FinTech & Digital Assets in Central Asia

AFSA Digital Asset Licensing

AFSA issues licences for Regulated Activities in relation to Digital Assets, including Operating a Digital Asset Trading Facility (exchanges), Providing Custody, Advising on Investments, Managing Investments, and Dealing in Investments. The AIFC Rules on Digital Asset Activities (in force since 1 January 2024) and the AIFC Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Rules set the core compliance obligations.

Bond Stone assists applicants through the full AFSA licensing cycle — from regulatory strategy and business plan alignment through to application drafting, compliance framework design, AML/CFT policy documentation, and post-licence regulatory maintenance. Bond Stone's partners hold AIFC Legal Adviser status, file directly with AFSA and appear before the AIFC Court on licence disputes and enforcement matters.

Payment Services & E-Money

Kazakhstan's Law on Payments and Payment Systems (Law No. 11-VI of 26 July 2016) regulates payment service providers, e-money operators, and payment infrastructure operators operating within or through the Republic of Kazakhstan. The National Bank of Kazakhstan (NBK) regulates the payment services market and registers payment organisations; banks are licensed by the Agency for Regulation and Development of the Financial Market (ARDFM). Cross-border payment flows between Kazakhstan, Uzbekistan, and Kyrgyzstan are subject to currency control rules and bilateral settlement frameworks. AFSA-licensed payment platforms are authorised for activity in or from the AIFC but require separate national authorisation for retail operations targeting Kazakhstan residents.

Bond Stone advises payment companies on national payment licences, cross-border remittance structures, currency control compliance, and NBK regulatory engagement. In Uzbekistan, payment organisations and payment system operators need a licence from the Central Bank of Uzbekistan (Law No. ZRU-578 on Payments and Payment Systems, Articles 22 and 24).

Blockchain Infrastructure & Web3

A blockchain or Web3 project must first decide which regime applies. In the AIFC, what a token represents determines the licence, and an Authorised Firm may not carry on an activity related to a Utility Token or Non-Fungible Token, except custody by an authorised Digital Asset Service Provider (DAA 3.12). The Law on Digital Assets in the Republic of Kazakhstan (No. 193-VII of 6 February 2023) established national-level recognition of digital assets, which since 1 May 2026 it divides into digital financial assets and unsecured digital assets.

Bond Stone advises on token structuring and classification, smart contract governance, DAO structuring and technology agreements for blockchain infrastructure deployments in Kazakhstan and across the region.

Digital Lending & Neobanks

Digital lending platforms, buy-now-pay-later operators and neobank ventures are growing in Kazakhstan and Uzbekistan. The Agency for Regulation and Development of the Financial Market of Kazakhstan (ARDFM) exercises supervisory authority over microfinance organisations, credit bureaux, and consumer lending platforms operating in the national market. In Uzbekistan, Presidential Resolution PP-359 of 27 November 2025 makes the Central Bank responsible for developing the fintech sector. Bond Stone monitors regulatory developments across both jurisdictions and advises clients on compliant product structuring, licensing strategy, and data localisation obligations under the Law on Personal Data (Kazakhstan) and the Law on Personal Data (Uzbekistan).

Cryptocurrency Mining

Kazakhstan became a major location for Bitcoin mining after China's 2021 mining ban. The government introduced a digital mining fee per kilowatt-hour of electricity consumed (Law No. 53-VII of 24 June 2021, effective 1 January 2022; now Articles 657 to 661 of the Tax Code), and the Law on Digital Assets requires digital miners to hold a licence from the authorised body, now the Ministry of Artificial Intelligence and Digital Development. Electricity allocation, grid connection agreements with KEGOC (the national grid operator), and import duties on mining hardware all need attention. Bond Stone advises mining operators on entity structuring, energy supply contracts, equipment importation and tax.

AFSA Digital Asset Exchange — Licensing Application, AIFC
Advised an international cryptocurrency exchange group on its AFSA Digital Asset Trading Facility licence application, covering licence category selection, governance framework design, AML/CFT programme development, and technology systems regulatory review under the AIFC Rules on Digital Asset Activities.

FinTech Holding Structure — AIFC Incorporation, Chinese Group
Advised a Chinese-backed fintech group on the establishment of an AIFC-incorporated holding company for its Central Asian payment and digital lending operations, including AIFC entity formation, intercompany agreements, and structuring of the technology licensing arrangements to the Kazakhstan operating subsidiary.

Cryptocurrency Mining Operations — Kazakhstan Tax & Regulatory Advisory
Advised a cryptocurrency mining operator establishing a mining facility in the East Kazakhstan region on the application of Kazakhstan's digital mining tax framework (the digital mining fee under the Tax Code), electricity tariff classification for mining operations, equipment importation procedures, and registration requirements.

Payment Organisation Registration — Kazakhstan NBK, E-Money Operator
Advised an international e-money operator on its registration application under Kazakhstan's Law on Payments and Payment Systems, including capital requirement compliance, payment system registration, AML/CFT programme development, and coordination with the National Bank of Kazakhstan during the review period.

Digital Asset Custody — AFSA Licensing Strategy, AIFC
Advised a regulated custodian seeking to extend its digital asset custody services to AIFC-domiciled clients, covering AFSA custody licence requirements, segregation obligations, internal control frameworks, and client onboarding documentation adapted for the AIFC common law environment.

Why Bond Stone for FinTech & Digital Assets

• Bond Stone's partners hold AIFC Legal Adviser status and handle direct AFSA engagement and AIFC Court proceedings on digital asset matters
• Advice on the AFSA licensing process across all digital asset activity categories — exchanges, custodians, advisers, and managers
• Experience structuring AIFC holding vehicles for international fintech groups seeking a regulated Central Asian base
• Experience advising cryptocurrency mining operators on energy agreements, equipment importation, and Kazakhstan's digital mining tax framework
• Coverage across the AIFC, Kazakhstan, and Uzbekistan, including both the regulated and emerging fintech markets of the region
• Advice on common law digital asset concepts (token classification, smart contracts, DAOs) as well as the civil law national frameworks applicable in Kazakhstan and Uzbekistan
• Ranked by Legal 500 EMEA and IFLR1000 — recognised practice for financial services and technology-sector mandates

What AFSA licences are required to operate a digital asset exchange in the AIFC?

To operate a digital asset trading facility (exchange) in the AIFC, a company must hold a licence for the Regulated Activity of Operating a Digital Asset Trading Facility (DATF), issued by AFSA under the AIFC Rules on Digital Asset Activities (DAA). The application requires a detailed business plan, governance documentation, AML/CFT programme compliant with FATF standards, technology systems review, and capital adequacy evidence. AFSA also licenses Digital Asset Service Providers for activities such as Providing Custody, Advising on Investments, Managing Investments, and Dealing in Investments. Bond Stone assists applicants through the full AFSA licensing cycle, including pre-application regulatory strategy and post-licence compliance.

How does token classification work under the AIFC rules?

Under the AIFC Glossary and the DAA, Digital Assets (including Fiat stablecoins, Commodity stablecoins, and Utility Tokens) are distinct from Investment Tokens, which are digital representations of Investments such as Security Tokens and Derivative Tokens. The classification determines which AFSA licence is required and what regulatory obligations apply. Bond Stone advises on token classification, the structure of issuances and submissions to AFSA on classification.

What is the difference between an AIFC licence and a Kazakhstan national fintech licence?

An AFSA licence authorises activity in or from the AIFC. It does not automatically grant the right to offer services to Kazakhstan retail customers outside the AIFC. For retail payment services, e-money operations, or lending to Kazakhstan residents, separate national authorisation is required: registration with the National Bank of Kazakhstan (NBK) for a payment organisation under the Law on Payments and Payment Systems (No. 11-VI of 26 July 2016), or a licence from ARDFM for a bank or microfinance organisation. Bond Stone advises on combining AIFC and national authorisations.

What AML/CFT obligations apply to digital asset businesses in Kazakhstan and the AIFC?

AIFC digital asset businesses are subject to the AIFC Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Rules, implementing FATF Recommendation 15, including the Travel Rule for Digital Asset transfers, with full originator and beneficiary information required at USD 1,000 or more. AFSA-licensed entities must implement risk-based KYC/CDD procedures, transaction monitoring systems, and suspicious transaction reporting. In Kazakhstan, national digital asset operators are subject to the Law on Countering the Legalisation (Laundering) of Proceeds of Crime and the Financing of Terrorism (Law No. 191-IV of 28 August 2009), under which reports go to the Financial Monitoring Agency of the Republic of Kazakhstan. Bond Stone designs AML/CFT programmes for VASPs covering both AFSA and national Kazakhstani requirements.

How is cryptocurrency mining regulated in Kazakhstan?

Cryptocurrency mining in Kazakhstan is regulated under the Law on Digital Assets (No. 193-VII of 6 February 2023) and the Tax Code (No. 214-VIII of 18 July 2025), which keeps the digital mining fee first introduced by Law No. 53-VII of 24 June 2021. Digital miners must hold a three-year digital mining licence from the authorised body, now the Ministry of Artificial Intelligence and Digital Development, operate through an accredited digital mining pool, and pay the fee per kilowatt-hour of electricity consumed. The state body responsible for electric power sets the requirements for connecting digital miners to electrical networks and the electricity quota mechanism, and grid connection agreements are made with KEGOC. Bond Stone advises mining operators on entity structuring, licensing, energy supply agreements and tax.

Entering the Central Asian FinTech or Digital Asset Market?

Bond Stone advises on AFSA licensing, AIFC structuring, payment licensing, AML/CFT compliance, and digital asset dispute resolution across Kazakhstan, the AIFC, and Uzbekistan. Bond Stone's partners hold AIFC Legal Adviser status and handle direct AFSA engagement and AIFC Court proceedings.