AIFC · DIGITAL ASSETS
AFSA Licensing — Digital Assets & Crypto
Bond Stone advises digital asset service providers, cryptocurrency exchanges, stablecoin issuers, and tokenisation platforms on AFSA licensing within the AIFC — from initial strategy and entity formation through application preparation, AFSA liaison, and post-licence compliance.
The AIFC has one of the most developed digital asset regulatory frameworks in the CIS region. In 2025, the AIFC was recognised by IOSCO as one of the leading jurisdictions implementing global standards for crypto and digital asset markets. AFSA supervised 9 Digital Asset Service Providers under the full regulatory framework, with DASPs generating a total transaction volume of USD 10.58 billion and approximately 215,000 users.
Governed by: AIFC Rules on Digital Asset Activities (as amended 13 April 2025, commencing 13 October 2025); AFSA Fees Rules (as amended 1 December 2025); AIFC Financial Services Framework Regulations. Authority: afsa.aifc.kz
Digital Asset Licence Categories
DASP — Digital Asset Service Provider
Covers dealing in, managing, providing custody of, exchanging, or transferring digital assets. Applies to crypto brokers, custodians, wallet service providers, and OTC desks. Additional AFSA application fee: USD 2,800. Min. capital: USD 10,000–200,000 depending on activity.
Additional fee: USD 2,800
DATF — Digital Asset Trading Facility
Market Activity licence for operating a centralised exchange where multiple parties buy, sell, or exchange digital assets for fiat or other digital assets. The most capital-intensive digital asset licence. Variable supervision fee capped at USD 250,000 (effective 1 December 2025).
Min. capital: USD 200,000 or 12-month working capital
Stablecoin Issuer
Dedicated AFSA framework for issuers of stablecoins — digital assets whose value is pegged to a currency, commodity, or financial instrument. Reserve and disclosure requirements apply. Framework effective 1 January 2024.
Framework: effective 1 January 2024
STO — Security Token Offering
Framework for issuance of security tokens — digital representations of shares, bonds, or fund units. Subject to AIFC prospectus and disclosure rules. Bond Stone advises on STO structuring and AFSA filing strategy.
Framework: effective 1 January 2024
FinTech Lab — Regulatory Sandbox
Pre-licence testing environment. FinTech Lab licence issued for up to 2 years. Participants must complete migration to the full AFSA supervisory regime by end of 2026. AML/CTF obligations apply from day one regardless of sandbox status.
Migration deadline: end of 2026
AFSA Discontinuance
Voluntary surrender of an AFSA digital asset licence. Requires formal AFSA application, wind-down plan, client notification, and regulatory exit documentation. Bond Stone has managed AFSA discontinuance mandates for international digital asset exchanges.
Active discontinuance experience
Application Process
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Licence category selection & entity formation Bond Stone advises on the appropriate AFSA digital asset licence category based on the client’s business model — DASP, DATF, Stablecoin, or STO. An AIFC-registered entity (Company or LLP) must be incorporated before AFSA will accept a licence application. Bond Stone manages entity formation in parallel with application preparation. |
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Application package preparation Bond Stone prepares the full AFSA application — business plan, financial projections, technology and security framework description, AML/CTF policies and procedures, Approved Individual applications for key personnel (CEO/SEO, Compliance Officer, MLRO, Deputy MLRO, Finance Officer), and all constitutional documents. The additional digital asset fee of USD 2,800 applies to all DASP/DATF applications. |
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Fee payment & submission AFSA does not regard an application as submitted until the fee is paid in full — all AFSA application fees are non-refundable regardless of outcome. Bond Stone submits the fee request form to AFSA, receives the invoice, and coordinates payment before formal submission. Registration fee: USD 500 (portal) or USD 1,500 (paper). |
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AFSA review, RMP & post-licence compliance Bond Stone manages AFSA liaison throughout the review period and responds to information requests. Post-licence: Risk Mitigation Programme (RMP) period before operations commence. Initial annual supervision fee payable within 21 days of licence grant. Variable supervision fee applies — capped at USD 250,000 effective 1 December 2025. |
Why Bond Stone
✦ AIFC RLA — Digital Assets & Blockchain specialisation
✦ Active AFSA digital asset practice — DASP, DATF, and discontinuance mandates
✦ Full application package — entity formation, AML/CTF framework, Approved Individual registrations, AFSA liaison on one mandate
✦ Ranked Legal 500 EMEA and IFLR1000 — offices in Almaty and Astana
Primary authority: afsa.aifc.kz · aifc.kz
Discuss your AFSA digital asset licence
Contact Bond Stone for a confidential discussion about AFSA digital asset licensing strategy, application preparation, and compliance requirements.
📧 info@bondstonelaw.com
📞 +7 (701) 729 76 72
Request a Confidential Consultation
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