{"id":4400,"date":"2026-06-08T01:56:25","date_gmt":"2026-06-07T20:56:25","guid":{"rendered":"https:\/\/bondstonelaw.com\/?post_type=industries&p=4400"},"modified":"2026-08-28T21:53:05","modified_gmt":"2026-08-28T16:53:05","slug":"fintech-and-digital-assets-in-kazakhstan","status":"publish","type":"industries","link":"https:\/\/bondstonelaw.com\/ru\/industries\/fintech-and-digital-assets-in-kazakhstan\/","title":{"rendered":"FinTech & Digital Assets"},"content":{"rendered":"

INDUSTRY \u00a0\u00b7\u00a0 FINTECH & DIGITAL ASSETS<\/strong><\/p>\n

FinTech and Digital Assets in Kazakhstan & Central Asia<\/h1>\n

Central Asia has emerged as a significant frontier for financial technology and digital asset regulation, anchored by the Astana International Financial Centre (AIFC) \u2014 one of the world’s most purposefully designed fintech and digital asset regulatory frameworks outside Singapore and Abu Dhabi. The AIFC’s common law ecosystem, English-language courts, and AFSA licensing regime have attracted crypto exchanges, payment platforms, digital securities issuers, and Web3 infrastructure companies from across Europe, the Gulf, Asia, and North America.<\/p>\n

Bond Stone advises fintech companies, digital asset businesses, payment service providers, and investors navigating the regulatory requirements of the AIFC, Kazakhstan’s national fintech regime, and the increasingly active digital finance markets of Uzbekistan and Kyrgyzstan. Bond Stone holds AIFC Legal Adviser status, enabling our attorneys to appear before the AIFC Court and advise on AFSA licensing matters for the full spectrum of regulated digital asset activities.<\/p>\n

The FinTech and digital assets regulatory landscape across the region is fast-moving. Licensing thresholds, AML\/CFT requirements, token classification frameworks, and cross-border payment licensing have all undergone significant reform since 2021. Experienced in-jurisdiction counsel is essential for any operator seeking market access or regulatory approval.<\/p>\n

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Central Asia FinTech & Digital Assets \u2014 Key Segments<\/h2>\n

<\/p>\n

\n
\n
AIFC<\/div>\n
Common law financial centre with dedicated digital asset framework (AFSA)<\/div>\n<\/div>\n
\n
10+<\/div>\n
AFSA digital asset licence categories for exchanges, custodians, and advisers<\/div>\n<\/div>\n
\n
2025<\/div>\n
Kazakhstan launched national digital tenge (CBDC) pilot with NBK<\/div>\n<\/div>\n
\n
USD 4B+<\/div>\n
Estimated annual fintech transaction volume in Kazakhstan (2024)<\/div>\n<\/div>\n<\/div>\n

<\/p>\n

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AFSA Digital Asset Licensing<\/h3>\n

The Astana Financial Services Authority (AFSA) operates one of the most comprehensive digital asset regulatory frameworks in the region. AFSA issues licences for Digital Asset Trading Facilities (exchanges), Digital Asset Custodians, Digital Asset Advisers, Digital Asset Managers, and operators of Digital Asset Lending Platforms. The AIFC Digital Assets Framework (2023), the AIFC Digital Asset Issuance Rules, and the AFSA AML\/CFT Guidance for Virtual Asset Service Providers set the core compliance obligations.<\/p>\n

Bond Stone assists applicants through the full AFSA licensing cycle \u2014 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 AIFC Legal Adviser registration enables our lawyers to file directly with AFSA and appear before the AIFC Court on licence disputes and enforcement matters.<\/p>\n<\/div>\n

<\/p>\n

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Payment Services & E-Money<\/h3>\n

Kazakhstan’s Law on Payments and Payment Systems (Law No. 11-VII, 2021) 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) is the primary regulator for national payment licences. Cross-border payment flows between Kazakhstan, Uzbekistan, and Kyrgyzstan are subject to currency control rules and bilateral settlement frameworks. AIFC-licensed payment platforms benefit from regulatory passporting within the AIFC perimeter but require separate national licences for retail operations targeting Kazakhstan residents.<\/p>\n

Bond Stone advises payment companies on national payment licences, cross-border remittance structures, currency control compliance, and NBK regulatory engagement. In Uzbekistan, we assist clients with payment operator registration under the Central Bank of Uzbekistan’s fintech licensing framework.<\/p>\n<\/div>\n

<\/p>\n

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Blockchain Infrastructure & Web3<\/h3>\n

Kazakhstan has emerged as a significant destination for blockchain infrastructure companies and Web3 projects, in part due to competitive energy pricing and a government-backed technology development agenda linked to the Digital Kazakhstan programme. The AIFC’s smart contract recognition framework and its flexibility on token classification have attracted decentralised finance (DeFi) projects, NFT platforms, and tokenisation ventures seeking a regulated Central Asian base. The Law on Digital Assets in the Republic of Kazakhstan (2023) established national-level recognition of digital assets, digital tokens, and blockchain-based transaction records.<\/p>\n

Bond Stone advises on token structuring and classification analysis, AIFC smart contract governance frameworks, DAO structuring, and technology agreements for blockchain infrastructure deployments in Kazakhstan and across the region.<\/p>\n<\/div>\n

<\/p>\n

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Digital Lending & Neobanks<\/h3>\n

The rapid growth of digital lending platforms, buy-now-pay-later operators, and neobank ventures in Kazakhstan and Uzbekistan has outpaced the formal regulatory framework in several areas. 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. Uzbekistan’s Central Bank has introduced an accelerated licensing pathway for fintech companies under its 2024 Digital Finance Strategy. 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).<\/p>\n<\/div>\n

<\/p>\n

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Cryptocurrency Mining<\/h3>\n

Kazakhstan became the world’s second-largest Bitcoin mining hub following China’s 2021 mining ban, drawing large-scale mining operations due to low electricity costs and geographic access to stranded energy sources. The government subsequently introduced a digital mining tax (Law No. 53-VII, 2022) and licensing requirements for mining operators through the Ministry of Energy. Electricity allocation, grid connection agreements with KEGOC (the national grid operator), and import duties on mining hardware require specialist structuring. Bond Stone advises mining operators on legal entity structuring, energy supply contracts, equipment importation, and tax optimisation within Kazakhstan’s mining regulatory framework.<\/p>\n<\/div>\n

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Bond Stone FinTech & Digital Assets Services<\/h2>\n

<\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n
Service<\/th>\nJurisdictions<\/th>\n<\/tr>\n<\/thead>\n
AFSA digital asset licence applications<\/td>\nAIFC<\/td>\n<\/tr>\n
AML\/CFT policy design for VASPs<\/td>\nAIFC, Kazakhstan, Uzbekistan<\/td>\n<\/tr>\n
Payment services licensing & NBK regulatory engagement<\/td>\nKazakhstan, Uzbekistan<\/td>\n<\/tr>\n
Token classification & structuring analysis<\/td>\nAIFC<\/td>\n<\/tr>\n
AIFC holding company structuring for fintech groups<\/td>\nAIFC<\/td>\n<\/tr>\n
Cryptocurrency mining licensing & energy agreements<\/td>\nKazakhstan<\/td>\n<\/tr>\n
Data localisation & personal data compliance<\/td>\nKazakhstan, Uzbekistan<\/td>\n<\/tr>\n
AIFC Court proceedings & fintech dispute resolution<\/td>\nAIFC Court<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n
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Key Regulatory Framework<\/h2>\n\n\n\n\n\n\n\n
Jurisdiction<\/th>\nPrimary Framework<\/th>\nKey Regulator<\/th>\n<\/tr>\n<\/thead>\n
AIFC<\/td>\nAIFC Digital Assets Framework (2023); AFSA Digital Asset Rules<\/td>\nAstana Financial Services Authority (AFSA)<\/td>\n<\/tr>\n
Kazakhstan<\/td>\nLaw on Digital Assets (2023); Law on Payments (2021); Digital Mining Tax Law (2022)<\/td>\nNBK; ARDFM; Ministry of Digital Development<\/td>\n<\/tr>\n
Uzbekistan<\/td>\nPresidential Decree on Crypto Assets (2018, as amended); CBU Digital Finance Strategy (2024)<\/td>\nCentral Bank of Uzbekistan (CBU); MIFT<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n
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Representative Experience<\/h2>\n

Bond Stone’s FinTech and digital assets experience includes the following representative matters. Client confidentiality is maintained; sector, transaction type, and jurisdiction are disclosed where permitted.<\/p>\n

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AFSA Digital Asset Exchange \u2014 Licensing Application, AIFC<\/strong>
\nAdvised 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 AFSA’s Digital Asset Rulebook.<\/p>\n<\/div>\n

\n

FinTech Holding Structure \u2014 AIFC Incorporation, Chinese Group<\/strong>
\nAdvised 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.<\/p>\n<\/div>\n

\n

Cryptocurrency Mining Operations \u2014 Kazakhstan Tax & Regulatory Advisory<\/strong>
\nAdvised a cryptocurrency mining operator establishing a mining facility in the East Kazakhstan region on the application of Kazakhstan’s digital mining tax framework (2022 Law on Digital Assets amendments), electricity tariff classification for mining operations, equipment importation procedures, and MDDKZ registration requirements.<\/p>\n<\/div>\n

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Payment Organisation Licensing \u2014 Kazakhstan NBK, E-Money Operator<\/strong>
\nAdvised an international e-money operator on its licence 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.<\/p>\n<\/div>\n

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Digital Asset Custody \u2014 AFSA Licensing Strategy, AIFC<\/strong>
\nAdvised a regulated custodian seeking to extend its digital asset custody services to AIFC-domiciled clients, covering AFSA Digital Asset Custodian licence requirements, segregation obligations, internal control frameworks, and client onboarding documentation adapted for the AIFC common law environment.<\/p>\n<\/div>\n

<\/p>\n

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Why Bond Stone for FinTech & Digital Assets<\/h2>\n

\u2014<\/strong>Bond Stone holds AIFC Legal Adviser status \u2014 our attorneys are authorised for direct AFSA engagement and AIFC Court proceedings on digital asset matters<\/p>\n

\u2014<\/strong>Deep understanding of the AFSA licensing process across all digital asset activity categories \u2014 exchanges, custodians, advisers, and lenders<\/p>\n

\u2014<\/strong>Experience structuring AIFC holding vehicles for international fintech groups seeking a regulated Central Asian base<\/p>\n

\u2014<\/strong>Track record advising cryptocurrency mining operators on energy agreements, equipment importation, and Kazakhstan’s digital mining tax framework<\/p>\n

\u2014<\/strong>Cross-jurisdictional capability across AIFC, Kazakhstan, and Uzbekistan \u2014 covering both the regulated and emerging fintech markets of the region<\/p>\n

\u2014<\/strong>Fluency in common law digital asset concepts (token classification, smart contracts, DAOs) as well as the civil law national frameworks applicable in Kazakhstan and Uzbekistan<\/p>\n

\u2014<\/strong>Ranked by Legal 500 EMEA and IFLR1000 \u2014 recognised practice for financial services and technology-sector mandates<\/p>\n<\/div>\n

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<\/p>\n

Related Practice Areas<\/h2>\n

FinTech and digital asset mandates in Central Asia typically engage multiple legal disciplines. Bond Stone’s integrated practice covers each of these areas with the same in-country depth.<\/p>\n\n\n\n
\n
AIFC for Global Investors<\/div>\n
AIFC incorporation, AFSA licensing, AIFC Court access, and common law holding structures for international groups.<\/div>\n

VIEW PRACTICE \u2192<\/a><\/td>\n

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Regulatory & Licensing<\/div>\n
Licensing strategy and regulatory submissions for fintech, payment services, and digital asset operators in Kazakhstan.<\/div>\n

VIEW PRACTICE \u2192<\/a><\/td>\n

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Corporate & Commercial Law<\/div>\n
Entity structuring, shareholder agreements, and commercial contracts for fintech companies entering Central Asian markets.<\/div>\n

VIEW PRACTICE \u2192<\/a><\/td>\n

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Data Protection<\/div>\n
Personal data compliance, cross-border data transfer frameworks, and privacy governance for financial services platforms.<\/div>\n

VIEW PRACTICE \u2192<\/a><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n

<\/p>\n

FinTech & Digital Assets \u2014 Key Legal Topics<\/h2>\n

In-depth guidance on the regulatory and commercial issues most frequently encountered by fintech companies and digital asset operators entering Central Asian markets.<\/p>\n\n\n\n
\n
Licensing<\/div>\n
AFSA Digital Asset Licensing<\/div>\n
AFSA licence categories, application process, capital requirements, and ongoing compliance obligations for digital asset exchanges and custodians in the AIFC.<\/div>\n

READ MORE \u2192<\/a><\/td>\n

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Regulation<\/div>\n
Kazakhstan Digital Asset Regulatory Framework<\/div>\n
Law on Digital Assets 2023, cryptocurrency mining tax obligations, NBK payment regulation, and digital finance strategy under Kazakhstan’s Fintech Hub programme.<\/div>\n

READ MORE \u2192<\/a><\/td>\n

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Compliance<\/div>\n
Payment Services & AML\/CFT Compliance<\/div>\n
Payment organisation licensing under Kazakhstan’s Law on Payments, AML\/CFT programme design, FATF travel rule compliance, and CBU payment licensing in Uzbekistan.<\/div>\n

READ MORE \u2192<\/a><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n

<\/p>\n

FinTech & Digital Assets Law \u2014 Frequently Asked Questions<\/h2>\n

Answers to the questions Bond Stone most frequently receives from fintech companies and digital asset operators entering the Central Asian and AIFC markets.<\/p>\n

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What AFSA licences are required to operate a digital asset exchange in the AIFC?<\/h3>\n

To operate a digital asset trading facility (exchange) in the AIFC, a company must hold a Digital Asset Trading Facility (DATF) licence issued by AFSA under the AIFC Digital Assets Framework (2023). 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 issues separate licences for Digital Asset Custodians, Advisers, Managers, and Lending Platform operators. Bond Stone assists applicants through the full AFSA licensing cycle, including pre-application regulatory strategy and post-licence compliance.<\/p>\n<\/div>\n

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How does token classification work under the AIFC Digital Assets Framework?<\/h3>\n

Under the AIFC Digital Assets Framework (2023), tokens are classified based on their economic function: Digital Assets (utility tokens and cryptocurrencies), Digital Securities (equity\/debt tokens regulated as securities under AFSA Investment Services Rules), and Digital Payment Tokens (stablecoins and payment instruments). The classification determines which AFSA licence is required and what regulatory obligations apply. Bond Stone advises on token classification analysis, structuring issuances to achieve the desired regulatory outcome, and preparing regulatory submissions to AFSA on classification matters.<\/p>\n<\/div>\n

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What is the difference between an AIFC licence and a Kazakhstan national fintech licence?<\/h3>\n

An AIFC licence issued by AFSA authorises operation within the AIFC perimeter \u2014 a special jurisdiction applying common law and AFSA rules. 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, a separate national licence from the National Bank of Kazakhstan (NBK) or ARDFM is required under Kazakhstan’s Law on Payments and Payment Systems (2021). Bond Stone advises on dual-track licensing strategies combining AIFC and national licences for optimal market coverage.<\/p>\n<\/div>\n

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What AML\/CFT obligations apply to digital asset businesses in Kazakhstan and the AIFC?<\/h3>\n

AIFC digital asset businesses are subject to AFSA’s AML\/CFT Guidance for Virtual Asset Service Providers, implementing FATF Recommendation 15, including the Travel Rule for transfers above USD 1,000. 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 Combatting Money Laundering (Law No. 191-IV, 2009 as amended), overseen by the Financial Monitoring Agency of Kazakhstan. Bond Stone designs AML\/CFT programmes for VASPs covering both AFSA and national Kazakhstani requirements.<\/p>\n<\/div>\n

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How is cryptocurrency mining regulated in Kazakhstan?<\/h3>\n

Cryptocurrency mining in Kazakhstan is regulated under the Law on Digital Assets (2023) and the digital mining tax amendments (Law No. 53-VII, 2022). Mining operators must register with the Ministry of Digital Development (MDDKZ) and pay a digital mining tax per kilowatt-hour of electricity consumed. Electricity supply requires Ministry of Energy authorisation and grid connection agreements with KEGOC. Equipment importation benefits from reduced import duty rates for qualifying mining hardware. Bond Stone advises mining operators on entity structuring, regulatory registration, energy supply agreements, and tax optimisation within Kazakhstan’s mining framework.<\/p>\n<\/div>\n

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<\/p>\n

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Entering the Central Asian FinTech or Digital Asset Market?<\/h3>\n

Bond Stone advises on AFSA licensing, AIFC structuring, payment licensing, AML\/CFT compliance, and digital asset dispute resolution across Kazakhstan, the AIFC, and Uzbekistan. AIFC Legal Adviser status enables direct AFSA engagement and AIFC Court proceedings.<\/p>\n\n\n\n
Contact Bond Stone \u2192<\/span><\/a><\/td>\nAIFC Licensing \u2192<\/span><\/a><\/td>\nFinTech in Kazakhstan \u2192<\/span><\/a><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/div>\n

<\/p>\n

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AFSA licensing, AIFC structuring, and digital asset regulatory compliance for fintech companies entering Kazakhstan’s financial centre.<\/p>\n","protected":false},"featured_media":0,"menu_order":1,"template":"","class_list":["post-4400","industries","type-industries","status-publish","hentry"],"translation":{"provider":"WPGlobus","version":"3.0.5","language":"ru","enabled_languages":["en","ru"],"languages":{"en":{"title":true,"content":true,"excerpt":true},"ru":{"title":false,"content":false,"excerpt":false}}},"_links":{"self":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/industries\/4400","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/industries"}],"about":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/types\/industries"}],"wp:attachment":[{"href":"https:\/\/bondstonelaw.com\/ru\/wp-json\/wp\/v2\/media?parent=4400"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}