AIFC · PAYMENT SERVICES
AFSA Licensing — Payment Services
Bond Stone advises payment services providers on AFSA licensing within the AIFC — Money Services Provider (MSP), Electronic Money Institution (EMI), and combined dual-licence mandates. We manage the full application process from AIFC entity formation through AFSA authorisation and post-licence compliance.
The AIFC payment services regulatory framework provides an internationally recognised licensing environment for payment companies seeking to operate in Kazakhstan and access Central Asian payment infrastructure under English common law. AIFC-licensed payment organisations benefit from the zero CIT exemption until 2066 and AIFC Court dispute resolution.
Governed by: AIFC Financial Services Framework Regulations; AFSA Conduct of Business Rules; AFSA AML/CTF Rules; AFSA Fees Rules (as amended 1 December 2025). Authority: afsa.aifc.kz
Payment Services Licence Types
| Licence | Covers | 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 under AFSA safeguarding rules. | Per AFSA safeguarding requirements |
| Dual MSP + EMI | Combined money transmission and e-money issuance. Where a payment company conducts both activities, a dual application is filed. The second activity is charged at 50% of the standard single-activity fee. | Higher of the two individual requirements |
Application Process
|
1
|
Licensing strategy Bond Stone advises on whether AFSA (AIFC) licensing is the appropriate route based on the client’s business model, client base, and operational footprint. AFSA is preferred for international payment companies requiring English common law governance and AIFC Court access. |
|
2
|
AIFC entity formation AFSA licences may only be held by AIFC-registered entities. Bond Stone registers the Company or LLP with the AIFC Registrar of Companies in parallel with preparing the AFSA application. Remote incorporation — no physical presence in Kazakhstan required. |
|
3
|
Application package preparation Bond Stone prepares the full AFSA application — business plan, financial projections, governance framework, AML/CTF policies, safeguarding arrangements (EMI), Approved Individual applications for key personnel (CEO/SEO, Compliance Officer, MLRO, Finance Officer). Fee invoice requested from AFSA before submission — all fees non-refundable. |
|
4
|
AFSA review & post-licence compliance Bond Stone manages AFSA liaison throughout the review period, responds to information requests, and attends AFSA meetings. Post-licence: Risk Mitigation Programme (RMP) period, annual supervision fee payable within 21 days of licence grant, AML/CTF reporting, and ongoing regulatory compliance management. |
Why Bond Stone
✦ Active dual MSP + EMI mandate experience within the AIFC
✦ AIFC RLA — Banking & Finance specialisation
✦ Full application package — entity formation, AML/CTF framework, Approved Individual registrations on one mandate
✦ Ranked Legal 500 EMEA and IFLR1000 — offices in Almaty and Astana
Primary authority: afsa.aifc.kz
Discuss your payment services licence
Contact Bond Stone for a confidential discussion about MSP or EMI licensing within the AIFC.
📧 info@bondstonelaw.com
📞 +7 (701) 729 76 72
Request a Confidential Consultation
← AFSA Licensing Hub
Investment Management →