Confidential

The Web3 rail
before the announcement.

A 50-50 vehicle. Pakistan's first PVARA-licensed Web3 layer, operated by Fasset. The first telco-bank to ship owns the category for a decade.

Zong
×
Zindigi
×
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01 · The window

The window opened in March. It closes when someone ships.

Three regulatory facts now in force. Each one is a door that opened. None of them stay open forever.

March 2026

Virtual Assets Act 2026

Federal legal framework for virtual assets. Criminal penalty for unlicensed operation. PVARA holds permanent statutory authority.

April 14, 2026

SBP Circular 10

Banks may open PKR accounts for PVARA-licensed VASPs. The seven-year banking ban on crypto is lifted, conditional on PVARA license.

Now

PVARA NOC queue is live

License applications in process. Binance and HTX received NOCs. The first telco-bank to apply through a proven operator wins the queue.

Easypaisa got the DRB.
JazzCash didn't.
The category that remains is the one no one has shipped.
02 · The anchors

What sits behind the Vehicle.

Distribution, scale, and the regulatory clock. The numbers that determine what gets built and when.

50M+
Zong subscribers across Pakistan
5M+
Zindigi digital banking users
10.7T
JazzCash 12-month transaction volume to Mar 2025
26%
Zong's mobile market share, #2 in Pakistan
03 · The competitive map

Every other player has stopped at the edge of Web3.

The DRB slots are awarded. The wallet wars are mature. The single regulated category nobody occupies is virtual assets.

Easypaisa
Telenor 55% × Ant Group 45%
Digital Retail BankYes · Jan 2025
Banking licenseYes
Web3 / VA licenseNo
JazzCash
VEON × Mobilink Microfinance Bank
Digital Retail BankNo
Banking licenseMicrofinance
Web3 / VA licensePending
Raqami Islamic Digital Bank
Kuwait Investment Authority × Enertech
Digital Retail BankYes · Feb 2026
Banking licenseYes
Web3 / VA licenseNo
HugoBank
Atlas Consulting
Digital Retail BankDRB pilot
Banking licenseYes
Web3 / VA licenseNo
Mashreq / KT Bank
Foreign banks · niche segments
Digital Retail BankDRB pilot
Banking licenseYes
Web3 / VA licenseNo
The Vehicle
50/50 confidential · powered by Fasset
Distribution55M reach
Banking licenseJS Bank
Web3 / VA licenseFirst mover
The category gets named once Easypaisa took Ant Group GCash took Ant Group The Vehicle decides next Pakistan's PVARA window opened in March Fifty million subscribers, five million users, one rail The first telco-bank to ship owns the decade Break-even at one hundred thousand active users The window closes when someone ships The category gets named once Easypaisa took Ant Group GCash took Ant Group The Vehicle decides next Pakistan's PVARA window opened in March Fifty million subscribers, five million users, one rail The first telco-bank to ship owns the decade Break-even at one hundred thousand active users The window closes when someone ships
04 · The Vehicle

Two of Pakistan's strongest brands, equally aligned.

A 50-50 equity vehicle. Zong contributes the distribution. Zindigi contributes the banking license. Combined addressable reach of 55M+ Pakistani consumers across telco and banking channels.

Shareholder A · 50%
Zong (CMPak)
Telco distribution rail
50M+ subs 26% market share 100+ cities 4G
  • China Mobile parent (1B+ subs globally)
  • My Zong App distribution
  • G2P disbursement rails live
  • SIM-binding identity layer
50/50
The Vehicle
Fasset Powered by Fasset
Shareholder B · 50%
Zindigi (JS Bank)
Digital banking rail
5M+ users JS Bank · $2.3B AUM PK's 1st fintech card
  • JS Bank commercial banking license
  • Raast QR rails live
  • USD freelancer account
  • PPP relationships (CDA, SBP, Punjab Suthra)
05 · Architecture

A three-layer stack. Built for this Vehicle alone.

The Vehicle controls Layer 1. Fasset operates Layer 2. Layer 3 is external counterparties under contract.

1 Distribution & Access Vehicle-owned
Zong
My Zong App50M+ subscribers reached
Zindigi
Zindigi App5M+ digital banking users
API Gateway
Throttling, routing
Identity & KYC
CNIC + biometric
Consent & Auth
OAuth, data flows
Policy Engine
Sharia + SBP + PVARA
Partner SDK
3rd-party developers
2 Core Web3 Rails Fasset Operated
01
Identity
Verified credentials, attestations
02
Wallet & Value
PKR, stablecoin, RWA
03
Payments
Atomic, cross-border
04
Tokenisation
ETFs, sukuk, equities
05
Compliance
Travel Rule, AML, monitor
06
Smart Contracts
Escrow, lending, payouts
07
Ledger
Immutable audit trail
08
Oracles
FX, equity, sukuk feeds
09
Partner Integration
Vehicle SDK, MZA, Zindigi APIs
The IP
10
Governance
PVARA, SBP, dashboards
Blockchain layer · leased, not owned
Polygon Tron · USDT Ethereum BNB Solana
3 External Ecosystem Contracted
SBP · PVARA
Regulators
JS Bank Core
PKR rails
KYC Vendors
Sumsub, HyperVerge
Custody
Fireblocks, BitGo
Compliance
Chainalysis, TRM
RWA Issuers
Securitize, Ondo
Global Rails
Circle, Bridge, BVNK
06 · Why Fasset. Why now.

The Vehicle has decided to ship Web3. The remaining question is who builds it.

Three operator categories could deliver this stack inside the announcement window. Global custody-and-tokenisation vendors like Fireblocks or Anchorage can supply rails turnkey, but lack a Pakistan operating entity. Regional crypto operators like Bitpanda or Bitso have platform depth, but no deployment cadence in South Asia. Integrated VASPs built for emerging markets combine the regulatory model with local deployment. In Pakistan, that category narrows to Fasset.

01

PVARA-ready VASP operating model

Identity, KYC/AML, custody segregation, transaction monitoring, Travel Rule compliance. Deployed at scale. Pre-engagement materials drafted by counsel already working with the regulator.

Pre-built. Pre-procured. Pre-licensed.
02

Institutional custody integrations

Fireblocks, BitGo, Anchorage. Insurance-backed. Hot, warm, cold separation. MPC-based key management. Built once at scale, deployable to the Vehicle.

Audit-grade key infrastructure.
03

Tokenisation stack for RWAs

Securitize, Tokeny, Ondo. US ETFs, sovereign sukuk, equities, supply chain receivables. ERC-3643 permissioned-transfer standard. Compliance built into the token, not bolted on.

Pre-built issuer integrations.
04

Stablecoin issuance pathway

White-label issuance via Paxos, Bridge, or Anchorage. Reserve management. Monthly attestation. Quarterly audit. The Vehicle owns the brand. Fasset operates the rail.

Western Union and Anchorage pattern.
05

Architecture proven at scale

The same infrastructure runs in live emerging-markets deployments at scale. The Vehicle is not the prototype. Pakistan is not the first deployment.

Deployed at scale, not a first build.

Cost model that travels

Variable cost per active user, benchmarked at deployment scale.

KYC
$0.80$2.50
Tech & Support
$1.00$3.00
Custody
$0.25$0.75
Blockchain
$0.05$0.15
per transaction
The precedents are on file
Took the operator
Easypaisa × Ant Group

$10M fresh equity at DRB grant. Crypto capability inherited from Ant's stack. The DRB licence and the operator decision happened in the same quarter.

Took the operator
GCash × Ant Group

The Philippines' largest wallet, backed by Globe Telecom, runs its crypto and investment layer on Ant's stack rather than an in-house build. The regional pattern is consistent.

Built path experience
CMPak × PayMax

EMI license March 2022. Surrendered October 2023. CMPak has direct operational experience with the in-house build path.

07 · Roadmap

Twelve months from sign-off. Six on critical path.

Pre-announcement integration is the critical path. If the Vehicle announces Q3 2026, Phase 1 must be in build by July. There is no compressed version.

00
Day 0 to 30
Alignment
  • NDA execution
  • Principals meeting
  • PVARA pre-engagement letter
  • Commercial flavour agreed
01
Day 30 to 120
MVP
  • Wallet inside super-app
  • USDT, USDC buy and sell
  • PKR off-ramp via JS Bank
  • Basic RWA brokerage · US ETFs
  • PVARA NOC submission
02
Day 120 to 240
Corridors
  • GCC to PK remittance corridor
  • Tokenised sovereign sukuk
  • Freelancer USD-stablecoin rail
  • Merchant tokenised payments
03
Day 240 to 365
Enterprise rails
  • Tokenised G2P payouts
  • Supply-chain finance
  • PSX equity tokenisation pilot
  • CMCC cross-border preview
08 · Unit economics

Break-even at 100K active users. Everything above is upside.

Directional numbers. A full model with sensitivity sits in the engagement letter. The purpose here is to size the opportunity well enough for principals to decide whether the integration warrants the next set of conversations.

Three revenue lines
Wallet transactions
30 to 50 bps
$50 to $150 per MAU per month
Tokenised asset brokerage
60 to 120 bps
$40 to $200 per active trader per month
Stablecoin remittance corridor
100 to 200 bps
$100 to $400 per corridor user per month
Scale ramp
Phase 1 · MVP
100K to 500K registered
5K to 25K MAU
Sub-$0.5M ARR · Investment phase
Phase 2 · Corridors
1M to 2M registered
50K to 150K MAU
$1M to $4M ARR · Contribution positive
Phase 3 · Enterprise rails
3M to 5M registered
200K to 400K MAU
$5M to $15M ARR · 10 to 25% contribution margin
Contribution-positive at 100K MAU. Blended ARPU crosses $4 per MAU per month in late Phase 2. Variable cost stack of $2.10 to $6.40 per MAU per month sits inside the cost grid in Section 06. Conservatism: conversion anchored on JazzCash's documented 5 to 8% MAU-to-registered ratio. Excludes upside from PSX equity tokenisation and supply chain finance.
09 · Commercial structure

The operator is settled. The shape is the Vehicle's choice.

Three structures sit on the table. The right one depends on how much capital each side commits and how fast the Vehicle needs to move.

A
Lowest friction
Vendor-as-a-service

Fasset bills the Vehicle on per-active-user and per-transaction terms. No equity. No revenue share. Fastest to deploy. Cleanest counterparty profile.

Fastest No exclusivity risk
B
Aligned
Revenue share

Fasset operates the Web3 layer and takes a defined percentage of net Web3 revenue for a fixed period. Aligned incentives. Medium upside on both sides.

Aligned Mid-term
C
Deepest
Minority equity

Fasset takes a sub-10% stake against infrastructure contribution. Optionally paired with a tokenised utility instrument for institutional investors.

Highest upside Longest close
Confidential · Q2 2026 window

The category gets named once.
The Vehicle names it.

Six months from sign-off, the Vehicle ships the only PVARA-licensed Web3 layer in Pakistan. The competitors are eighteen months behind on category, or not in it at all. The Vehicle either ships the rail first, or watches a fast follower take the category.

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