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11 March 2026
Author: Mr Asif S Kasbati (FCA, FCMA & LLB).
Today Important Videos & Quotation
A. Comprehensive Solutions & shared Insights on Laws, Budgets & QC Services - Mr Sunaib Barkat, Ex Company Secretary of a Listed Company & Ex Partner Mazars & Co. Click on the Link to watch video
B. Get Timely Updates & Commentaries for Better Planning, Saving & Proper Compliance Click on the Link. For High Level Professionals & Subscribers views, please click here.
Below is the QC Sample released earlier. For having the same on a timely basis and with all links, please subscribe today by calling Abid 0335 2204 786 or UAN 0331 1118 786
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A. Background
(1) This refers to the related Important BFICs in trail, blue, italic and double Line (a) 319 of 12.8.25 about Virtual Assets law criticized (b) 315 of 1.8.25 about Virtual Assets Ordinance 2025 and Crypto, Betting & Shariah History (c) 308 of 25.3.25 about Cryptocurrency is not as per Shariah - Top Level World renowned Expert (2) More relevant QCs List is given Para C for ready reference
B. Updated Commentary
Further to KQU 3812 of 4.3.26, being an important matter, The Virtual Assets Bill, 2026 as passed by the National Assembly (yet to be assented by the President) (Attachment 365.1) consisting of 36 pages. If your Goodself has a short
S No. |
| Page No. |
CHAPTER 1 - PRELIMINARY | ||
1 | Short title, extent, commencement. | 1 |
2 | Scope of application | 1 |
3 | Definitions | 2 |
4 | Extraterritorial application | 7 |
5 | Relationship with other law | 7 |
CHAPTER 2 - PAKISTAN VIRTUAL ASSETS REGULATORY AUTHORITY | ||
1 | Establishment of the Authority | 7 |
2 | Composition of Authority | 8 |
3 | Procedures of the Authority | 8 |
4 | objectives, functions and powers of the Authority | 8 |
5 | Delegation of powers | 10 |
6 | Appointment and Functions of Chairperson | 10 |
7 | Appointment and Functions of Managing Director | 11 |
8 | Appointment of Officers, Staff, Consultants, Advisors and other | 11 |
9 | Pakistan Virtual Asset Regulatory Authority Fund | 12 |
10 | Code of conduct | 14 |
11 | Inter-agency cooperation and information-sharing | 14 |
CHAPTER 3 - LICENSING OF VIRTUAL ASSET SERVICE PROVIDERS AND ISSUANCE OF VIRTUAL ASSETS | ||
1 | Categories of virtual asset services | 15 |
2 | Application for License | 15 |
3 | Fit-and-proper criteria | 15 |
4 | Grant, refusal and terms of license | 16 |
5 | Ongoing obligations of licensees | 22 |
6 | Variation, suspension and revocation of license | 23 |
CHAPTER 4 - PRUDENTIAL REQUIREMENTS, SAFEGUARDING AND CUSTODY | ||
1 | Segregation of customer assets | 17 |
2 | Minimum financial resource requirements | 18 |
3 | Custody standards and key-management controls | 18 |
4 | Proof-of-reserves and audit obligations. | 18 |
5 | Reserve custodians | 18 |
6 | Customer safeguard or compensation mechanism | 18 |
CHAPTER 5 - FIAT-REFERENCED AND ASSET.REFERENCED TOKENS | ||
1 | Initial virtual Asset offering | 19 |
2 | Issuance Requirements for Fiat-Referenced Tokens | 19 |
3 | Issuance Requirements for Asset-Referenced Token | 19 |
4 | Significant issuers | 20 |
CHAPTER 6 - CYBERSECURITY, SANDBOX AND INNOVATION | ||
1 | Cybersecurity and operational resilience | 20 |
2 | Regulatory sandbox | 20 |
3 | Oversight of blockchain technology adoption | 21 |
4 | Regulation of Virtual Asset Mining Activities | 21 |
5 | Establishment of Strategic Digital Wallet Company | 21 |
6 | Data localization framework | 21 |
7 | Data segregation and protection of sensitive information | 21 |
CHAPTER - MARKET CONDUCT, CONSUMER PROTECTION | ||
1 | Duty of integrity and fair dealing | 22 |
2 | Obligations of issuers of Virtual Assels | 22 |
3 | Marketing and conduct restrictions | 23 |
4 | Conflict-of-interest management | 23 |
5 | Complaint-handling and dispute resolution | 23 |
CHAPTER 8 - ANTI.MONEY LAUNDERING, COUNTERING OF TERRORISM FINANCING AND | ||
1 | Application of Anti-Money Laundering Act, 2010 | 23 |
2 | Travel rule and record-keeping obrigations | 24 |
3 | Real-time data access and reporting | 24 |
4 | Data Privacy obligations for Licensed entities | 24 |
CHAPTER 9 - PROHIBITIONS | ||
1 | Prohibition of unlicensed Virtual Asset services | 24 |
2 | Prohibition on Initial Virtual Asset Offerings | 25 |
3 | Prohibition of market manipulation and insider trading | 25 |
4 | Prohibition on Algorithmic tokens | 25 |
CHAPTER 10 - ENFORCEMENT, OFFENCES AND PENALTIES | ||
1 | Criminal offence | 26 |
2 | Liability of officers of bodies corporate | 26 |
3 | Power t-o Investigate | 26 |
4 | Powers of Authorized Office | 26 |
5 | Prosecution of offences | 26 |
6 | Administrative sanction | 27 |
7 | Emergency intervention powers | 28 |
8 | Power to prevent access to unlicensed virtual asset services | 28 |
CHAPTER 11 - APPEALS | ||
1 | Establishment of the virtual assets appellate tribunal | 28 |
2 | Jurisdiction | 29 |
3 | Appeal | 29 |
4 | Appeal to Supreme Court | 29 |
CHAPTER 12 - MISCELLANEOUS | ||
1 | Tax Compliance | 29 |
2 | Power to make Rules | 30 |
3 | Powers to make regulations. | 30 |
4 | Officers to be public Servants | 30 |
5 | Transitional provisions | 30 |
6 | Power of the Federal Government to issue policy directive | 30 |
7 | Annual and special reports of the Authority | 30 |
8 | Removal of difficulties | 30 |
9 | Savings | 31 |
SCHEDULE I (See section 18) CATEGORIES OF VIRTUAL ASSET SERVICES | 32 to 35 | |
STATEMENT OF OBJECTS AND REASONS | 36 | |
C. List of relevant QCs
(a) BFIC 316 of 5.8.25 about GENIUS Act versus Virtual Assets
(b)TLQC 3086 of 18.4.25 about 9 Million Crypto users but no Tax Policy - FTO Recommended action
(c) BFIC 309 of 26.3.25 about Crypto Council constituted
(d) COQC 620 of 27.11.23 about Surrogate ads of Cryptocurrency & Betting and Shariah
(e) BFIC 98 of 30.6.21 about Crypto Currency Islamic Shariah & Legal Aspects
D. Multiplication
Although all the Commentaries are to the extent of the Subscribed IDs only, however, your Goodself is allowed to share this QC to Impart Knowledge to the maximum Employees, Relatives, Groups, etc to avoid from Crypto until the same is not as per Shariah in Pakisan as Learned Muftian e Kiram.
E. Further Details & Services
Should you require any clarification or explanations in respect of the above or otherwise, please feel free to email Mr Amsal at amsal@kasbati.co with CC to info.kasbati@professional-
Best regards for Here & Hereafter
Asif S Kasbati (FCA, FCMA & LLB)
Managing Partner
Kasbati & Co (900+ Tax, Levies, Companies, Banking, Finance, Economy, Inflation, etc
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