Kazakhstan AML/CFT Law — scope and obligations

Kazakhstan’s primary AML/CFT legislation — the Law on Countering the Legalisation of Illegally Obtained Money and Financing of Terrorism — imposes compliance obligations on a broad range of entities including banks, non-bank financial institutions, payment organisations, real estate agents, accountants, lawyers, and dealers in high-value goods. Obligated entities must conduct customer due diligence (CDD), maintain records, report suspicious transactions to the Financial Monitoring Committee, and implement internal control programmes.

Financial Monitoring Committee — regulatory authority

The Financial Monitoring Committee (FMC) under the Ministry of Finance of Kazakhstan is the primary AML/CFT regulatory and supervisory authority. The FMC receives suspicious transaction reports (STRs), maintains the national AML/CFT database, conducts compliance inspections, and enforces AML/CFT obligations. Bond Stone advises on regulatory engagement with the FMC, compliance with inspection requirements, and response to FMC 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 25% or more of the entity; 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. The beneficial ownership threshold is generally set at 25% direct or indirect ownership or control. 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 directly affects Kazakhstan’s international banking relationships. Bond Stone advises on FATF-aligned compliance frameworks for entities seeking to maintain or expand international correspondent banking relationships.

AML Programme — Payment Organisation

AML/CFT · Kazakhstan · Fintech

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.

KYC Framework — Foreign Bank

AML/CFT · Kazakhstan · Banking

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.

UBO Identification — Complex Structure

AML/CFT · Kazakhstan · Corporate

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.