FinTech, Digital Assets & AIFC Licensing
PRACTICE AREA · FINTECH & DIGITAL ASSETS
Kazakhstan FinTech, Digital Assets & AIFC Licensing
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 attorneys hold AIFC Registered Legal Adviser status (RLA) — enabling Bond Stone to advise on AFSA-regulated matters and appear before the AIFC Court.
Kazakhstan has positioned the Astana International Financial Centre (AIFC) as Central Asia’s primary fintech and digital assets jurisdiction. The AIFC operates under a legal framework based on English common law — with zero corporate income tax and zero capital gains tax on qualifying AIFC participants during the exemption period to 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. For fintech companies entering Kazakhstan or Central Asia, structuring through the AIFC combines regulatory certainty, tax efficiency, English-language dispute resolution at the AIFC Court, and access to the broader Kazakhstan market.
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 persons, 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 USD 250,000 minimum capital requirement, 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 persons 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 that gives fintech investors tax efficiency alongside market access. 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 0% corporate income tax and capital gains tax exemption regime for qualifying AIFC participants through 2066, withholding tax treaty analysis on Kazakhstan-to-AIFC dividend flows under applicable double taxation conventions, intercompany loan structuring, and AIFC entity formation to optimise the treatment of fintech revenues and investor returns.
AFSA Regulatory Compliance & Ongoing Advisory
Ongoing regulatory compliance advisory for AFSA-licensed entities — periodic compliance reviews, approved persons 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. Sanat Ablakov’s AIFC RLA status (No. 250) confers the right of audience before the AIFC Court. 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, right of audience via AIFC RLA No. 250 — Read more →
Tax Advisory — Kazakhstan & AIFC
AIFC 0% CIT regime, 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 Exchange | USD 1,000,000 | AML/CFT framework, approved persons, technology systems review |
| Payment Services | USD 250,000 | Client categorisation, safeguarding, AML/CFT compliance |
| Investment Management | USD 500,000 | Conduct of business rules, approved persons, compliance officer |
| Banking & Credit | USD 5,000,000+ | Prudential requirements, full AFSA application, approved persons |
| AIFC CIT exemption | 0% until 2066 | Qualifying AIFC participant — CIT and capital gains tax exemption |
| AIFC Court jurisdiction | English common law | English-language proceedings, independent judiciary, no state court involvement |
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 digital asset exchange licensing
AFSA Licensing · AIFC · Digital Assets
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 persons, and regulatory dialogue with AFSA during review. Partner: Sanat Ablakov.
AFSA payment services licensing
AFSA Licensing · AIFC · Payment Services
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 fintech holding company — cross-border structuring
AIFC Entity Formation · FinTech · Tax 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 0% CIT analysis on dividends and capital gains through 2066. Partner: Sanat Ablakov.
AFSA discontinuance proceedings — Peken Ltd (KuCoin affiliate)
AIFC Court · AFSA · Digital Assets
Bond Stone advised Peken Ltd, an affiliate of KuCoin, on AFSA discontinuance advisory in proceedings AIFC-C/CFI/2026/0010 — one of the first AIFC Court fintech enforcement matters in Kazakhstan. Partner: Sanat Ablakov.
AIFC Investment Tax Residency Programme advisory
AIFC · Tax Residency · Individual Investors
Bond Stone advises individuals and fintech founders on the AIFC Investment Tax Residency Programme (ITP) — eligibility assessment, application preparation, and ongoing compliance. The ITP provides 0% personal income tax for qualifying residents. See: Investment Tax Residency Programme →
Why Bond Stone for FinTech & AIFC Licensing
✦ AIFC Registered Legal Adviser No. 250 — one of the few Kazakhstan-based practitioners personally qualified to advise on AFSA-regulated matters and appear as advocate before the AIFC Court
✦ 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, without separate international counsel
✦ AIFC Court experience — including AFSA discontinuance proceedings (AIFC-C/CFI/2026/0010) — one of the first AIFC fintech enforcement matters in Kazakhstan
✦ 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.
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