Building a Digital Retail Bank in Pakistan
Partner track record — Ali Saqib Janjua, Chief Operating Officer and Acting Chief Financial Officer, HugoBank (Private) Limited, August 2023 to September 2024
1. Context
In January 2022 the State Bank of Pakistan issued its Licensing and Regulatory Framework for Digital Banks, creating a route to a full banking licence for institutions with no branch network. The framework is deliberately staged. An applicant moves from in-principle approval, to a restricted pilot with a capped customer base, to commercial launch, and only then to a full Digital Retail Bank licence. Each gate requires the regulator to be satisfied on capital, governance, technology, risk and operational readiness before the next one opens.
Five applicants received in-principle approval. HugoBank was one of them, backed by a consortium including Atlas Consolidated of Singapore, The Getz Group and Muller and Phipps Pakistan.
The challenge in this kind of mandate is not the technology. It is that a licence applicant has to behave like a regulated bank long before it is allowed to act like one. It must stand up a full governance and control environment, a credible ten year financial case, a cloud and technology architecture the regulator will accept, and a management team capable of running it, all while generating no revenue and drawing continuously on shareholder capital.
2. Mandate
Ali Janjua joined as Chief Operating Officer, and additionally held the Acting Chief Financial Officer role, reporting to the Chief Executive Officer and the Board. The remit covered corporate governance, human resources, risk, financial control and the regulatory relationship through the pre-licence phase.
3. What the work involved
Corporate and financial strategy. Developing the business strategy, the financial model and a ten year plan capable of surviving both Board and regulator scrutiny. Securing Board approval for equity investment tranches and for the delivery timeline.
Governance architecture. Building the bank-wide governance framework from a blank sheet, spanning cloud strategy, information technology, internal audit, risk, customer service, human resources and compliance, each aligned to the relevant State Bank of Pakistan guidance. For a digital bank this is more demanding than for a conventional entrant, because controls that a branch network would deliver through physical process have to be evidenced entirely within systems.
Technology and cloud. Directing the technology roadmap and assembling the cloud services pack required by the State Bank of Pakistan. Cloud adoption in a regulated Pakistani banking context requires the applicant to satisfy the regulator on data residency, outsourcing risk, exit planning and operational resilience, not simply to select a provider.
Pilot readiness. Leading the pilot readiness submission, the gate that determines whether an applicant may begin testing with live customers.
Institution building. Procurement, hiring, and investor relations. Building the management and specialist teams needed to deliver against the licensing milestones.
Regulatory engagement. Running the direct relationship with the State Bank of Pakistan to keep operational frameworks aligned to each licensing gate.
4. Outcome
HugoBank progressed through the in-principle approval stage and built the governance, financial and technology foundation required for the pilot phase. The bank subsequently received pilot operations approval from the State Bank of Pakistan and completed its licensing process in August 2026.
The later approvals fell after Ali Janjua’s tenure ended in September 2024. What the work delivered was the institutional foundation on which those approvals rested: the governance frameworks, the financial case, the cloud and technology submission, and the pilot readiness package.
5. What this means for a client
Three lessons transfer directly to any institution pursuing a digital banking or electronic money licence in a staged regulatory regime.
The licence is won on governance, not on product. Applicants consistently over-invest in the customer proposition and under-invest in the control environment. The regulator is assessing whether the institution can be trusted to hold retail deposits. Product differentiation matters commercially, but it does not open the gate.
Cloud is a regulatory question before it is a technical one. Treating cloud as a procurement decision rather than an outsourcing and resilience question is the most common cause of delay at the technology gate.
The pre-licence period burns capital with no revenue. The ten year financial model has to be honest about how long each gate takes and what the institution costs to run while waiting. Optimistic sequencing in the model becomes a governance problem later, when the Board is asked for capital that was not planned for.
6. Relevant capability
Digital bank and electronic money licensing strategy, regulatory submission design, governance and control framework build, cloud and outsourcing risk, financial modelling for licence applicants, and Board and regulator engagement.
This case study describes a partner’s executive experience prior to joining Leap Associates. It draws on publicly reported facts and the partner’s own record. It does not disclose confidential information belonging to HugoBank or its shareholders, and HugoBank was not a client of Leap Associates.