Kazakhstan
Fintech Digital Assets
PRACTICE AREA · FINTECH & DIGITAL ASSETS
FinTech, Digital Assets & AIFC Licensing in Kazakhstan
Bond Stone advises fintech companies, digital asset exchanges, payment services providers, and investment platforms on AFSA licensing, AIFC entity structuring, regulatory compliance, and AML/CFT frameworks in Kazakhstan. Bond Stone's partners hold AIFC Registered Legal Adviser status; rights of audience before the AIFC Court come from registration with the AIFC Court Registry. Ranked Legal 500 EMEA and IFLR1000.
The Astana International Financial Centre (AIFC) is Kazakhstan's centre for regulated fintech and digital asset business. It operates under a legal framework based on English common law — with a corporate income tax exemption on qualifying financial services, and an income tax exemption on dividends from and gains on shares of AIFC-registered companies, until 1 January 2066. The Astana Financial Services Authority (AFSA) regulates all financial services within the AIFC, issuing licences across digital assets, payment services, investment management, banking, insurance, Islamic finance, and capital markets. An AIFC structure offers published rules, activity-based tax exemptions and English-language proceedings at the AIFC Court. It does not by itself open the Kazakhstan market: serving residents outside the AIFC is limited by the AIFC currency rules and may need national authorisation.
Primary authority: AIFC Acts and AFSA Rulebooks — aifc.kz · AFSA: afsa.kz
FinTech & Digital Asset Legal Services in Kazakhstan
AFSA Digital Asset Licensing
Application strategy, business plan review for AFSA compliance, AML/CFT framework drafting tailored to the applicant’s specific business model and customer risk profile, fitness and propriety documentation for Approved Individuals, and regulatory dialogue with AFSA during review. Bond Stone has managed AFSA digital asset exchange licence applications through to determination. See: Digital Assets & Crypto Licensing →
AFSA Payment Services Licensing
Capital adequacy structuring to meet the capital requirement under the AIFC Rules on Providing Money Services (base capital of USD 50,000, or a higher expenditure-based or e-money amount), compliance framework documentation, client categorisation and disclosure obligations under AFSA conduct of business rules, conflict of interest management, and full regulatory submission preparation. See: Payment Services Licensing →
AFSA Investment Management Licensing
Advising on AFSA Managing Investments, Advising on Investments, and Arranging Deals in Investments licence categories — application strategy, AFSA conduct of business compliance, Approved Individual preparation, and ongoing regulatory compliance advisory. See: Investment Management Licensing →
AIFC Entity Formation for FinTech
AIFC company or LLP formation under the AIFC Companies Regulations — constitutional documentation, shareholder agreement structuring under English common law, AFSA regulatory positioning for proposed regulated activities, and coordination with the Kazakhstani operating subsidiary layer. Bond Stone advises on the dual-layer AIFC holding company plus Kazakhstani operating entity structure used by fintech investors. See: AIFC Entity Formation →
AML/CFT Compliance Frameworks
Drafting AML/CFT policies, customer due diligence procedures, transaction monitoring frameworks, suspicious activity reporting procedures, and sanctions screening protocols tailored to digital asset exchanges, payment services providers, and investment platforms. AFSA requires AML/CFT frameworks as part of the licence application and as an ongoing regulatory obligation.
AIFC Tax Structuring
Analysis of the AIFC corporate income tax exemption for qualifying services and the exemption for dividends and gains on shares of AIFC-registered companies, both through 2066, withholding tax analysis on dividends paid to foreign shareholders under applicable double tax treaties, intercompany loan structuring, and AIFC entity formation.
AFSA Regulatory Compliance & Ongoing Advisory
Ongoing regulatory compliance advisory for AFSA-licensed entities — periodic compliance reviews, Approved Individual changes, material change notifications to AFSA, policy updates, and preparation for AFSA supervisory visits. Bond Stone advises licensed entities on maintaining compliance with AFSA conduct of business rules, prudential requirements, and AML/CFT obligations on a retainer basis. See: AIFC Regulatory Compliance →
AIFC Court Proceedings
Representing fintech clients in AIFC Court commercial disputes — breach of platform agreements, investor disputes, regulatory appeals, and enforcement of AIFC Court judgments. Bond Stone's partners hold AIFC RLA status and appear before the AIFC Court, where rights of audience come from registration with the AIFC Court Registry. See: AIFC Court Proceedings →
FinTech — Detailed Guides
Full AIFC advisory — entity formation, AFSA licensing across all categories, AIFC Court, tax residency, regulatory compliance — Read more →
All AFSA licence categories — digital assets, payment services, investment management, banking, insurance, Islamic finance, capital markets — Read more →
AIFC company and LLP formation, constitutional documents, shareholder agreements under English common law — Read more →
AIFC Court commercial disputes, enforcement, and regulatory appeals — English-language proceedings, rights of audience on registration with the AIFC Court Registry — Read more →
Tax Advisory — Kazakhstan & AIFC
AIFC CIT exemption on qualifying services, withholding tax, DTT planning, transfer pricing — for fintech investors structuring through Kazakhstan and AIFC — Read more →
Secondary sanctions risk, AML/CFT compliance, export controls — for fintech and digital asset businesses operating across Kazakhstan and the AIFC — Read more →
Key Facts — AIFC FinTech Licensing
| LICENCE CATEGORY | MIN. CAPITAL | KEY REQUIREMENT |
|---|---|---|
| Digital Asset Trading Facility | Higher of USD 200,000 or 12 months' operating expenses | AML/CFT framework, Approved Individuals, technology systems review |
| Payment Services | USD 50,000 base capital, or a higher calculated amount | Client categorisation, safeguarding, AML/CFT compliance |
| Investment Management | USD 150,000 (Managing Investments) | Conduct of business rules, Approved Individuals, Compliance Officer |
| Banking & Credit | USD 10,000,000 (Bank); USD 2,000,000 (Credit Provider) | Prudential requirements, full AFSA application, Approved Individuals |
| AIFC CIT exemption | Exempt until 2066, qualifying services only | CIT on listed financial services (the digital asset exchange is excluded); dividends and gains on shares of AIFC-registered companies exempt for all recipients |
| AIFC Court jurisdiction | English common law | English-language proceedings; independent of the Kazakhstan court system |
Selected Experience — FinTech & AIFC Licensing
Bond Stone has advised on AFSA licensing applications, AIFC entity structuring, and regulatory compliance mandates for digital asset exchanges, payment services providers, investment platforms, and fintech holding companies — acting for clients from Asia, the Gulf, Europe, and North America entering Kazakhstan through the AIFC.
AFSA Licensing · AIFC · Digital Assets
AFSA digital asset exchange licensing
Bond Stone acted as AFSA licensing adviser for a digital asset exchange seeking a Digital Asset licence — application strategy, business plan compliance review, AML/CFT framework drafting, fitness and propriety documentation for Approved Individuals, and regulatory dialogue with AFSA during review. Partner: Sanat Ablakov.
AFSA Licensing · AIFC · Payment Services
AFSA payment services licensing
Bond Stone advised a Central Asian payment services provider on AFSA licensing — capital adequacy structure, compliance framework, client categorisation, conflict of interest management, and full regulatory submission. Partner: Sanat Ablakov.
AIFC Entity Formation · FinTech · Tax Structuring
AIFC fintech holding company — cross-border structuring
Bond Stone advised an international fintech investor group on forming an AIFC holding company above a Central Asian operating subsidiary — AIFC Companies Regulations entity formation, AFSA regulatory positioning, shareholder agreement under English common law, and analysis of the AIFC dividend and gains exemption through 2066. Partner: Sanat Ablakov.
AIFC · Tax Residency · Individual Investors
AIFC Investment Tax Residency Programme advisory
Bond Stone advises individuals and fintech founders on the AIFC Investment Tax Residency Programme (ITRP): eligibility, application and ongoing compliance. The ITRP exempts its tax residents from tax on income from sources outside Kazakhstan; Kazakhstan-source income stays taxable. See: Investment Tax Residency Programme →
Why Bond Stone for FinTech & AIFC Licensing
- AIFC Registered Legal Adviser status held by the partners — AIFC Court appearances on registration with the AIFC Court Registry
- Active AFSA licensing practice — Bond Stone has managed AFSA licence applications across digital assets, payment services, and investment management categories through to determination
- Dual-layer advisory — AIFC/English common law holding company alongside Kazakhstani operating subsidiary on one mandate
- AIFC Court experience, including advice on AFSA enforcement proceedings concerning digital asset platforms
- Ranked Legal 500 EMEA and IFLR1000 in Kazakhstan — Almaty and Astana offices
Primary authority: aifc.kz · AFSA: afsa.kz
Bond Stone Kazakhstan offices: Almaty · Astana
Discuss your FinTech or AIFC licensing matter
Contact Bond Stone for a confidential discussion about AFSA licensing, AIFC entity structuring, AML/CFT compliance, or AIFC Court proceedings in Kazakhstan.
Request a Confidential ConsultationAFSA Licensing Hub →AIFC Practice Hub →