AML/CTF Framework Development

All AFSA-licensed firms must implement AML/CTF policies and procedures compliant with AFSA AML/CTF Rules and FATF Recommendations. Bond Stone prepares or reviews AML/CTF policy frameworks, customer due diligence (CDD/EDD) procedures, suspicious activity reporting protocols, and MLRO appointment documentation. Required for all AFSA licence applications and updated annually.

AFSA Supervisory Engagement

Responding to AFSA information requests, preparing responses to AFSA supervisory reviews, representing clients in AFSA meetings, managing annual return filings, and handling AFSA enforcement correspondence. Bond Stone acts as the primary AFSA liaison for several licensed firms — including management of the AFSA check-in protocol and ongoing communication with AFSA case officers.

AFSA Discontinuance Management

Voluntary surrender of an AFSA licence — wind-down plan preparation, client notification obligations, AFSA application submission, regulatory exit documentation, and post-discontinuance confirmation. Bond Stone has managed AFSA discontinuance mandates for international digital asset exchanges.

AFSA Approved Individual Registration

Applications for registration of key personnel as AFSA Approved Individuals — CEO, MLRO, Compliance Officer, Finance Officer. Fit-and-proper assessment documentation, reference checks, and AFSA submission. Changes of MLRO and Audit Principal now subject to dedicated application fees under the December 2025 AFSA Fees Rules amendments.

FinTech Lab Migration to Full Regime

FinTech Lab participants operating under a 2-year FinTech Lab licence must complete migration to the full AFSA supervisory regime by end of 2026 under current AFSA rules. Bond Stone advises on migration timelines, full licence application preparation, and AFSA engagement during the transition period.

Initial annual supervision fee payable to AFSA — covers the Risk Mitigation Programme (RMP) period

Annual confirmation statement filed with AIFC Registrar of Companies. Annual accounts filed. Annual supervision fee paid to AFSA. AML/CTF policy review and update. MLRO annual report.

Material changes to business model, key personnel, ownership, or activities notified to AFSA. Change of control application (if applicable). New Approved Individual registration for replacement key personnel.

Late fee of 1% per month on unpaid supervisory fees. Non-payment of annual return or accounts within 3 business days of deadline incurs a late filing fee. Late fee unpaid within 30 days incurs a further 10% per calendar day surcharge.