National Bank of Kazakhstan (NBK) — regulated activities

The NBK is the primary financial services regulator for activities outside the AIFC. NBK-licensed activities include: banking (deposit-taking, lending, payment services); payment organisations and payment system operators; microfinance organisations; insurance and reinsurance; brokerage, dealer, and investment portfolio management activities on the Kazakhstan Stock Exchange (KASE); and currency exchange operations. Each licence category has specific minimum capital, qualified personnel, IT systems, internal control, and AML/CFT requirements.

AFSA licensing — AIFC-regulated financial services

The AIFC Financial Services Authority (AFSA) licenses financial services activities within the AIFC framework — digital assets, payment services, investment management, banking, insurance, Islamic finance, and capital markets. Bond Stone holds AIFC Registered Legal Adviser status and advises on AFSA licensing applications, regulatory business plans, compliance frameworks, and ongoing AFSA supervision requirements. AFSA-licensed entities benefit from AIFC tax exemptions until 2066 and access to the AIFC Court.

Payment organisations — NBK licensing

Payment organisation licences from the NBK are required for companies providing payment services, operating electronic payment systems, or processing payments in Kazakhstan. Since 2022, the NBK has significantly tightened payment organisation licensing requirements — minimum capital of KZT 200 million, mandatory AML/CFT programme, certified IT systems, and qualified personnel requirements. Bond Stone advises on structuring payment operations to meet NBK licensing requirements and manages the full application process.

Banking licence — foreign bank entry

Foreign banks entering Kazakhstan may obtain a full banking licence from the NBK or establish an AIFC-regulated bank branch. Full bank licensing requires minimum capital of KZT 20 billion, qualified management, and comprehensive regulatory documentation. A foreign bank branch within the AIFC is subject to AFSA regulation with different capital and operational requirements. Bond Stone advises on the choice between NBK-licensed and AFSA-licensed banking structures for foreign bank entry into Kazakhstan.

Payment Organisation Licence — NBK

Licensing · Kazakhstan · Fintech

Full-cycle advisory on obtaining a payment organisation licence from the NBK — capital structuring, AML/CFT programme preparation, IT certification documentation, qualified personnel requirements, and regulatory liaison throughout the approval process.

AFSA Digital Assets Licence

Licensing · AIFC · Digital Assets

Advising a digital asset exchange on AFSA licensing — regulatory business plan, AML/CFT framework, custody arrangements, consumer protection policies, and ongoing AFSA compliance framework implementation.

Microfinance Organisation Licence

Licensing · Kazakhstan · Financial Services

Obtaining a microfinance organisation licence from the NBK for a fintech company — minimum capital structuring, organisational requirements, loan portfolio limits, and interest rate cap compliance advisory.