, \r\napproval processes and ongoing obligations applicable to Initial Virtual Asset Offerings. \r\n31. Issuance Requirements for Fiat-Referenced Tokens.—(1) Any Issuer intending to issue a \r\nFiat-Referenced Token in Pakistan shall comply with following requirements: \r\n(a)  Hundred percent reserve backing , with High -Quality Liquid Assets (HQLA) or \r\nother assets as prescribed for fiat referenced token, held as a segregated reserve; \r\n(b)  mechanisms for redemption at par value without undue delay; \r\n(c)  audited reserve disclosures as prescribed by the Authority; \r\n(d)  robust AML, CFT, CPF and sanctions compliance programs; \r\n(e)  prioritized holder protections in insolvency; and \r\n(f)  any other requirement prescribed by the Authority. \r\n(2) The Authority may prescribe differentiated requirements based on the size, scope, complexity, \r\nor risk profile of the issuer, including but not limited to, expedited approval, stress testing, ongoing \r\nsupervision, and consultation with the State Bank of Pakistan on reserve arrangements. \r\n32. Issuance Requirements for Asset-Referenced Tokens.—(1) Any Issuer intending to issue \r\nAsset-Referenced Token in Pakistan shall comply with following requirements: \r\n(a)  a reserve of the underlying assets, as prescribed, for Assets-referenced token held \r\nin custody in accordance with Regulations; \r\n(b)  audited reserve disclosures as prescribed by the Authority;  \r\n(c)  robust AML, CFT, CPF and sanctions compliance programs; \r\n \r\nPage 22 of 35 \r\n \r\n(d)  prioritized holder protections in insolvency; and \r\n(e)  any other requirement prescribed by the Authority. \r\n(2) An Asset-Referenced Token shall at all times be fully backed by the underlying assets and \r\nmay reference tangible or intangible assets, including but not limited to commodities, real estate, real -\r\nworld assets, securities, financial assets, or a combination of official currencies, but shall not be backed \r\nor derive its value from other Virtual Assets. \r\n(3) The Authority may prescribe differentiated requirements based on the size, scope, complexity, \r\nor risk profile of the Issuer, including, but not limited to, expedited approval, s tress testing, ongoing \r\nsupervision, and consultation with the State Bank of Pakistan on reserve arrangements. The Authority \r\nmay prescribe eligible categories of underlying assets and may restrict or prohibit types of assets for the \r\nissuance of Asset-Referenced Token. \r\n33. Significant issuers. —(1) An Issuer shall be deemed a Significant Issuer if it meets the \r\nthresholds and criteria prescribed by Regulations, having regard to size, scal e, systemic importance, \r\nmarket impact, number of holders, and cross-border activity. \r\n(2) Significant Issuers shall be registered with the Authority and shall comply with enhanced \r\nrequirements, including reporting, disclosure, governance, and risk management, as prescribed in \r\nRegulations. \r\nChapter-6 \r\nCYBERSECURITY, SANDBOX AND INNOVATION \r\n34. Cybersecurity and operational resilience.—Licensees shall comply with cybersecurity and \r\noperational-resilience requirements prescribed by the Authority or under any other applicable laws, \r\nincluding, but not limited to, technical standards, security controls, and reporting mechanisms. \r\n35. Regulatory sandbox. —(1) The Authority may establish a regulatory sandbox to facilitate \r\ncontrolled testing of innovative Virtual Asset s products or services, in the manner prescribed by \r\nRegulations. \r\n(2) Eligibility, application procedures, supervisory arrangements, risk limits, duration and exit \r\nrequirements shall be prescribed by Regulations. \r\n(3) The Authority may issue guidance, no -objection statements or no-action communications in \r\naccordance with Regulations. \r\n36. Oversight of blockchain technology adoption.—(1) The Authority shall issue Regulations, \r\nstandards, directives, and guidelines on the adoption, deployment, and use of blockchain or distributed-\r\nledger technology. \r\n(2) The Authority shall consult with rele vant regulators and ministries to ensure harmonization \r\nof blockchain adoption across Pakistan. \r\n \r\nPage 23 of 35 \r\n \r\n37. Regulation of Virtual Asset Mining Activities. —(1) The Authority may, in consultation \r\nwith relevant government entities, issue Regulations, standards, and guidelines for mining activities. \r\n(2) Pure mining, by itself, does not constitute a Virtual Asset Service requiring license  under \r\nsection 18 and Schedule I . Mining operations i nvolving customer assets or funds, however, shall be \r\ntreated as Virtual Asset Services and require licensing. \r\n(3) The Authority may establish a registration or declaration framework for mining operators \r\nexceeding thresholds of scale, energy use, or hash rate, as set by Regulations. \r\n38. Establishment of Strategic Digital Wallet Company. —(1) The Federal Government may \r\nestablish or designate, under the Companies Act, 2017 [XIX of 2017), a wholly owned company to be \r\nknown as the Strategic Digital Wallet Company (SDWC) to perform custody and administration \r\nservices, and to design, develop, operate and secure wallet infrastructure that enables the Government of \r\nPakistan or other designated public bodies or institutions to manage, transfer and record Virtual Asset s \r\nin furtherance of the Company’s strategic reserve objectives. \r\n(2) The Company sha ll operate exclusively on behalf of the Government of Pakistan and \r\ndesignated public bodies and shall not provide services to the private persons. \r\n39. Data localization framework.— (1) A Licensee may store or process data outside Pakistan, \r\nsubject to compliance with applicable laws relating to data protection, cybersecurity, and cross -border \r\ndata transfers, and subject to such safeguards as shall be prescribed by Regulations. \r\n(2) Nothing in this section shall prevent the Authority from requiring immediate l ocalization or \r\nrestricted cross-border transfer of specific datasets where necessary in the interest of national security, \r\nfinancial stability, consumer protection, or enforcement effectiveness. \r\n40. Data segregation and protection of sensitive information. —(1) Every Licensee shall \r\nimplement appropriate technical, organizational, and governance measures to ensure the segregation of \r\nsensitive information from other operational data, in such manner as may be prescribed by Regulations. \r\n(2) For the purposes of this section, “sensitive information” shall include, but not be limited to- \r\n(a)  customer identification and due-diligence; \r\n(b)  transaction-level data capable of identifying a customer; \r\n(c)  private keys, cryptographic credentials, or wallet authentication data; \r\n(d)  proprietary trading data and risk-management systems; and  \r\n(e)  any other category of information designated as sensitive by the Authority. \r\n(3) A Licensee shall ensure that— \r\n(a)  sensitive information is logically and t echnically segregated from non -sensitive \r\ndata; \r\n(b)  access to sensitive information is strictly controlled on a need-to-know basis; \r\n \r\nPage 24 of 35 \r\n \r\n(c)  encryption, tokenization, and secure key-management protocols are implemented \r\nin accordance with internationally recognised standards; and \r\n(d)  appropriate audit trails and monitoring mechanisms are maintained. \r\n(4) The Authority may prescribe, by Regulatio ns, minimum technical standards,  cybersecurity \r\ncontrols, storage architectures, encryption requirements, and data-governance frameworks to give effect \r\nto this section. \r\nChapter-7 \r\nMARKET CONDUCT, CONSUMER PROTECTION \r\n41. Duty of integrity and fair dealing. —(1) A Licensee shall conduct its business honestly, \r\nfairly and professionally and in accordance with the best interests of its customers and in a manner that \r\nupholds the integrity of the market. \r\n(2) The Authority may prescribe, by Regulations, detailed requirements relating to market \r\nconduct, including standards of fair dealing, professional behaviour, and customer treatment. \r\n42. Obligations of issuers of Virtual Assets. —(1) An Issuer offering a Virtual Asset to the \r\npublic shall publish a whitepaper in such form and manner as may be prescribed by Regulations. \r\n(2) Issuers shall make ongoing disclosures of material information including reserve attestations \r\nin the manner and frequency prescribed by Regulations. \r\n(3) The Authority may exempt categories of Issuers or offerings from requirements under this \r\nsection, subject to appropriate safeguards. \r\n(4) The Authority shall prescribe, by Regulations, mandatory risk disclosures, periodic reporting \r\nrequirements and disclosure templates applicable to Issuers and Licensees. \r\n43. Marketing and conduct restrictions. —(1) No person shall advertise or market a Virtual \r\nAsset unless the Issuer holds a valid license or registration under this Act. \r\n(2) All marketing materials shall contain risk disclosures and shall comply with such conditions, \r\nstandards and limitations, in such form and manner, as may be prescribed by the Authority. \r\n44. Conflic t-of-interest management. —A Licensee shall identify, manage, and disclose \r\nconflicts of interest and shall not place its own interests above those of its customers, in accordance with \r\ndetailed requirements on policies, disclosure, and management as may be prescribed by the Authority by \r\nRegulations. \r\n45. Complaint-handling and dispute resolution. —(1) Licensees shall establish and maintain \r\ninternal complaint-handling procedures in accordance with the requirements prescribed by Regulations. \r\n(2) Notwithstanding anything contained in any other law for the time being in force, the Authority \r\nmay establish or recognize an independent dispute -resolution scheme for claims below a prescribed \r\nmonetary threshold. \r\n \r\nPage 25 of 35 \r\n \r\nChapter-8 \r\nANTI-MONEY LAUNDERING, COUNTERING OF TERRORISM FINANCING AND \r\nCOUNTERING OF PROLIFERATION FINANCING \r\n46. Application of A nti-Money Laundering Act, 2010. —(1) For the purposes of the Anti -\r\nMoney Laundering Act, 2010 (VII of 2010), Virtual Asset Service Providers licensed under this Act \r\nshall be deemed to be financial institutions, and shall comply with all obligations thereunder. \r\n(2) Without prejudice to sub-section (1), every Virtual Asset Service Provider and Issuer shall- \r\n(a)  report suspicious transactions to the Financial Monitoring Unit (FMU) in \r\naccordance with Anti-Money Laundering Act, 2010 (VII of 2010) and any rules, \r\nregulations or guidelines issued thereunder; \r\n(b)  maintain records of customer due diligence, transactions and other relevant \r\ninformation for the period prescribed under Anti -Money Laundering Act, 2010 \r\n(VII of 2010); and \r\n(c)  establish and maintain i nternal controls and compliance programmes to prevent \r\nmoney laundering and terrorist financing, including the appointment of an AML, \r\nCFT or CPF compliance officer. \r\n(3) The Authority shall, through AML, CFT or CPF Regulations, align its supervisory framework \r\nwith the standards of the Financial Action Task Force (FATF) and may issue additional guidance, \r\nconsistent with FMLI’s mandate, to address risks specific to Virtual Assets. \r\n47. Travel rule and record-keeping obligations. (1) A Licensee shall obtain, hold and transmit \r\noriginator and beneficiary information in any transfer of Virtual Assets meeting or exceeding the \r\nthreshold prescribed by the Authority, in a manner consistent with Recommendations of Financial Action \r\nTask Force, as updated from time to time. \r\n(2) Such obligations shall be implemented in compliance with applicable data protection, data \r\ngovernance, and cybersecurity laws, ensuring the confidentiality, integrity, and sec urity of the \r\ninformation. \r\n(3) The Authority may prescribe detailed procedures, standards, and formats for record-keeping, \r\nreporting, and transmission of information through Regulations. \r\n(4) A Licensee shall maintain records of transactions, customer due -diligence data and risk \r\nassessments for a period prescribed by Regulations, which shall not be less than the period required \r\nunder the Anti-Money Laundering Act, 2010 (VII of 2010). \r\n48. Real -time data access and reporting. —(1) Licensees shall establish secur e reporting \r\nchannels, and where required secure automated interfaces, enabling the Authority and such other \r\nagencies as notified to access prescribed data for supervisory and enforcement purposes. \r\n(2) The Authority shall prescribe, by Regulations, the technical standards, security requirements \r\nand data specifications for the reporting and interfaces referred to in subsection (1). \r\n \r\nPage 26 of 35 \r\n \r\n49. Data Privacy Obligations for Licensed entities.- Each licensee shall implement strict limits \r\non the collection, use, and sharing of customer data, requiring explicit, informed, and revocable consent \r\nfor any non-essential data processing. \r\nChapter-9 \r\nProhibitions \r\n50. Prohibition of unlicensed Virtual Asset services.—(1) No Person shall, by way of business, \r\nengage in, or represent themselves as engaging in, any Virtual Asset Services in or from Pakistan, unless \r\nthat Person:- \r\n(a)  is a company incorporated under the Companies Act, 2017 or any other law for \r\nthe time being in force in Pakistan governing the incorporation of companies; and \r\n(b)  holds a valid license granted by the Authority under this Act. \r\n51. Prohibition on Initial Virtual Asset Offerings. —No Person shall conduct or purport to \r\nconduct an Initial Virtual Asset Offering, in or from Pakistan, except in accordance with this Act and the \r\nRules or Regulations made thereunder. \r\n52. Prohibition of market manipulation and insider trading. —(1) No person shall engage in \r\nmarket manipulation or Market abuse in relation to virtual assets. \r\n(2) No person shall: \r\n(a)  use inside information to trade virtual assets for themselves or others; \r\n(b)  recommend or induce trading based on inside information; or \r\n(c)  unlawfully disclose inside information. \r\n(3) The Authority shall issue guidelines and regulations specifying the type of manipulative \r\nbehavior. \r\n53. Prohibition on Algorithmic tokens.—No Person shall issue, offer, or market a Virtual Asset \r\nwhose primary mechanism for maintaining value is algorithmic and not fully or adequately \r\ncollateralized, unless specifically permitted by Regulations and  subject to the safeguards prescribed \r\ntherein. \r\nChapter-10 \r\nENFORCEMENT, OFFENCES AND PENALTIES \r\n54. Criminal offences. —(1) Whoever, willfully, provides an unlicensed Virtual Asset Se rvice \r\nshall be punishable with imprisonment for a term up to five years, or with fine up to fifty million Rupees, \r\nor with both. \r\n(2) Whoever conducts an Initial Virtual Asset s Offering in contravention of this Act, Rules and \r\nRegulations shall be punishable with imprisonment for a term up to three years, or with fine up to twenty-\r\nfive million Rupees or with both. \r\n \r\nPage 27 of 35 \r\n \r\n(3) Whoever, wilfully, contravenes section 52 shall be punishable: \r\n(a)  in the case of natural person, with imprisonment for a term up to three years or \r\nwith fine up to twenty-five million Rupees or with both. \r\n(b)  in the ca se of a legal person, with fine or three times the amount of any profit \r\ngained or loss avoided as a result of the contravention. If the amount of profit \r\ngained or loss avoided cannot be determined, a fine not exceeding 15% of the total \r\nannual turnover of the body corporate in the preceding financial year. \r\n(4) Whoever, knowingly, makes any false or misleading statement in any application, return or \r\ndocument submitted to the Authority shall be punishable with imprisonment for a term up to three years, \r\nor with fine up to twenty million Pakistani Rupees, or with both. \r\n(5) Whoever, obstructs an officer of the Authority in the exercise of powers under this Act shall \r\nbe punishable with imprisonment for a term up to two years, or with fine up to ten million Pakistan i \r\nRupees, or with both. \r\n(6) Whoever, willfully, fails to comply with any order or decision of the Authority shall be \r\npunishable with imprisonment up to one year, or with fine up to twenty -five million Pakistani Rupees \r\nand the Authority may also impose administrative penalties prescribed in this Act. \r\n(7) All offences punishable under this Act shall be investigated, tried, and punished in accordance \r\nwith the provisions of the Code of Criminal Procedure, 1898 (Act V of 1898) and the Qanun-e-Shahadat \r\nOrder, 1984 (Order X of 1984), unless otherwise provided in this Act. \r\n(8) The Federal Government may, by notification in the Official Gazette, designate one or more \r\nSpecial Courts to exercise jurisdiction over offences committed under this Act. \r\n55. Liability of offi cers of bodies corporate. —Where an offence under this Act i s committed \r\nby a body corporate with the consent, connivance or neglect of any director, manager, secretary or similar \r\nofficer, such Person shall be deemed to have committed the offence. \r\n56. Power to Investigate.—Only an authorized officer of the Authority shall have the power to \r\ninvestigate offences under this Act. \r\n57. Powers of Authorized Officer.—(1) For the purpose of investigation of offences under this \r\nAct, an authorised officer shall obtain a warrant for search and seizure of evidence of an offence from a \r\ncourt of competent jurisdiction. \r\n(2) The powers specified in sub -section (1), the authorized officer shall, for the purposes of \r\ninvestigation, inquiry, search, seizure, arrest, attachment, confiscation, and other criminal proceedings \r\nunder this Act, exercise all powers conferred upon an officer incharge of a police station or an \r\ninvestigating officer under the Code of Criminal Procedure, 1898 (Act V of 1898), subject to the \r\nprovisions of this Act. \r\n \r\nPage 28 of 35 \r\n \r\n(3) Any person who, wilfully, refuses to provide information required by the Authorized Officer \r\nunder sub-section (1) shall be punishable with imprisonment for a term up to one year or with fine up to \r\none million rupees or with both. \r\n(4) No Court sh all take cognizance of any offence under this Act except on a report in writing \r\nsubmitted by an authorized officer of the Authority. \r\n58. Prosecution of offences.—(1) All prosecutions under this Act shall be conducted by a special \r\npublic prosecutor appointe d by the Federal Government. The special public prosecutor, or advocates \r\nappointed by the Division concerned, may institute or defend cases, appeals, petitions, applications, and \r\nall other matters before any court, including the High Court and Supreme Court, arising from proceedings \r\nunder this Act. \r\n(2) The personal attendance of any officer authorized by the Authority to file a complaint shall \r\nnot be required during trial in the presence of the special public prosecutor referred to in sub-section (1). \r\n(3) The court shall, in a manner not inconsistent with this Act, follow the procedure provided \r\nunder Chapter XXII-A of the Code of Criminal Procedure, 1898 (Act V of 1898), and all prosecutions \r\nshall be disposed of and judgments pronounced as expeditiously as possible. \r\n(4) Hearings shall not be adjourned except for sufficient cause to be recorded, and for no more \r\nthan fourteen days at a time. The court may impose such costs as it deems fit. \r\n59. Administrative sanctions. —(1) Where the Authority is satisfied that a Person has \r\ncontravened any provision of this Act, or any Rules, Regulations, directions, circulars, or other regulatory \r\nrequirements made thereunder, it may, impose one or more of the following sanctions \r\n(a)  issue a written reprimand or public censure; \r\n(b)  issue a directive requiring the Person to cease or remedy the contravention; \r\n(c)  impose a financial penalty up to the maximum amount prescribed by the Rules; \r\n(d)  suspend or revoke any license issued under this Act; or \r\n(e)  disqualify any Person from  holding any office  or position of responsibility i n a \r\nLicensee. \r\n(2) Where the Authority is satisfied that an Issuer has contravened this Act or any Regulations \r\nmade thereunder, it may impose sanctions under sub -section (1), with such modifications as are \r\nappropriate, upon Issuers. \r\n(3) Without prejudice to sub-sections (1) and (2), where a Virtual Asset Service Provider or Issuer \r\ncontravenes any other law applicable in Pakistan, the Authority may, in accordance with Regulations, \r\nimpose administrative sanctions as it deems appropriate. \r\n(4) The Authority may impose a fine up to twenty -five million rupees for any contravention of \r\nthe provisions of this Act. \r\n \r\nPage 29 of 35 \r\n \r\n(5) The court may order restitution, disgorgement of profits or such other relief as it deems \r\nappropriate. \r\n60. Emergency intervention powers.—In the event of a systemic threat, market manipulation, \r\nfraud, or cybersecurity breach, or other serious risk to customers or market Integrity, the Authority may \r\nissue an order temporarily suspending specified Virtual A sset Services or freezing related assets for a \r\nperiod not exceeding thirty days. \r\n61. Power to prevent access to unlicensed virtual asset services. —(1) The Authority may \r\nremove, block, or direct the removal or blocking of any online material (e.  g., websites, apps, ads, \r\npayment links) if, on reasonable grounds, it promotes, operates, or relates to an unlicensed Virtual Asset \r\nService or contravenes this Act, its Rules, or Regulations. \r\n(2) Such directions may be issued to telecommunication authorities, Virtual  Asset Service \r\nProviders, intermediaries, hosting providers, app stores, search engines, advertising networks, registrars, \r\npayment providers, or any person facilitating such material. \r\n(3) All orders or directions shall be in writing, stating reasons and st atutory basis, and \r\ncommunicated to the affected person. \r\n(4) The Authority may require preservation of copies, logs, or transactional data for evidentiary \r\npurposes. \r\n(5) A person aggrieved by an order may submit a representation within ten days; the Authorit y \r\nshall respond in writing within fifteen days. \r\nChapter-11 \r\nAPPEALS \r\n62. Establishment of the virtual assets appellate tribunal. —(1) A Virtual Assets Appellate \r\nTribunal shall be established and no court shall take cognizance of a legal dispute under this Act  or the \r\nRules or Regulations made thereunder to which the jurisdiction of the Virtual Assets Appellate Tribunal \r\nextends. \r\n(2) The Virtual Assets Appellate Tribunal shall consist of a presiding officer, who shall be a \r\nperson who is a retired Judge of a High Court, or an advocate having not less than ten years' practice and \r\nexperience in the relevant field, and two members, one being a technical expert and the other being a \r\nfinancial expert, who shall be Persons of ability, Integrity, and have special knowledge and professional \r\nexperience of not less than ten years in the fields of law, technology, finance, or economics. \r\n(3) The presiding officer and members of the Virtual Assets Appellate Tribunal shall be appointed \r\nby the Federal Government, i n the manner Pre scribed, and hol d office for a period of three years and \r\nshall be eligible for re-appointment for a similar term or terms and shall cease to hold office on attaining \r\nthe age of sixty years or the expiry of the term, whichever is earlier. \r\n(4) The terms, con ditions, and appointment of the Virtual Assets Appellate Tribunal presiding \r\nofficer and other members shall be in the manner Prescribed by the Federal Government. \r\n \r\nPage 30 of 35 \r\n \r\n63. Jurisdiction.—Any Virtual Asset Service Provider, Licensee, or any other Person aggrieved \r\nby an order of the Authority may prefer an appeal before the Virtual Assets Appellate Tribunal within \r\nthirty days of the date on which the order was communicated, in accordance with the Prescribed Rules. \r\n64. Appeal.—(1) An appeal to the Virtual Assets App ellate Tribunal shall be filed within thirty \r\ndays from the date of such order in such form, contain such particulars, and be accompanied by such \r\ndocuments and fees as may be prescribed under this Act. \r\n(2) The Virtual Assets Appellate Tribunal shall decide an appeal expeditiously but not later than \r\nthree months of its presentation to the Tribunal. \r\n(3) The Virtual Assets Appellate Tribunal shall, for the purpose of deciding an appeal, be deemed \r\nto be a civil court and shall have the same powers as are vested in such court under the Code of Civil \r\nProcedure, 1908 (Act V of 1908), including the powers of— \r\n(a)  enforcing the attendance of any Person and examining him on oath; \r\n(b)  compelling the production of documents; and \r\n(c)  issuing commissions for the examination of witnesses and documents. \r\n(4) It shall be sufficient for the Virtual Assets Appellate Tribunal to establish, or to be satisfied \r\nas to any matter on the standard of proof applicable to civil proceedings in a summary manner in a court \r\nof law. \r\n(5) The Virtual Assets Appellate Tribunal's determinations or decisions under this Act shall be \r\ndeemed to be the decrees of a civil court under the Code of Civil Procedure, 1908 (Act V of 1908). \r\n65. Appeal to Supreme Court. —Any Person aggrieved by an order of the Virtual Assets \r\nAppellate Tribunal may file an appeal to the Supreme Court of Pakistan within thirty days from the date \r\nof such order and in such manner as may be prescribed. \r\nChapter-12 \r\nMISCELLANEOUS \r\n66. Tax Compliance. —Every Virtual Asset Service Pr ovider licensed under this Act shall \r\ncomply with the obligations imposed under the Income Tax Act, 2001 and any Rules or Regulations \r\nissued by the Federal Board of Revenue. \r\n67. Power to make Rules.—The Federal Government may by notification in the official Gazette, \r\nmake Rules, as deemed necessary for the implementation of and to carry out the purposes of this Act. \r\n68. Powers to make regulations. —The Authority may make Regulations in the consultation \r\nwith Division concerned as deemed necessary for the implem entation of and for carrying out the \r\npurposes of this Act. \r\n69. Officers to be Public Servants. —The Chairperson, Managing Director, members, staff, \r\nexperts; consultants, advisers, other officers and employees of the Authority shall be deemed to be public \r\nservants within the meaning of section 21 of the Pakistan Penal Code; 1860 (XLV of 1860). \r\n \r\nPage 31 of 35 \r\n \r\n70. Transitional provisions. —(1) Any Person providing Virtual Asset Services Immediately \r\nbefore the commencement of this Act shall, within six months of such commenceme nt, apply to the \r\nAuthority for a license under this Act or shall cease to provide such services. \r\n(2) After the commencement of this Act, within six months, a Person who has submitted a \r\ncomplete application as per sub-section (1) may continue to provide existing Virtual Asset Services: \r\nProvided that such Person fully complies with any interim directives issued by the Authority and \r\ncontinues to adhere to the core obligations of this Act, particularly regarding customer asset protection \r\nunder AML, CFT and CPF. \r\n71. Power of the Federal Government to issue policy directives. —The Federal Government \r\nmay, by notification in the official Gazette, give policy directives to the Authority to align its actions \r\nwith national policies, priorities and interests consistent w ith the objectives and framework established \r\nunder this Act. Such policy directives shall not impede the Authority's operational autonomy. \r\n72. Annual and special reports of the Authority. — (1) The Authority shall prepare an annual \r\nreport at the end of the financial year and may at any time prepare special reports on any matter which \r\nin its opinion is of particular urgency or importance. \r\n(2) The Division concerned shall cause the annual report and the special reports to be laid before \r\nthe Majlis-e-Shoora (Parliament) within ninety days. \r\n(3) The report shall be placed on the website of the Authority immediately after its lying before \r\nthe Majlis-e-Shoora (Parliament) for information of general public. \r\n73. Removal of difficulties. —If a procedural or operational difficulty arises in giving effect to \r\nany of the provisions of this Act, the Federal Government may, within six months of the commencement \r\nof this Act, make such order not inconsistent with the provisions of this Act, as may appear to it to be \r\nnecessary or expedient for removing such difficulty. \r\n74. Savings.—Notwithstanding the lapse of the Virtual Assets Ordinance, 2025 (VII of 2025), \r\nanything done, action taken, appointment made, notification or order Issued, or right, privilege, \r\nobligation or liability accrued under the said Ordinance shall be deemed to have been validly done, taken, \r\nmade, issued or accrued under the corresponding provisions of this Act. \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\nPage 32 of 35 \r\n \r\nSCHEDULE-I \r\n(See section 18) \r\nCATEGORIES OF VIRTUAL ASSET SERVICES \r\nThe list below shall constitute the types of Virtual Asset Services and their description. \r\nSr. No.  Service Category  Description \r\n(1) (2) (3) \r\n1.            Advisory Services means the provision of \r\npersonalized recommendations, on \r\nprofessional basis, to a customer, \r\neither upon request or at the \r\ninitiative of Virtual Asset Service \r\nProviders, relating to one or more \r\nactions or transactions involving \r\nVirtual Assets.  \r\n \r\nThe term “ personalized” refers to \r\nrecommendations that are \r\naddressed to a specific customer \r\nand take into account (or are \r\npresented as taking into account) \r\nthat customer’s individual \r\ncircumstances, objectives, risk \r\nprofile or financial situation. \r\nGeneral market info rmation, \r\nresearch reports or non - \r\nindividualised suggestions do not \r\nconstitute personalised \r\nrecommendations.  \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\n \r\nPage 33 of 35 \r\n \r\n2.               Broker-Dealer Services     means any of the following: \r\n \r\n(a) arranging or facilitating \r\norders for the purchase and \r\nsale of Virtual Assets \r\nbetween two parties; \r\n \r\n(b) soliciting or accepting \r\norders and receiving \r\nconsideration in flat \r\ncurrency or Virtual Assets; \r\n \r\n(c) trading Virual Assets on \r\nthe Virtual Asset Service \r\nProvider’s own account; \r\n \r\nExemption: A person that deals \r\nsolely on its own account, does not \r\nexecute orders on behalf of \r\ncustomers, and does not hold or \r\ncontrol Customer Assets is not \r\nregarded as carrying on ‘broker -\r\ndealer services’ for the purposes of \r\nthis act \r\n \r\n(d) market-making using \r\nCustomer Assets; or \r\n \r\n(e) providing placement or \r\ndistribution services for \r\nissuers acting as \r\nintermediaries.   \r\n3. Custody and Administration Services means the safekeeping or \r\nadministration, on behalf of \r\ncustomers and pursuant to their \r\ninstructions, of: \r\n \r\n(a) Virtual Assets; or \r\n \r\n(b) private cryptographic keys   or  \r\nother means of access that allow  \r\nthe customer to transfer or dispose  \r\nof Virtual Assets independently \r\nbut excludes the mere provision of \r\nsoftware, hardware or \r\ninfrastructure that enables  a \r\ncustomer to reta in exclusive \r\ncontrol over their own private \r\nkeys. \r\n \r\n \r\nPage 34 of 35 \r\n \r\n4.                 Exchange Services means any of the following: \r\n \r\n(a) exchanging Virtual Assets \r\nfor fiat currency; \r\n \r\n(b) exchanging one or more \r\ntypes of Virtual Assets; \r\n \r\n(c) matching orders between \r\nbuyers and sellers and \r\nexecuting conversions as \r\ndescribed in (a) and (b); or \r\n \r\n(d) maintaining an order book \r\nfor the above purposes. \r\n \r\n5. Lending and Borrowing Services means the facilitation, \r\narrangement, intermediation or \r\ndirect provision (as principal) of \r\nlending or borrowing arrangements \r\ninvolving Virtual Assets, where \r\none or more lenders transfer, lend \r\nor make available Virtual Assets \r\n(or rights thereto) to one or more \r\nborrowers, subject to a contractual \r\nobligation for the borrower to \r\nreturn equivalent Vi rtual Assets \r\n(together with any agreed interest, \r\nfees or rewards) at a specified time \r\nor upon demand. \r\n \r\n \r\n6. Virtual Assets Derivatives Services means the offering, facilitation, \r\nexecution, clearing, trading or \r\narranging of transactions in \r\nderivatives (incl uding futures, \r\noptions, swaps, contracts for \r\ndifference or other similar  \r\nInstruments) that have a Virtual \r\nAsset (or a basket or index of \r\nVirtual Assets) as their underlying \r\nreference asset. \r\n \r\n7. Virtual Asset Management and  \r\n                 Investment  \r\n                 Services \r\nmeans acting in a fiduciary or \r\nagency capacity for the purpose of \r\nmanaging or administering another \r\nPerson’s Virtual Assets, including: \r\n \r\n \r\nPage 35 of 35 \r\n \r\n(a) portfolio or discretionary \r\ninvestment management involving \r\nVirtual Assets; and \r\n \r\n(b) respo nsibility for staking on \r\nbehalf of customers to earn \r\nvalidator or network rewards, \r\nprovided that such staking is \r\nperformed on a discretionary basis \r\nor forms part of a broader \r\ninvestment management mandate. \r\n \r\n8. Virtual Asset Transfer and Settlement  \r\n           Services \r\nincludes transfer, transmission, or \r\nsettlement of Virtual Assets \r\nbetween parties, or from one \r\nwallet, address, or location to \r\nanother, on behalf of customers \r\nexcluding exchange execution. \r\n \r\n9.            Virtual Assets Issuance Services Creation, issuance, initial offering, \r\nadministration, and ongoing \r\nmanagement of Virtual Assets, \r\nincluding supply control, reserve \r\nmanagement (if any), redemption, \r\ngovernance, and required \r\ndisclosures. \r\n \r\n10. Mining-related Virtual Assets Services Includes a ctivities where mining \r\noperations provide services to third \r\nparties involving customer virtual \r\nassets or funds. Pure mining for \r\nown account is excluded. \r\nLicensing and regulatory \r\nobligations apply only  if the \r\nservice involves customer assets or \r\nfunds, as pe r the Authority’s \r\nRegulations.  \r\n \r\n \r\n_______________________ \r\n \r\n \r\n \r\nRGN Date: 06-03-2026",
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