SANCTIONS & TRADE COMPLIANCE · KAZAKHSTAN
AML/CFT Compliance in Kazakhstan
Bond Stone advises financial institutions, non-bank financial companies, and foreign investors on AML/CFT compliance in Kazakhstan — the domestic legal framework under Law No. 191-IV of 2009 on Countering the Legalisation (Laundering) of Proceeds of Crime and the Financing of Terrorism, FATF requirements, KYC/CDD obligations, beneficial ownership disclosure, and suspicious transaction reporting to the Financial Monitoring Agency of the Republic of Kazakhstan.
Key Framework
Kazakhstan AML/CFT Law — scope and obligations
Law No. 191-IV imposes compliance obligations on a broad range of entities including banks, non-bank financial institutions, payment organisations, real estate agents, dealers in precious metals and stones and, in the cases listed in Article 3, accountants and lawyers. Obligated entities must conduct customer due diligence (CDD), maintain records, report suspicious transactions to the Financial Monitoring Agency, and implement internal control programmes.
Financial Monitoring Agency and supervisors
The Financial Monitoring Agency of the Republic of Kazakhstan is the authorised body under the Law. It collects, processes and analyses information on transactions subject to financial monitoring, including suspicious transaction reports, coordinates the state bodies working against money laundering, and passes information to law enforcement bodies (Law No. 191-IV, Art. 16). Compliance by each type of reporting entity is supervised by the state body competent for that sector; for AIFC participants, the AFSA supervises jointly with the Agency (Art. 14). Bond Stone advises on dealing with the Agency and the sector supervisor, inspections and their enquiries.
KYC/CDD obligations
Obligated entities must conduct Know Your Customer (KYC) and Customer Due Diligence (CDD) on clients before establishing a business relationship or conducting a covered transaction. KYC/CDD requirements include: identification and verification of the client; identification of beneficial owners holding more than 25% of the entity or otherwise controlling it; understanding the nature and purpose of the business relationship; and ongoing monitoring of transactions. Enhanced due diligence (EDD) applies to high-risk clients including PEPs, high-risk jurisdictions, and complex ownership structures.
Beneficial ownership disclosure
Kazakhstan law requires the disclosure of ultimate beneficial owners (UBOs) in the context of company registration, banking relationships, and AML/CFT compliance. A beneficial owner is an individual who directly or indirectly holds more than 25% of the entity, controls it in another way, or for whose benefit transactions are carried out (Art. 1(3)). The Law also provides for a state register of beneficial owners, and a change of beneficial owner is notified to the registrar (Law No. 2198, Art. 14-2). Bond Stone advises on structuring beneficial ownership disclosure for complex international holding structures and ensuring compliance with Kazakhstan's UBO identification and verification requirements.
FATF and international compliance
Kazakhstan is a member of EAG (Eurasian Group on Combating Money Laundering) and participates in FATF mutual evaluation processes. Kazakhstan's AML/CFT framework is assessed against FATF standards, and the outcome of FATF evaluations can affect Kazakhstan's international banking relationships. Bond Stone advises on FATF-aligned compliance frameworks for entities seeking to maintain or expand international correspondent banking relationships.
Experience
AML/CFT · Kazakhstan · Fintech
AML Programme — Payment Organisation
Advising a Kazakhstan payment organisation on implementing a FATF-compliant AML/CFT programme — KYC/CDD policies and procedures, beneficial ownership identification, suspicious transaction reporting, and staff AML training framework.
AML/CFT · Kazakhstan · Banking
KYC Framework — Foreign Bank
Advising the Kazakhstan subsidiary of a foreign bank on its KYC/CDD framework — aligning Kazakhstan domestic AML requirements with the parent bank's group compliance standards and correspondent banking due diligence requirements.
AML/CFT · Kazakhstan · Corporate
UBO Identification — Complex Structure
Advising a Kazakhstan company with a complex international ownership structure on beneficial ownership identification and disclosure — mapping the UBO chain through multiple holding layers and documenting the beneficial ownership structure for AML compliance and banking onboarding purposes.
Why Bond Stone
- Kazakhstan market knowledge combined with expertise in the extraterritorial reach of US, EU, and UK sanctions
- Ranked Legal 500 EMEA Top Tier and IFLR1000 Market Leader — Almaty and Astana offices
Discuss your matter
Contact Bond Stone for a confidential discussion about AML/CFT compliance in Kazakhstan.
info@bondstonelaw.com
+7 (701) 729 76 72 — Almaty
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