Islamic Republic of Pakistan

Pakistan (~230 million population, >97% Muslim) maintains a near-absolute constitutional and statutory prohibition on all forms of gambling. The federal Prevention of Gambling Act 1977 extends to the whole country and overrides other laws, reinforced by the Pakistan Penal Code and constitutional Islamic injunctions (Articles 31, 227, 37(g)). No gambling regulator, licence, or state lottery exists. A significant illegal offshore market — concentrated on cricket — persists, creating AML and payment-facilitation exposure rather than a commercially accessible market. This is a closed, hostile jurisdiction: a legal/AML risk signal, not an entry opportunity.

There is no gambling regulator and no licensing framework. The Prevention of Gambling Act 1977 prohibits all gambling and overrides other laws; the only statutory saving (s.11) is for games in a provincially licensed 'tourist complex' admitting foreigners only — a marginal historical derogation, not a commercial pathway. No B2C or B2B licence has ever been issued and no state lottery exists. All product classes are prohibited.

The National Cyber Crime Investigation Agency's action against 46 applications linked to illegal gambling, unlicensed trading, and data-privacy breaches operated at the distribution and platform-access layer, blocking applications rather than amending any licensing text. This is a probable-confidence finding, corroborated across independent trade-press coverage, though no primary regulator notice from the Pakistan Telecommunication Authority or the Federal Investigation Agency was located this cycle to confirm the scope of the block list. The action represents a tightening of the practical barrier facing any gambling-adjacent product that might otherwise reach Pakistani users through app-store or direct-download channels, even though the underlying statutory prohibition under the Prevention of Gambling Act, 1977 has not itself changed. Distribution-layer enforcement of this kind now sits alongside, rather than in place of, the base prohibition as the practical mechanism shaping platform access into the jurisdiction.

The Federal Investigation Agency intensified action against gambling-linked payment-aggregator flows, with press reporting on 8 October 2026 describing more than PKR 119.93 billion in traced transactions linked to gambling applications. JazzCash closed over one hundred aggregator accounts following FIA notices, with some reporting as high as three hundred, and Easypaisa merchant and aggregator settlements were delayed, affecting six major payment companies. A separate first information report, filed by the FIA's Composite Circle in Faisalabad, names eight suspects connected to six gambling platforms (U7777 Game, TD777, Game89, EPIWIN, B9 Game, S9 Game), alleging use of bank transfers, mobile wallets and USDT for real-money betting, with charges under the Foreign Exchange Regulation Act 1947 and the Pakistan Penal Code. A single press report also describes the Pakistan Telecommunication Authority blocking forty-six related applications; this figure is not independently corroborated. No FIA or State Bank primary notice has yet been located to corroborate the aggregate transaction figure, which rests on converging press reporting. The statutory basis for accessory liability in both matters is the Foreign Exchange Regulation Act 1947, applied against unlicensed gambling-linked value transfer through mobile wallets and payment aggregators, and the sustained, multi-agency character of the action signals active criminal exposure for any payment channel found to serve gambling platforms.