Page 8 - CMA Journal (Jan-Feb 2026)
P. 8

Exclusive Interview


              Third, the integration of AI with financial infrastructure
              means regulatory frameworks must evolve quickly. If we
              move early and thoughtfully, Pakistan can position itself   Millions of Pakistanis were
              as a jurisdiction where digital finance innovation
              happens first, not last.                          already using global platforms in
              What excites me most is the mindset shift I saw at Davos.   a grey market environment with
              The world is building the next financial architecture now.
              Pakistan has the talent, the adoption rates, and the   zero local oversight, no formal
              demographic advantage to be a nation of builders in this
              new system, not just consumers of it.                     reporting lines, and no
              ICMA:  Issuing NOCs to global exchanges was a         structured accountability. By
              landmark regulatory decision. In concrete terms,
              what will be the first noticeable improvement for an   issuing NOCs under PVARA, we
              average citizen or small business?
                                                                  have brought these exchanges
              Bilal Bin Saqib: Issuing NOCs to global exchanges was
              not about endorsing crypto overnight. It was about   into a supervised framework
              bringing an existing reality into a regulated perimeter.
              Millions of Pakistanis were already using global
              platforms in a grey market environment with zero local
              oversight, no formal reporting lines, and no structured   My guiding principle is proportionality. Innovation
              accountability. By issuing NOCs under PVARA, we have   should not be stopped, but it must be supervised in
              brought these exchanges into a supervised framework.
                                                               proportion to the risk it generates. A retail trading
              They are now registered on the goAML portal, subject to   platform does not carry the same systemic implications
              AML and CFT reporting, and operating under defined   as a stablecoin integrated into payment rails or a lending
              engagement with the regulator rather than outside it.
                                                               protocol offering leverage. The regulatory response must
              For the average citizen or small business, the first   be aligned with the risk profile.
              noticeable improvement is clarity and confidence.   Another principle is sequencing. We do not attempt to
              Instead of wondering whether the platform they are   regulate everything at once. Markets are brought into
              using could suddenly be restricted or disconnected from   visibility first, then prudential standards are introduced,
              the local financial system, there is now growing
                                                               and finally consumer protections are strengthened. This
              regulatory visibility. That reduces ambiguity and signals   layered approach reduces shock to the system while
              that Pakistan is moving toward structured participation   steadily raising standards.
              rather than informal tolerance.
                                                               And finally, credibility over popularity. There is always
              The NOC is only Phase One and it’s not a blanket
                                                               pressure to move faster, especially in emerging
              approval for exchanges. It allows an exchange to register   technology sectors. Short-term applause is never worth
              their local company while maintaining compliance with   long-term damage. A regulatory failure in this space
              our AML frameworks.  Full licensing will introduce   would not just hurt investors. It would undermine trust in
              stronger safeguards such as custody standards,
                                                               digital finance more broadly.
              segregation of client assets, capital adequacy
              requirements, governance rules, and formal dispute   ICMA: Pakistan ranks among the world's top crypto
              resolution mechanisms. That is when citizens will begin   adopting nations. As the regulatory architect, what is
              to see tangible structural protections similar to other   your strategy to transform this organic adoption into
              regulated financial services.                    structured, recognized global leadership?
              ICMA:  Your role requires balancing breakthrough   Bilal Bin Saqib: Pakistan’s high crypto adoption is an
              innovation with public safety.  Where do you     advantage, but adoption alone is not leadership. My
              personally feel the greatest tension lies, and what   strategy is to transform scale into structure and structure
              principle guides you when these priorities conflict?  into creditability, via following:

              Bilal Bin Saqib: Pakistan has one of the highest organic   First, we are moving from informal usage to rule-based
              adoption rates in the world.  That creates enormous   participation. Through phased NOCs, full licensing, and
              opportunity, but it also means mistakes scale very   activity-specific regulations, we are bringing VASPs into a
              quickly. If policy is too restrictive, activity is pushed   transparent supervisory framework aligned with AML,
              underground. If it is too permissive, systemic risk enters   governance, prudential, and consumer protection
              an already delicate financial environment. The hardest   standards. The objective is simple- the same innovation,
              part of this role is deciding where to draw that line.  but within legal certainty.

               6    ICMA’s Chartered Management Accountant, Jan-Feb 2026
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