What is Sarzif Policy?
Sarzif Policy is a regulatory research desk based in Islamabad, Pakistan. We do two things. We publish plain-English analysis of Pakistan’s virtual asset rules, and we connect firms applying for a licence with consultants who have completed that filing before.
We are independent. We are not affiliated with PVARA, the SECP, the State Bank of Pakistan or any other regulator, and no regulator reviews or approves what we publish.
Why does this exist?
Pakistan built a virtual asset regulator faster than it built the market’s understanding of it. PVARA arrived, consultations opened, and firms that had been operating for years suddenly needed to know which licence class they fell into and what a fit-and-proper submission looks like.
The information existed, but it was scattered across notifications, draft rules and consultation papers written for lawyers. Most operators could not read it, and the ones who could still had no way to find an adviser with a real track record. So they hired whoever answered the phone, paid for someone else’s learning curve, and filed applications that came back incomplete.
Sarzif Policy was founded to close both gaps at once. If a firm can understand the rule, and can reach an adviser who has already worked with that rule, most of the cost and delay in licensing disappears.
We had also watched this problem get solved elsewhere. Dubai went through the same transition a few years earlier, and the firms that came through it intact were rarely the biggest ones. They were the ones who understood the requirement early and hired someone who had already done the filing. Pakistan is at that same point now.
Who runs it?
Noor Aslam is Chief Executive Officer. She leads the research desk, sets editorial standards, and personally reviews the consultant shortlists that go out to applicants. She is the named author on the analysis published here.
She has eight years in the virtual asset industry:
- Four years in crypto regulation advisory, working on VARA licensing in Dubai. This is where the approach behind Sarzif Policy comes from — she saw at close range which applications a regulator approves and which ones come back.
- Two years in crypto business development, on the commercial side of the industry rather than the compliance side. It is a useful counterweight: she has had to build a business under the rules, not only interpret them.
- Two years building her own startup from the ground up. She knows what a licensing bill does to a young company’s runway, which is why nothing is charged until a client actually appoints someone.
She has never been employed by a regulator. Her VARA experience is as a consultant advising licence applicants, not as a member of the authority.
Who is on the team?
Noor leads a team of six.
| Function | People | What they do |
|---|---|---|
| Legal | 1 qualified lawyer | Reads primary sources, checks how a rule applies, and reviews anything on this site that states a legal position |
| Regulatory research | 3 researchers | Track PVARA, the SECP, the State Bank, the FBR, FATF guidance and court rulings. Fifteen years of combined experience |
| Operations | 2 staff | Run the consultant panel, verify completed filings, and manage matching requests end to end |
The three researchers hold fifteen years of combined regulatory experience. We state that as a combined figure because that is what it is.
How do we make money?
We charge the firm we are helping, not the consultant. When a client appoints a consultant we introduced, the client pays us 20% of that consultant’s fee.
This is worth stating plainly because it shapes everything else:
- Consultants pay us nothing. Not to join the panel, not to be listed, not to rank higher. They are not our customer, so there is no arrangement they could offer us.
- Our fee is the same 20% whichever consultant a client picks. We earn identically from the cheapest adviser on the panel and the most expensive, so we have no reason to steer anyone.
- The shortlist itself is free, and the fee applies only on appointment. If nobody on the list suits you, you owe us nothing.
- Reading this site costs nothing. The analysis, the checklists and the tracker are free and always will be.
- We publish this on the VASP Licensing page too, because a reader should not have to hunt for it.
What do we publish?
Daily analysis of what Pakistan’s regulators actually said, written for operators rather than lawyers. Each article states what changed, who it affects, what the deadline is, and what a firm should do about it.
We work from primary sources only:
| Source | What we use it for |
|---|---|
| PVARA official | Licensing framework, notifications, consultations |
| SECP | Company and securities rules touching virtual assets |
| State Bank of Pakistan | Banking, payments and foreign exchange treatment |
| FBR | Tax treatment of virtual asset gains and business income |
| FATF | International AML and CFT standards, Recommendation 15 |
| Pakistani courts | Rulings that set precedent |
We do not report from social media, unnamed sources, or other people’s coverage. If we cannot point to a document, we do not publish the claim. Our full standards are on the editorial policy page.
What we do not claim
We think it is worth being direct about the limits.
- We are not a law firm and nothing here is legal advice.
- We do not file applications. We introduce you to people who do.
- We cannot promise an approval. A regulator decides that, and any adviser who tells you otherwise is selling something.
- We hold no certification or regulatory authorisation at this stage, and we do not imply one.
How to reach us
Email is the only channel: sarzifpolicy@gmail.com. We answer within two business days.
We take regulatory tips, corrections to anything we have published, and licensing enquiries. Corrections get priority — see the editorial policy for how we handle them.
If you are looking for a consultant, the VASP Licensing page is faster than email.