AIFC & AFSA · Financial Services Licensing

AFSA Payment Services Licensing

Part of Bond Stone's AFSA Licensing Practice

AFSA licences for payment services providers, e-money issuers, and operators of payment systems within the Astana International Financial Centre — regulatory framework, licensing requirements, and ongoing compliance obligations.

Payment Services Regulation under AFSA

The Astana Financial Services Authority (AFSA) regulates payment services within the Astana International Financial Centre (AIFC) under the AIFC Rules on Providing Money Services (PMS), in full effect since 13 January 2026, together with the AIFC General Rules. Payment services activities conducted from or within the AIFC require an AFSA licence, regardless of whether the payments themselves are processed domestically or cross-border.

The AIFC payment services regime is distinct from the National Bank of Kazakhstan (NBK) payment organisation registration, which governs payment service providers operating under Kazakhstani domestic law outside the AIFC perimeter. Companies seeking to serve the broader Kazakhstani market in tenge, or to connect directly to the domestic interbank settlement system, typically require both an AFSA licence (for AIFC-based operations and cross-border services) and NBK registration (for domestic tenge settlement). Bond Stone advises on both regimes and on structuring entities to hold each registration appropriately.

Regulated Payment Activities under AFSA

AFSA regulates the following payment activities. Providing Money Services and Operation of a Payment System are separate Regulated Activities; issuing e-money and currency exchange are types of Money Service under paragraph 21 of Schedule 1 to the AIFC General Rules:

Providing Money Services. Covers execution of payment transactions (credit transfers, direct debits), payment initiation services, account information services, and money remittance. Applies to payment processors, B2B payment platforms, remittance operators, and API-based payment gateways serving AIFC-registered clients or processing cross-border transactions routed through the AIFC.

Issuing Payment Instruments (E-Money). Covers issuance of electronic money — stored-value instruments redeemable in fiat currency. E-money must be issued and redeemed at par value, and client money must be safeguarded under Part 9 of the PMS. Fiat stablecoins are Digital Assets, which the AIFC Glossary distinguishes from E-money; they fall under Part 4 of the AIFC Rules on Digital Asset Activities.

Operation of a Payment System. Applies to entities that operate the infrastructure through which payment instructions are transmitted, cleared, or settled between participants. This covers card scheme operators and operators of proprietary settlement networks serving AIFC participants. Operating a Clearing House is a separate Market Activity.

Providing Currency Exchange Services. Spot foreign exchange conversion services provided commercially within the AIFC require an AFSA licence. Currency exchange desks operated as ancillary services by AIFC-registered banks or investment firms may hold this authorisation as a variation of their primary licence rather than a standalone licence.

Capital and Prudential Requirements

AFSA payment service providers must meet minimum capital thresholds that vary by licence category and the scope of services authorised:

Money Services (payment processing and remittance): The capital requirement is the highest of a base capital of USD 50,000, an Expenditure-Based Capital Minimum of 10% of Annual Audited Expenditure, and, for e-money issuers, the Electronic Money Capital Requirement (PMS 10.1).

E-Money Issuers: The Electronic Money Capital Requirement is 1.5% of the average daily outstanding e-money where total e-money issued exceeds USD 3 million. Client money must be safeguarded by placing it in a Client Money Account, investing it in secure, liquid assets, or covering it by an insurance policy or guarantee (PMS 9.1).

Payment System Operators: The capital figures in PMS 10.1 apply to Money Service Providers. We have not found a separate fixed capital figure for operating a payment system in the AIFC rules, so the requirement should be confirmed with AFSA at the pre-application stage.

A Money Service Provider must submit prudential returns and other information AFSA requests, under the relevant provisions of the Banking Business Prudential Rules (PMS 8.1). The Money Services Rules contain no general professional indemnity requirement; insurance appears there as one way to safeguard client money (PMS 9.1).

Licensing Process and Timeline

An AFSA payment services licence application proceeds in two stages: a pre-application meeting with AFSA, followed by formal application submission. Bond Stone recommends the pre-application meeting in all cases — it lets the applicant test the licence category with AFSA before preparing documents and reduces the risk of a scope problem later.

Required documentation for a payment services licence application includes: a regulatory business plan (describing the services, target clients, projected transaction volumes, and revenue model), financial projections (three-year, stress-tested), compliance manual and AML/CFT policies, IT and cybersecurity framework description, the proposed legal structure of the AIFC entity, fit and proper declarations for all controllers and senior managers, and source of funds documentation for the initial capital.

The Framework Regulations set no fixed statutory review period. AFSA states that its average processing time is around two to three months from receipt of a materially complete application, excluding time spent waiting for the applicant. The timeline depends on the complexity of the business model and the completeness of the application. Applications involving novel payment structures, cross-border currency flows or crypto infrastructure usually draw more questions from AFSA; our working estimate for them is 90 to 120 days from submission to in-principle approval.

The licence is held by an entity registered in the AIFC, either incorporated there or registered as a Recognised Company. An offshore parent cannot hold it from outside the AIFC. The entity needs a real presence: a registered office in the AIFC and staff able to run the licensed activity. A shell with all staff and functions outside the AIFC should not expect to obtain a licence.

AML/CFT and Compliance Obligations

Payment service providers licensed by AFSA are subject to the AFSA AML/CFT Rules, which implement the FATF Recommendations. Key obligations include: customer due diligence (CDD) and enhanced due diligence (EDD) for high-risk clients and transactions, transaction monitoring, suspicious transaction reporting to the Financial Intelligence Unit of the Republic of Kazakhstan (the state authority responsible for financial monitoring), record retention for a minimum of six years, and regular reviews of AML/CFT effectiveness by the audit function, at least once every two years.

Transactions for clients in sanctioned jurisdictions, or involving sanctioned persons, carry serious regulatory risk. The AML Rules require screening against UN Security Council sanctions lists and the Kazakhstan Sanctions List, and firms must consider unilateral sanctions such as those of the EU, the UK, and the US (OFAC) where required or appropriate; licensees with US dollar clearing arrangements must also comply with correspondent bank sanctions screening requirements, which are typically more stringent than AFSA's own rules.

Bond Stone drafts AML/CFT compliance manuals, transaction monitoring procedures, and sanctions screening frameworks for payment services licence applications and assists with the AML/CFT audit process. We also advise on responses to AFSA supervisory enquiries and on self-reporting obligations when a compliance breach is identified.

AFSA Payment Services vs NBK Payment Organisation

Foreign-owned payment businesses entering Kazakhstan regularly face a structural choice between AFSA licensing and NBK payment organisation registration. The two regimes serve different purposes and are not interchangeable:

An AFSA licence is the appropriate route for companies operating primarily in foreign currency, serving international clients, or wanting a regulatory framework based on English common law. AFSA licensing documents, regulatory opinions, and correspondence are all in English. The AIFC Court provides an English-language dispute resolution forum. The AIFC framework's basis in the law of England and Wales and the standards of leading global financial centres can assist in accessing European banking and payment scheme partnerships.

NBK payment organisation registration is the correct route for companies that need to connect directly to Kazakhstan's domestic interbank payment infrastructure, or process tenge transactions for Kazakhstani consumers or businesses. NBK registration is conducted entirely under Kazakhstani law and in Kazakh or Russian.

A payment business serving both markets may establish two entities: an AIFC-incorporated company holding the AFSA licence (for international operations and investor-facing structuring) and a Kazakhstani LLP registered with NBK (for domestic tenge settlement). Bond Stone advises on both entities and on the intra-group agreements and fund flows between them.

Fintech and Embedded Finance Applications

Fintech companies building embedded finance products often ask whether they fall under this regime. B2B payment platforms, payroll processors, remittance apps and API banking providers may do so if they carry on a Regulated Activity in or from the AIFC, depending on what they actually do. A BNPL product may instead be Providing Credit. The AFSA FinTech Lab allows novel payment products to be tested and developed under a FinTech Lab Licence, which has effect for 2 years and may be extended, without the firm being immediately subject to the full set of regulatory requirements.

Bond Stone advises on AFSA FinTech Lab applications, on determining whether a fintech product falls within the payment services perimeter or the digital assets perimeter (a question that arises frequently with stablecoin-based payment products), and on the regulatory opinion letters that investors and banking partners often ask for before committing capital or correspondent services to a new payment platform.

Frequently Asked Questions

Our Experience in AFSA Payment Services Licensing

Bond Stone has advised payment technology companies, fintech platforms, and financial institutions on AFSA licensing strategy, AIFC entity structuring, and regulatory compliance across the AIFC payment services framework. Our AFSA practice draws on active mandates in payment organisation licensing, e-money issuance, and cross-border payment infrastructure, as well as work under the parallel NBK payment organisation registration regime.

Related Guides

AFSA Licensing in Kazakhstan — Overview  ·  AFSA Digital Assets & Crypto Licensing  ·  AFSA Banking & Credit Licensing  ·  AIFC Entity Formation  ·  Financial Services Licensing in Kazakhstan  ·  AML/CFT Compliance in Kazakhstan