CRYPTOCURRENCY AND TERROR FINANCING: PAKISTAN’S REGULATORY CHALLENGES IN THE GLOBALISED DIGITAL ECONOMY

SEPTEMBER 2025

ABSTRACT

This research paper examines how Pakistan can reduce the risks of terrorist financing (TF) linked to virtual assets (VAs) by enhancing data-intensive workflow for pre-existing authorities. Using a qualitative content analysis approach, the study takes statutes, regulator circulars, and institutional analyses and reports as primary sources, triangulated with reputable secondary reporting. The findings highlight three recurring gaps: the absence of a settled licensing and inspection regime for virtual-asset service providers, missing Travel-Rule messaging, and weak evidentiary continuity between alert and arrest. These stratifications are magnified by high grassroots adoption of the VAs and a significant cash usage dependency. Priority recommendations include the designation of a virtual-asset service provider (VASP) supervisor, the creation of a national “Travel-Rule” utility, the creation of rapid-freeze and evidence-continuity protocols, and publishing sector-specific red flags using standardised suspicious transaction report (STR) crypto fields. Taken together, these measures can provide admissible, timely evidence while protecting lawful innovation and strengthening cross-border investigative cooperation capacity.

Keywords: Pakistan Cryptocurrency Council; virtual assets; terrorist financing; VASP licensing; Travel Rule; Raast/NADRA
This paper is currently under review for publication in a domestic/international journal. It will be available once published.

Amjad Fraz

Research Assistant

CASS LAhore

The Centre for Aerospace & Security Studies (CASS) was established in July 2021 to inform policymakers and the public about issues related to aerospace and security from an independent, non-partisan and future-centric analytical lens.

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