PRACTICE AREA · AIFC & DIGITAL ASSETS
AIFC & Digital Assets
Bond Stone advises on AIFC legal matters, including entity formation, AFSA licensing across all regulated categories, AIFC Court proceedings and IAC arbitration, AIFC regulatory compliance, and investment tax residency. Bond Stone's partners hold AIFC Registered Legal Adviser (RLA) status. Rights of audience before the AIFC Court come from registration with the AIFC Court Registry.
For a fuller guide to the AIFC as a legal environment, see the AIFC Legal Guide 2026 →
AIFC — Key Facts 2026
4,954
Participants from 91 countries — end 2025
USD 6B
Raised through AIFC in 2025
2066
Tax exemption horizon — qualifying services and income only
AIFC Legal Services
AFSA Licensing — Categories
The AIFC Legal Framework
English common law jurisdiction
The AIFC operates on the Acting Law of the Astana International Financial Centre — incorporating English common law as its foundation. AIFC Contract Regulations, Companies Regulations, Employment Regulations, and AFSA rulebooks are drafted in English and draw on English law principles. Constitutional Statute No. 438-V dated 7 December 2015 established the AIFC as an independent jurisdiction within Kazakhstan, operational since 2018.
AIFC Court & IAC
The AIFC Court is staffed by judges of international standing with English common law backgrounds; the court is led by a former Lord Chief Justice of England and Wales, and its justices include former Court of Appeal and High Court judges. It operates in English, applies AIFC law, and issues judgments enforced in Kazakhstan on the same terms as Kazakhstani court judgments. As of 24 December 2025 the AIFC Court and IAC had completed and enforced more than 4,600 cases since they began operating, including 227 court judgments, 1,039 arbitration cases and 3,427 mediation cases (AIFC, 26 December 2025).
Tax incentives — until 2066
The exemptions depend on the activity, not on AIFC registration alone (Constitutional Statute No. 438-V, Article 6). Until 1 January 2066, AIFC participants are exempt from corporate income tax (CIT) on income from financial services provided in the AIFC: Islamic banking, reinsurance and insurance broking, services for investment funds, brokerage, dealing and underwriting, and other services set by joint act. The digital asset exchange is excluded. Those services are also exempt from VAT. The same CIT exemption covers legal, audit, accounting and consulting services supplied to AIFC bodies and to those participants. Foreign employees of such participants are exempt from individual income tax (IIT) until the same date, and these participants pay no property tax or land tax on objects in the AIFC. All individuals and legal entities are exempt until 2066 on dividends from, and gains on, shares of AIFC-registered companies and on officially listed securities. Bond Stone advises on how these exemptions apply to a given structure.
Digital assets — first stablecoin licence, USD 10.58B transaction volume
In June 2025 AFSA granted its first licence for fiat-backed stablecoin issuance. 9 DASPs operated under the full regulatory framework and 19 within the FinTech Lab. DASPs generated USD 10.58 billion in transaction volume with a client base of approximately 215,000 users. AFSA officially joined IOSCO's I-SCAN fraud alert network in 2025.
AFSA regulatory amendments — effective 1 January 2026
AFSA introduced amendments to capital markets, digital assets, and crowdfunding frameworks effective 1 January 2026. AFSA's 2026 regulatory agenda includes an Appointed Representative Framework, Derivatives Framework amendments, Asset Management Framework review, and updates to Fitness and Propriety Guidance. Bond Stone advises participants on the compliance implications.
Experience
AFSA Licensing · AIFC · Digital Assets
AFSA Digital Asset Exchange Licence
Advising a digital asset exchange on AFSA licensing — regulatory business plan, AML/CTF framework, custody arrangements, consumer protection policies, and transition from FinTech Lab sandbox to full authorisation.
AIFC Court · Dispute Resolution · Financial Services
AIFC Court — Commercial Dispute
Representing an AFSA-regulated entity in AIFC Court proceedings — pleadings, evidence preparation, and enforcement of AIFC Court judgment across Kazakhstan.
AIFC Entity Formation · M&A Structuring · Kazakhstan
AIFC Holding Structure — Cross-border M&A
Structuring a cross-border Kazakhstan acquisition using an AIFC private company as the acquisition vehicle — English law shareholders' agreement, AIFC Court dispute resolution clause, tax exemption analysis, and AIFC Registrar filing.
AFSA Licensing · AIFC · Fintech
AFSA Payment Services Licence
Full-cycle advisory on AFSA payment services licence application — regulatory business plan, AML/CTF framework, systems documentation, qualified personnel requirements, and ongoing AFSA supervisory liaison post-authorisation.
AIFC · Tax Residency · Individual
Investment Tax Residency — ITRP
Advising a senior international executive on Kazakhstan tax residency through the AIFC Investment Tax Residency Programme — AIFC company formation, qualifying investment structuring, C5 investor visa, and family residence permits.
AFSA Licensing · AIFC · Asset Management
AFSA Investment Management Licence
Advising an international asset manager on AFSA investment management licence application — fund structuring, regulatory business plan, compliance framework, and AIX listing advisory for fund units.
Why Bond Stone for AIFC Matters
- AIFC Registered Legal Adviser — AIFC law advice and AIFC Court appearances
- Dual capability — AIFC/English common law and Kazakhstan civil law on a single mandate
- Astana office — adjacent to the AIFC; direct engagement with AFSA and AIFC Authority
- Active AFSA licensing track record — digital assets, payment services, investment management, brokerage
- Ranked Legal 500 EMEA Top Tier and IFLR1000 Market Leader — Kazakhstan
Related Industry Practice
Bond Stone's AIFC practice is the foundation of our FinTech & Digital Assets industry advisory. Explore our sector intelligence guide for digital asset businesses in the AIFC.
Frequently Asked Questions — AIFC & AFSA Licensing
What AFSA licence categories are available for digital asset service providers in the AIFC?
AFSA licenses Regulated Activities in relation to Digital Assets under the AIFC Rules on Digital Asset Activities, including Operating a Digital Asset Trading Facility, Providing Custody, Dealing in Investments as Principal or Agent, and Providing Money Services, which covers issuing Fiat stablecoins. AFSA granted its first licence for fiat-backed stablecoin issuance in June 2025. Operators may first enter the AFSA FinTech Lab under a sandbox authorisation. By the end of 2025, 9 DASPs operated under full authorisation and 19 within the Lab, generating USD 10.58 billion in transaction volume.
How does the AIFC Court differ from Kazakhstan's national courts?
The AIFC Court applies the Acting Law of the AIFC — based on English common law — rather than Kazakhstani civil law. Proceedings are conducted in English by internationally experienced judges (led by a former Lord Chief Justice of England and Wales, with former Court of Appeal and High Court judges). Its judgments are enforced in Kazakhstan on the same terms as Kazakhstani court judgments, after an Execution Order from the AIFC Court, without recognition proceedings — unlike foreign court judgments. As of 24 December 2025, the AIFC Court and the International Arbitration Centre (IAC) had completed and enforced more than 4,600 cases since they began operating. Bond Stone's partners hold AIFC Legal Adviser status and appear before the Court; rights of audience come from registration with the AIFC Court Registry.
What tax benefits do AIFC participants receive?
AIFC registration alone gives no general tax exemption. Under Article 6 of Constitutional Statute No. 438-V, until 1 January 2066 participants are exempt from corporate income tax (CIT) on listed financial services provided in the AIFC and on legal, audit, accounting and consulting services supplied to AIFC bodies and to those participants. Those financial services are exempt from VAT, foreign employees of such participants are exempt from individual income tax (IIT), and such participants pay no property tax or land tax on objects in the AIFC. Dividends from, and gains on, shares of AIFC-registered companies are exempt for all recipients until the same date. Registration of currency contracts and notification of currency operations are not required for currency operations carried out by participants in the AIFC (Article 5). These incentives suit investment management platforms and financial services operations; a pure holding company relies on the dividend and capital gains exemptions.
Do I need an AFSA licence to operate a crypto exchange in the AIFC?
Operating a digital asset exchange in or from the AIFC requires AFSA licensing. Requirements include capital adequacy, AML/CFT framework documentation, custody arrangements, consumer protection policies, qualified personnel, and IT systems standards. Operators may first enter the AFSA FinTech Lab (sandbox) while building infrastructure, then transition to full authorisation. Bond Stone advises from the pre-application assessment through to post-authorisation compliance.
What types of legal entities can be incorporated in the AIFC?
The AIFC Companies Regulations provide for: AIFC Private Company (the most common vehicle for holding structures, SPVs, and AFSA-licensed entities); AIFC Public Company (for entities listed on AIX); AIFC Limited Liability Partnership (LLP); and AIFC Foundation (for wealth and philanthropic structuring). AIFC entities are registered with the AIFC Registrar under English common law principles. The CIT exemption until 2066 is not automatic: it covers income from qualifying services only. Bond Stone advises on entity selection based on the client's operational, licensing, tax, and exit objectives.
Discuss your AIFC matter
Contact Bond Stone for a confidential discussion about AIFC entity formation, AFSA licensing, or AIFC Court proceedings.
info@bondstonelaw.com
+7 702 808 11 58 — Astana (adjacent to AIFC)
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