Fintech & Financial Services
SSA advises payment businesses in Pakistan from regulatory-route analysis through SBP authorisation and launch.
For EMIs and payment-system businesses, we translate the proposed product into the material SBP expects to see: the e-money or payment-service model, customer and merchant journeys, fund flows, clearing and settlement, governance, technology, safeguarding and the contracts supporting the operating structure. We prepare the application package and support the applicant through In-Principle Approval, Pilot Operations and Commercial Operations.
How SSA Supports the Mandate
Our role is to turn the proposed business or transaction into the applications, documents, structures and operating arrangements required to move it forward.
The precise workstream is tailored to the product, licence category, ownership structure and stage of the business. Where a mandate also requires cross-border, technology, transactional or continuing compliance support, those elements are integrated into the engagement.
We prepare and review the EMI application and regulator-facing business plan, including the strategic and operational plan, market and five-year projections, proposed e-money and payment services, payment-flow diagrams, clearing and settlement mechanics, delivery channels, partnerships and supporting contractual arrangements.
SSA supports the applicant through SBP's staged authorisation process. We coordinate the legal and regulatory work required for In-Principle Approval, prepare for Pilot Operations and address the documentation, product and operating issues that must be resolved before Commercial Operations approval and go-live.
We structure wallet and e-money functionality around issuance, redemption, permitted transactions, customer onboarding, transaction limits and the movement of customer funds. We advise on safeguarding and trust arrangements, settlement accounts and the legal relationships among the EMI, users, merchants, banks and other payment participants.
Where the model involves switching, processing, gateways, payment schemes, clearing or other PSO/PSP functions, we assess the correct regulatory perimeter and authorisation route. We also advise on integrations and contractual arrangements involving Raast, 1LINK, banks, acquiring institutions and other regulated participants.
We map the proposed customer journey and movement of funds for P2P, P2M, QR, online checkout, payment links, merchant acquiring and other payment products. This allows the legal documentation, revenue model, settlement responsibilities and regulatory permissions to be tested against the way the product will actually operate.
We advise on technology and cloud arrangements, processors, APIs, cybersecurity, data, outsourcing and third-party service providers as part of the regulated model. After launch, we support product changes, new partnerships, regulatory reporting and SBP engagement where approval, notification or restructuring may be required.
Our Approach
We identify the regulatory perimeter, approvals and sequencing before the application or transaction is built.
We prepare and coordinate the applications, business and corporate materials, policies, contracts and supporting submissions required for the mandate.
We support regulatory observations, implementation, launch and subsequent changes so the legal structure remains aligned with the operating business.
Your Team
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