ABS & Co advises on regulatory aspects for proposed gold-backed lending model

We’ve advised on the banking and financial aspects of a proposed “Gold Bank” model in Pakistan. This innovative mandate involved the acceptance of gold as an investable asset, the issuance of investment instruments, profit-sharing returns, and gold-backed lending. 

The firm’s role included a comprehensive assessment of licensing boundaries under Pakistan’s banking and financial services framework. We analyzed whether the proposed activities would constitute deposit-taking, investment solicitation, or banking business requiring formal authorization from the State Bank of Pakistan. The team further explored alternative regulatory pathways, including Non-Banking Finance Company (NBFC), Modaraba Management Company, and investment company structures. The matter was particularly significant due to the regulatory implications of using the term “bank,” the quasi-deposit-taking characteristics of the model, and the strict regulatory perimeter governing banking activities in Pakistan.

ABS & Co provided detailed advisory on the permissibility of accepting gold as an asset for investment or financing purposes, as well as on profit-sharing mechanics, custody arrangements, and gold-backed lending features. This engagement underscores the firm’s capability in navigating complex regulatory landscapes for pioneering financial products and institutional models.

This matter was handled by Samar Masood, Partner at ABS & Co, along with Associates Ena Murakami, Ahmed Islam, and Uzair Ahmed Jan.

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