Ghasfar Ali Mirza
AssociateVirtual Assets and FintechSalahuddin, Saif & Aslam (Attorneys at Law), Lahore
PVARA, SECP and SBP.
Across Europe, Asia and the Gulf, including China, the United Kingdom, Russia and the United Arab Emirates.
- AssociateSalahuddin, Saif & Aslam (Attorneys at Law), Lahore
- LLB (Hons)Liverpool John Moores University, 2024
- Certificate in AI and its Application in FintechLahore University of Management Sciences (LUMS), 2026
Profile
Grounded in the Primary Sources
Ghasfar is an Associate at Salahuddin, Saif & Aslam, where he advises international businesses on entry into Pakistan's regulated financial sector. His practice is anchored in virtual assets and blockchain under the Pakistan Virtual Assets Regulatory Authority (PVARA), and extends across the licensing regimes of the Securities and Exchange Commission of Pakistan (SECP) and the State Bank of Pakistan (SBP). His clients operate across Europe, Asia and the Gulf, including China, the United Kingdom, Russia and the United Arab Emirates.
He acts as advising counsel and researcher, and carries each mandate through to its conclusion. His approach is grounded in the primary sources: the statutes, regulations and circulars that govern a product, read in full rather than through commentary. On that foundation he examines how a group is structured and operates abroad, establishes where its products fall within Pakistan's regulatory perimeter, and adapts the business to meet local requirements. Every submission is prepared so that what reaches the regulator is complete, accurate and properly presented, and he leads the engagement with the regulator through to approval. His involvement does not end at the licence: he supports clients through application whitelisting, launch and ongoing compliance, so that the business remains regularised as it grows.
Practice
What Ghasfar Advises On
Virtual Assets and Blockchain
Ghasfar advises virtual asset service providers, including exchanges and wallet providers, on the licensing route under the Virtual Assets Act 2026 and on structuring their operations to satisfy it. He advises on tokenization, including the structuring of real-world asset tokenization projects, an area of growing significance for Pakistan's real estate sector, and on whether a given token constitutes a security. In that assessment he applies the framework established by the US Supreme Court in SEC v. W.J. Howey Co., examining a token by its features and economic substance rather than by its label. His work in this area reflects a central feature of the Pakistani regime: a virtual asset licence seldom stands alone. Products such as cross-border remittance and card-based merchant settlement also depend on payment processing arrangements and on the foreign exchange framework, and he advises on these regimes together so that the product operates lawfully from end to end.
Fintech Licensing
Under the SECP's non-banking finance regime, he has taken clients from initial structure to licence for digital lending products under Investment Finance Services, including buy now, pay later, small-ticket consumer lending, SME lending and credit lines. The mandate covers policies, business plans, fit and proper requirements and regulatory correspondence. Under the SBP framework, he has worked on electronic money institution licensing and advises licensed EMIs.
Market Entry and Corporate
For foreign groups establishing in Pakistan, the regulatory path is determined by the product and by what the business intends to bring to the market. A group building a complete ecosystem will ordinarily require several licences, and many begin with a mid-tier licence and expand as the business scales. He advises on that sequencing, structures the local presence, and supports the integrations and partnerships that follow with financial institutions, merchants and regulators. He also advises startups, from early stage to established, on structuring, funding rounds and acquisitions, supported by contract drafting and due diligence.
Beyond Fintech
As his clients' businesses are predominantly technology-led, his practice extends to cyber crime, where he represents and defends founders and platforms, including in matters concerning source code and crypto-related fraud. He also handles intellectual property, from the registration and publication of trademarks and patents to objections and hearings before the Intellectual Property Organisation of Pakistan; real estate sales and rentals; and mergers and acquisitions, including acquisitions by startups.
Framework
Governing Frameworks
- Virtual Assets Act 2026PVARA
- Pakistan Virtual Asset Services Regulations 2026PVARA
- Non-Banking Finance Companies (Establishment and Regulation) Rules 2003SECP
- Non-Banking Finance Companies and Notified Entities Regulations 2008SECP
- SECP Circular 12 of 2024SECP
- Payment Systems and Electronic Fund Transfers Act 2007SBP
- Regulations for Electronic Money Institutions (revised 2023)SBP
- Foreign Exchange Regulation Act 1947SBP
Experience
Representative Experience
- Advised on a card programme under which merchants are settled in fiat, in real time, from users' virtual asset balances, delivered through a card issuer partnering with an exchange or wallet provider.
- Advised a remittance service provider on a cross-border model converting fiat to virtual assets and back, operated in partnership with financial institutions.
- Advised foreign virtual asset exchanges on the licensing route and structure for entry into Pakistan.
- Opined on whether an AI-based token, designed to make crypto mining more efficient, constitutes a security.
- Structured two products under a single NBFC licence for one client: buy now, pay later for consumers and SME lending for the merchants supplying those goods, serving both sides of the transaction. Both products are licensed and live.
- Secured NBFC licences for foreign digital lenders across buy now, pay later, small-ticket and SME lending products, with support continuing through whitelisting, launch and compliance.
- Took electronic money institution applicants through licensing, and advised licensed EMIs on their continuing obligations.
- Led foreign entities through market entry, from structuring and licensing to partnerships and integration within the Pakistani framework.
- Advised startups from early stage to established on structure, funding rounds and acquisitions.
Contact
Speak With Ghasfar
For virtual assets, fintech licensing and market entry in Pakistan.
- DegreeLLB (Hons), Liverpool John Moores University, 2024
- CertificateCertificate in AI and its Application in Fintech, Lahore University of Management Sciences (LUMS), 2026
- RegulatorsPVARA, SECP, SBP
Client identities are withheld. Nothing on this page is legal advice.