Firm advises Silicon Valley blockchain entity on PVARA NOC and reverse solicitation analysis
Lex Legal Practice is advising a Silicon Valley-headquartered blockchain technology company, which operates a global cryptocurrency exchange and a decentralised finance wallet, on obtaining a No Objection Certificate (NOC) from the Pakistan Virtual Asset Regulatory Authority (PVARA) for the provision of Virtual Asset Services in Pakistan.
Beyond the NOC application itself, the engagement encompasses a comprehensive analysis of the applicable Virtual Asset Service Provider regime in Pakistan, including an assessment of whether crypto trading services may be operated under a reverse solicitation framework pursuant to the newly enacted virtual assets legislation.
The reverse solicitation question, whether services provided at the unsolicited initiative of Pakistani clients fall within the licensing perimeter is among the most consequential structuring issues facing offshore platforms evaluating the Pakistani market, and the firm's analysis addresses both the statutory text and the supervisory expectations emerging from PVARA.
“Reverse solicitation is where the perimeter of every new virtual assets regime is tested. Our advice gives offshore operators a clear-eyed view of where the Pakistani perimeter sits, and what it takes to operate inside it.”
— Asad Salahuddin, Managing Partner, Lex Legal Practice