Pakistan – CM P

2025, Cross-border, Update

New BRP Country Manual Products

Pakistan

BRP SA - Pakistan CM P
BRP SA – Pakistan CM P

BRP has updated

its Country Manual Products

for Pakistan

SOURCE OF CHANGESANSWERS
Law/Regulation  No
New Position of the Authorities  No
Evolution of Expert’s interpretation  Yes

Definitions & Concepts, Regulatory Overview and Behaviour Template

The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date.

Material changes

In alignment with the Country Manual Private Banking (CM PB), the active provision of macroeconomic information/reports and investment research and financial analysis documents/reports is now only permitted on an occasional basis and if covered by an ongoing advisory agreement onshore in Pakistan (at target) and on a cross-border basis into Pakistan (remote) (with the exception that macroeconomic information/reports may also be provided on a cross-border basis if no advisory agreement is in place).

With respect to execution-only services, it is emphasised, in line with the CM PB, that any provision of execution-only services by foreign (unlicensed) service providers onshore in Pakistan (at target) triggers local licensing requirements. It is therefore only permitted to accept unsolicited client orders on a cross-border (remote) basis, provided that no local securities are involved. Accordingly, the CM P BT provides the answers “Grey zone/NO” (at target) and “Grey zone/YES – Unofficial tolerated practice”. (remote).

With regard to execution only services, in line with the CM PB, it is highlighted that any provision of execution only services by foreign (unlicensed) service providers onshore in Pakistan (at target) triggers local licensing requirements. It is therefore only permitted to accept unsolicited client orders on a cross-border basis (remote) provided that no local Securities are involved. Accordingly, the CM P BT provides the answers “Grey zone/NO” (at target) and “Grey zone/YES – Unofficial tolerated practice.” (remote).

In further alignment with the CM PB, the provision of investment services, as well as any product-related marketing activities, is considered a “Grey zone” and only “permitted” on an occasional basis onshore in Pakistan (at target). In addition, the active provision of investment services and any product-related marketing activities outside the scope of a written advisory agreement (spot advice) is not recommended onshore in Pakistan (at target) and on a cross-border basis into Pakistan (remote). Accordingly, the CM P BT answers the relevant onshore/cross-border scenarios with “Grey zone/NO”.

Please note that the provision of investment services as well as any product-related marketing activities in relation to locally registered securities constitutes a regulated activity in Pakistan and are subject to licensing requirements. Therefore, locally registered securities cannot be marketed/offered/distributed to local investors without a licence, whether in Pakistan (onshore), cross-border (remote) or in the service provider’s country of establishment (offshore). The CM P BT therefore provides the answer “NO” in the relevant scenarios.

Non-material changes

Some comments and content have been slightly reworded in the CM, without introducing substantive changes to reflect the regulatory situation/current interpretation of the regulatory framework more accurately.

For more information, please contact us: info@brpsa.com

Geneva, January 23rd, 2025