AIFC · AFSA LICENSING
AFSA Licensing in the AIFC — Complete Guide
Bond Stone advises on the full spectrum of AFSA licensing within the Astana International Financial Centre — digital assets, payment services, investment management, banking, insurance, Islamic finance, and capital markets. We hold AIFC Registered Legal Adviser status with active mandates across the most in-demand licence categories.
The Astana Financial Services Authority (AFSA) is the independent regulator of financial services within the AIFC. In 2025, AFSA authorised 29 financial services firms, with strong interest in investment-related activities such as fund management, brokerage, and advisory services. AFSA’s 2025 Annual Report covers its activities across capital markets, asset management, digital assets, banking, and insurance.
Governed by: AIFC Financial Services Framework Regulations; AFSA Conduct of Business Rules; AFSA AML/CTF Rules; AFSA Fees Rules (as amended 1 December 2025); AIFC Rules on Digital Asset Activities (as amended 13 October 2025). Authority: afsa.aifc.kz
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Digital Assets (DASP · DATF · Stablecoin · STO) ·
Payment Services (MSP · EMI) ·
Investment Management ·
Banking & Credit ·
Insurance ·
Islamic Finance ·
Capital Markets
Licence Category Guides
Requirements common to all AFSA licence applications
✦ AIFC entity first — AFSA licences may only be held by AIFC-registered entities (Company or LLP). Incorporation must precede or run in parallel with the AFSA application.
✦ Non-refundable application fees — AFSA does not refund application fees regardless of outcome. The application is not regarded as submitted until the fee is paid in full. AFSA issues an invoice upon receipt of the completed fee request form.
✦ Approved Individuals — Key personnel (CEO/SEO, Finance Officer, Compliance Officer, MLRO, Deputy MLRO) must be individually registered with AFSA. Fit-and-proper assessment required for each.
✦ AML/CTF framework — All AFSA-licensed firms must implement AML/CTF policies compliant with AFSA AML/CTF Rules and FATF Recommendations before licence grant.
✦ Multiple activities — fee discount — Where an applicant seeks more than one Regulated Activity, the highest fee applies in full and each additional activity is charged at 50%.
Digital Assets
The digital assets sector has been and continues to be one of the key priority areas for market development within the AIFC. In 2025, the AIFC was recognised by IOSCO as one of the leading jurisdictions in implementing global standards for crypto and digital asset markets. AFSA supervised 9 Digital Asset Service Providers (DASPs) under the full regulatory framework, and 19 DASPs operated under supervision within the FinTech Lab, generating a total transaction volume of USD 10.58 billion with approximately 215,000 users.
| Licence / Activity | Description | Min Capital |
|---|---|---|
| DASP — Digital Asset Service Provider | Dealing in, managing, providing custody of, exchanging, or transferring digital assets. Covers crypto exchanges, custodians, brokers, and wallet service providers. Additional AFSA application fee: USD 2,800. | USD 10,000–200,000 depending on activity |
| DATF — Digital Asset Trading Facility | Market Activity licence for operating a centralised digital asset exchange. The most capital-intensive digital asset licence. Variable supervision fee capped at USD 250,000 effective 1 December 2025. | Higher of USD 200,000 or 12-month working capital |
| Stablecoin Issuer | Issuance of stablecoins — digital assets pegged to a currency, commodity, or financial instrument. Reserve and disclosure requirements apply. Framework effective 1 January 2024. | Determined by AFSA based on reserve model |
| STO — Security Token Offering | Issuance of security tokens — digital representations of shares, bonds, or fund units. Subject to AIFC prospectus and disclosure rules. Framework effective 1 January 2024. | Per underlying regulated activity |
| FinTech Lab | Regulatory sandbox. Licence issued for up to 2 years. Participants must migrate to the full AFSA supervisory regime by end of 2026. AML/CTF obligations apply from day one. | Reduced — per AFSA FinTech Lab terms |
| AFSA Discontinuance | Voluntary surrender of an AFSA digital asset licence. Requires formal application, wind-down plan, client notification, and regulatory exit documentation. | N/A |
Payment Services
Payment services within the AIFC are regulated under the Providing Money Services activity — covering money transmission, remittance, currency exchange, and electronic money issuance. Bond Stone has active experience across MSP and EMI mandates within the AIFC.
| Licence / Activity | Description | Min Capital |
|---|---|---|
| MSP — Money Services Provider | Money transmission, remittance, currency exchange, and cross-border payment services. Primary AFSA vehicle for international remittance companies and payment platforms. | USD 10,000–50,000 depending on scope |
| EMI — Electronic Money Institution | Issuance of e-money stored electronically and issued on receipt of funds. Covers e-wallet providers, prepaid card issuers, and digital payment platforms. Client funds must be segregated. | Per AFSA safeguarding requirements |
| Dual MSP + EMI | Combined money transmission and e-money issuance on one application. The second activity is charged at 50% of the standard single-activity fee. | Higher of the two individual requirements |
Investment Management
| Regulated Activity | Description | Min Capital |
|---|---|---|
| Managing Investments | Discretionary management of investment portfolios on behalf of clients. Covers asset managers, hedge funds, family office managers, and private equity fund managers. Liquid assets must equal at least 25% of annual operating expenditure at all times. | USD 150,000 |
| Managing a Collective Investment Scheme | Establishing, managing, or winding up a Collective Investment Scheme (fund). Covers Exempt Funds (professional investors) and Non-Exempt Funds (full disclosure). Base capital: USD 50,000–500,000 depending on fund type and nature. | USD 50,000–500,000 |
| Advising on Investments | Giving investment advice to clients on buying, selling, holding, subscribing for, or underwriting investments. Covers investment advisers and wealth managers. Additional digital asset fee of USD 2,800 if advice extends to digital assets. | USD 10,000 |
| Arranging Deals in Investments | Making arrangements for another person to buy, sell, subscribe for, or underwrite investments. Covers placement agents, fund distributors, and introducing brokers. | USD 10,000 |
| Dealing in Investments as Principal / Agent | Buying, selling, subscribing for, or underwriting investments as principal (own account) or agent (on behalf of clients). Covers broker-dealers and market makers. Capital adequacy calculated on a risk-adjusted basis. | Risk-adjusted |
| Providing Custody / Arranging Custody | Safekeeping and administration of investments (including digital assets) on behalf of clients. Arranging custody means arranging for another authorised firm to provide custody. Frequently combined with Managing Investments or DASP licences. | USD 10,000–150,000 |
| Providing Trust Services / Fund Administration | Trust services: acting as trustee or managing trust structures. Fund administration: providing back-office NAV calculation, accounting, transfer agency, and related services to funds. Frequently used by family offices and fund service providers. | USD 10,000 |
Banking & Credit
Advisory capacity — high capital requirements apply
Banking and credit activities within the AIFC are among the most capital-intensive licences and require significant governance infrastructure. Bond Stone can advise on the licensing pathway and application structure for banking and credit activities, though these mandates typically involve specialist prudential advisers working alongside legal counsel.
| Regulated Activity | Description | Min Capital |
|---|---|---|
| Accepting Deposits | Accepting money from the public on terms that it will be repaid. The core banking activity. Subject to extensive prudential requirements, governance obligations, and ongoing AFSA supervision. | Set by AFSA on case-by-case basis |
| Providing Credit | Lending money or extending credit facilities to clients. Covers lending institutions, consumer credit providers, and trade finance companies operating within the AIFC. | Set by AFSA |
| Advising / Arranging a Credit Facility | Advising clients on or making arrangements for credit facilities — including syndicated loans, trade finance structures, and debt capital market transactions. Lower capital requirement than direct lending. | USD 10,000 |
| Opening and Operating Bank Accounts | Opening and operating bank accounts on behalf of clients. Typically combined with custody or trust services mandates. Requires robust AML/CTF framework and client onboarding procedures. | Set by AFSA |
Insurance
Advisory capacity
| Regulated Activity | Description |
|---|---|
| Effecting / Carrying on Contracts of Insurance | Underwriting and carrying on insurance contracts — the core insurer activity. Subject to AFSA Insurance Business Rules and significant capital and solvency requirements. |
| Insurance Management | Managing the business of an insurer — policy administration, claims management, and reinsurance arrangement. Note: minimum capital requirement revised by AFSA Notice AFSA-Q-OA-2020-0025. |
| Insurance Intermediation | Arranging insurance contracts between insurers and clients. Covers insurance brokers and agents operating within the AIFC. |
| Operating a Representative Office | Foreign insurance companies may establish a non-commercial representative office within the AIFC without a full insurance licence — for liaison, marketing, and research purposes only. |
Islamic Finance
Growing AIFC priority — advisory capacity
The AIFC has made Islamic finance a strategic priority — establishing an international Islamic Finance Advisory Board with experts from the UAE, Saudi Arabia, Bahrain, Malaysia, Turkey, and Kazakhstan. The AIFC’s Islamic finance framework provides a full suite of Shariah-compliant financial services licences, positioning Astana as the Islamic finance gateway for Central Asia.
| Regulated Activity | Description |
|---|---|
| Islamic Banking Business | Conducting banking business in compliance with Shariah principles — covering Murabaha, Ijara, Musharaka, and Mudaraba structures. Governed by AFSA Islamic Banking Business Rules. |
| Providing Islamic Financing | Providing Shariah-compliant financing arrangements — covering trade finance, project finance, and structured finance using Islamic instruments. |
| Managing a Restricted Profit Sharing Investment Account | Managing investment accounts where returns are based on profit-sharing (Mudaraba) arrangements rather than fixed interest. Shariah-compliant alternative to discretionary investment management. |
| Takaful Business | Shariah-compliant insurance — participants contribute to a pool that provides mutual indemnity. AIFC Takaful framework supports both Family Takaful (life-equivalent) and General Takaful (non-life) operations. |
Capital Markets
Market Activities — AIX listed venue
Capital market activities within the AIFC are classified as Market Activities — regulated separately from Regulated Activities. The Astana International Exchange (AIX) is the AIFC’s licensed exchange, hosting listings of bonds, equities, and green finance instruments.
| Market Activity | Description |
|---|---|
| Operating a Multilateral Trading Facility (MTF) | Operating a non-discretionary trading system that brings together multiple buyers and sellers of financial instruments. Alternative to a regulated exchange — used for OTC bond trading, equity trading, and alternative investment platforms. |
| Operating an Organised Trading Facility (OTF) | Discretionary trading system for non-equity instruments — bonds, structured finance instruments, and derivatives. OTF operators may exercise discretion in order execution within defined parameters. |
| Operating a Digital Asset Trading Facility (DATF) | See Digital Assets section above. DATF is technically a Market Activity under AFSA rules — the most complex and capital-intensive digital asset licence category. |
Selected AFSA Licensing Experience
Bond Stone has advised on AFSA licensing mandates across digital assets, payment services, and investment management. Client confidentiality is maintained across all mandates.
International Digital Asset Exchange — AFSA Licence Discontinuance
DATF · AIFC · 2026
Full AFSA discontinuance mandate — AFSA liaison, wind-down plan, regulatory exit documentation, and post-discontinuance confirmation.
International Investment Bank — Dual MSP + EMI Application
MSP + EMI · AFSA · 2026
Dual payment services AFSA application — Money Services Provider and Electronic Money Institution combined mandate with full AML/CTF framework and Approved Individual registrations.
AFSA-Licensed Digital Asset Provider — AIFC Court Proceedings
DASP · AIFC Court · 2026
AIFC Court litigation on behalf of an AFSA-licensed digital asset service provider. Bond Stone holds automatic right of audience before the AIFC Court as an AIFC Registered Legal Adviser.
Fintech Platform — Multi-jurisdiction AFSA Licensing
DASP · Multi-jurisdiction · 2026
Multi-phase AIFC digital asset licensing mandate — AIFC entity structuring, AFSA application strategy, and cross-border regulatory advisory across multiple jurisdictions.
Why Bond Stone for AFSA Licensing
✦ AIFC RLA — eight specialisations including Digital Assets & Blockchain, Banking & Finance, and Regulatory & Compliance
✦ Active across all major licence categories — DASP, DATF, MSP, EMI, investment management, and discontinuance
✦ AI-calibrated AFSA fee matrix — BSL_Fee_Matrix_AI_FINAL_June2026 for licensing cost analysis and planning
✦ Entity formation + AFSA application on one mandate — no coordination across multiple providers
✦ Ranked Legal 500 EMEA and IFLR1000 — offices in Almaty and Astana, with direct access to AFSA and the AIFC Registrar
Primary authority: afsa.aifc.kz · aifc.kz
Bond Stone Kazakhstan offices: Almaty · Astana
Discuss your AFSA licence
Contact Bond Stone for a confidential discussion about AFSA licensing strategy, application preparation, and compliance requirements across all regulated activity categories.
📧 info@bondstonelaw.com
📞 +7 (701) 729 76 72
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