AIFC Digital Assets Licence Kazakhstan

The AIFC digital assets licence Kazakhstan pathway has become one of the most credible routes for exchange operators, custodians and digital-asset service providers seeking a regulated home in Central Asia. The Astana International Financial Centre (AIFC) operates under a distinct legal regime modelled on English common-law principles, and its sole regulator the Astana Financial Services Authority (AFSA) is the body that grants Digital Asset authorisations. Since the AIFC Rules on Digital Asset Activities (DAA) V3 came into effect on 1 January 2025, the framework has moved from rule publication to active operational onboarding, generating strong demand for practical, application-focused guidance.

Introduction What the AIFC Digital Assets Licence Covers

Quick Summary

An AIFC Digital Assets Licence authorises a firm to conduct one or more regulated digital-asset activities within the AIFC principally operating a Digital Asset Trading Facility (DATF), providing custody of digital assets, or dealing in and advising on digital assets. The licence is issued exclusively by AFSA, the independent regulator of the AIFC. Any entity wishing to operate an exchange, run a custody service or provide investment-type services involving digital assets from the AIFC must hold the appropriate AFSA authorisation before commencing business.

Key Benefits of Licensing in the AIFC

• Dedicated legal regime: The AIFC operates under the Constitutional Statute on the Astana International Financial Centre, which establishes a special jurisdiction with its own courts, arbitration centre and regulatory framework, separate from Kazakhstan’s general civil and commercial law.
• English common-law foundation: The AIFC Financial Services Framework Regulations (FSFR) and the DAA draw on internationally recognised regulatory models, giving participants legal certainty and familiarity for cross-border structuring.
• Tax and regulatory incentives: AIFC participants benefit from published incentive packages including corporate income tax, individual income tax and property tax exemptions designed to attract financial-services and technology firms.
• Proven market access: Major global exchanges have secured in-principle approvals and full authorisations through the AIFC route, as confirmed in AFSA’s record-growth announcement for 2024, which signals growing market confidence and operational viability for new entrants.

Process How to Obtain an AIFC Digital Assets Licence

This is the pragmatic path most applicants follow. Each step includes required documents, typical pitfalls and what AFSA expects.

Step 1 Eligibility and Strategic Decision

Begin by identifying which regulated activity or activities your business requires. The AIFC Rules on Digital Asset Activities define the principal categories: Operating a Digital Asset Trading Facility, Providing Custody, and Dealing or Advising on digital assets. Many applicants bundle DATF and custody permissions in a single application. At this stage, confirm whether the AIFC route as opposed to a non-AIFC Kazakhstan VASP registration aligns with your target markets, client base and corporate structure. Early regulatory scoping reduces the risk of mid-process pivots.

Step 2 Corporate Structure and AIFC Presence

Applicants must establish a legal presence in the AIFC either by incorporating a new AIFC company or registering a branch of an existing entity. The FSFR sets out governance and substantial-presence obligations, including appointing approved individuals to controlled functions and maintaining a registered office within the AIFC. AIFC company formation should be initiated early, as corporate registration is a prerequisite for submitting the licence application itself.

Step 3 Documentation Pack

AFSA publishes a detailed application package list for each regulated activity. For a DATF application, the documentation typically includes a comprehensive business plan, three-year financial projections, an AML/CFT policy, compliance manual, Money Laundering Reporting Officer (MLRO) nomination, technology architecture documentation, custodial and legal agreements, and the applicant’s proposed business rules. AFSA provides downloadable templates and application forms on its regulated-activities page. Incomplete documentation packs are the single most common cause of delay.

Step 4 Technology and Security

The DAA imposes specific obligations around custody design, cybersecurity and technology governance. Applicants must demonstrate secure wallet architecture including hot/cold segregation, multi-signature controls or engagement of a qualified third-party custodian and must commission a mandatory third-party technology audit before AFSA will grant final authorisation. Penetration testing, business-continuity planning and alignment with recognised standards such as ISO 27001 or SOC 2 are expected. Industry observers note that technology readiness or the lack of it is frequently a gating factor for AFSA approvals.

Step 5 Compliance Programme and Control Testing

AFSA expects a fully operational compliance programme at the point of application, not merely a policy document. This includes transaction-monitoring systems, sanctions-screening tools, travel-rule implementation, and an independent AML audit. Fit-and-proper assessments for approved individuals are conducted by AFSA against published criteria. The AFSA Guidance for AIFC Banks also sets out KYC and AML expectations that will indirectly shape the controls AFSA expects of licensed DATFs and DASPs.

Step 6 AFSA Submission, Fees and Authorisation

Once the documentation pack is complete, the applicant submits to AFSA and requests an invoice for the application fee. For a DATF, the application fee is USD 70,000. AFSA reviews the submission and may issue requests for further information (RFIs), conduct interviews with designated persons, or require additional evidence. Upon satisfactory review, AFSA issues an in-principle approval followed by full authorisation, which may include post-licence conditions such as supervisory reporting obligations and annual supervision fees.

Common Delays and Mitigation

The most frequent causes of delay are incomplete documentation, outstanding technology audits and protracted bank-onboarding processes. Practical mitigations include engaging specialist compliance counsel before submission, commissioning the technology audit in parallel with documentation preparation, and initiating bank-relationship discussions as early as Step 2. Applicants who treat bank settlement as a separate workstream rather than an afterthought typically progress faster to operational launch.

Comparison Table Licence Types, Requirements, Fees and Typical Timelines

At a glance: how key AIFC digital-asset activities compare.

*AFSA does not publish a fixed statutory processing deadline; timing depends on application completeness and external dependencies such as banking and tech audits. Applicants should treat all timelines as indicative and plan contingencies.

Key Requirements and Eligibility for the AIFC Digital Assets Licence

Who Can Apply

The AIFC is open to foreign-owned entities. There is no nationality restriction on shareholders, and 100% foreign ownership is permitted. Applicants may incorporate a new company under AIFC rules or register a branch of an existing entity. All applicants must obtain AIFC Participant status a precondition for conducting any regulated activity. The Constitutional Statute on the AIFC confirms that the Centre’s special legal regime applies equally to domestic and international participants, providing a single regulatory gateway irrespective of country of origin. The FSFR sets out the detailed corporate governance, directorship and registered-office requirements that apply once a firm is established.

Minimum Capital and Prudential Requirements

For a DATF applicant, the minimum capital requirement is the higher of USD 200,000 or 12 months’ projected working capital. AFSA may impose higher capital requirements depending on the firm’s risk profile, volume expectations and the range of activities authorised. Capital must be maintained on an ongoing basis and is subject to supervisory reporting. Custody-only applicants face separate prudential rules calibrated to the risks of holding client assets.

Approved and Designated Persons Fit and Proper Checks

AFSA requires that certain controlled functions are filled by individuals who have been individually assessed and approved. Key roles include the Senior Executive Officer (SEO), Chief Compliance Officer (CCO), Money Laundering Reporting Officer (MLRO) and Chief Information Technology Officer (CITO). Each candidate must submit a personal questionnaire, undergo background screening and demonstrate relevant experience. AFSA publishes approved-individual application forms on its regulated-activities page, and candidates should anticipate direct engagement including interviews with AFSA staff during the assessment process.

Fees and Timelines

Understanding the full cost structure is essential for budgeting an AIFC digital assets licence Kazakhstan application.

AFSA regulatory fees: The application fee for Operating a Digital Asset Trading Facility is USD 70,000, payable upon invoice from AFSA. Annual supervision fees comprise a fixed component of USD 30,000 plus a variable component linked to the scope of authorised activities. Payment is made via AFSA’s invoice-request process and must be settled before AFSA will commence formal review.

Indicative third-party costs (market estimates not AFSA policy): Applicants should budget for legal and compliance documentation drafting, mandatory technology audits, penetration testing, custodian bonding or attestation reports, and integration with chain-analytics and KYC vendor platforms. These costs vary significantly depending on the applicant’s existing infrastructure and chosen service providers. Prospective applicants are advised to obtain competitive quotes early in the process.

Timelines: AFSA does not guarantee a fixed processing timeline. The overall duration depends on the completeness of the application, the speed of RFI responses, the readiness of the technology audit, and critically the progress of banking onboarding. Industry observers note that well-prepared applicants with a complete documentation pack and a pre-engaged banking partner can progress materially faster than those who treat these workstreams sequentially.

Technical and Operational Requirements

Custody and Wallet Architecture

The DAA requires firms providing custody to implement robust wallet architecture, including clear segregation between hot and cold storage, multi-signature authorisation protocols and where a third-party custodian is engaged evidence that the custodian meets AFSA’s operational and financial standards. Reconciliation procedures must ensure that client assets are verifiable at all times, and industry best practice is trending toward proof-of-reserves attestations, although the DAA does not yet mandate a specific attestation format.

Mandatory Technology Audit and Cybersecurity Policy

Before AFSA grants final authorisation, every DATF and custody applicant must undergo a mandatory third-party technology audit. The audit scope is defined by the DAA and covers the firm’s entire technology stack from matching engines and order management to wallet infrastructure and disaster-recovery protocols. AFSA expects alignment with internationally recognised cybersecurity standards such as ISO 27001 or SOC 2. Penetration testing should be conducted at least annually, and most applicants commission an initial test during the application process to identify and remediate vulnerabilities before AFSA’s review.

AML/KYC and Transaction Monitoring

AIFC VASPs must operate a FATF-aligned AML/CFT framework. This includes risk-based customer due diligence, enhanced due diligence for higher-risk relationships, ongoing transaction monitoring, sanctions screening, and full travel-rule compliance for virtual-asset transfers. The MLRO is responsible for filing suspicious-activity reports (SARs) with the relevant authorities. The AFSA Guidance for AIFC Banks further reinforces these expectations by requiring banks to verify that DATF and DASP clients maintain effective AML controls as a condition of settlement-account provision.

Reporting, Record Keeping and Auditability

Licensed firms must submit regular supervisory returns to AFSA, maintain comprehensive records of all transactions and client interactions, and appoint an external auditor approved by AFSA. The external auditor must be independent, meet AFSA’s qualification criteria, and produce an annual audit report that is filed with the regulator. Record-keeping obligations extend to all digital-asset transactions, wallet movements, client onboarding files and compliance decisions and records must be retained for a minimum period prescribed in the DAA.

Banking and Fiat On-Ramp

How to Secure Relationships with AIFC Banks

Securing a fiat settlement account is frequently the most operationally challenging element of the licensing process. The AFSA Guidance for AIFC Banks conducting settlement for DATF/DASP entities establishes that banks may onboard digital-asset firms subject to their own risk appetite, provided they conduct enhanced due diligence covering the applicant’s AML controls, ownership structure and operational model. Practical steps that accelerate bank engagement include: initiating discussions during Step 2 of the application process; preparing a comprehensive shareholder and source-of-funds pack; presenting a live demonstration of transaction-monitoring systems; and providing evidence of custodial attestations and insurance coverage where available.

Practical Bank-Readiness Checklist

Banks conducting settlement for AIFC-licensed digital-asset firms will typically request the following:

• Ownership and corporate structure: Certified shareholder register, UBO declarations, and group-structure chart.
• AML/CFT controls: Approved AML policy, MLRO appointment letter, and evidence of compliance training.
• Compliance team credentials: CVs and qualifications for all compliance personnel, including AFSA-approved individuals.
• Transaction-monitoring evidence: Vendor contracts, system configuration documents, and sample alert-handling procedures.
• Custodial attestations: Third-party custody audit reports, insurance certificates and wallet-segregation documentation.

Practical Checklist and Downloadable Document List

The following documents form the core of a complete AIFC Digital Assets Licence application. AFSA publishes downloadable templates and forms on its regulated-activities page.

• AIFC company formation documents: Memorandum and articles of association, board resolutions, registered-office lease.
• Business plan: Market analysis, product description, revenue model, three-year financial projections.
• AML/CFT policy and compliance manual: Risk assessment, CDD/EDD procedures, SAR process, sanctions-screening protocols.
• Custody architecture diagram: Hot/cold wallet design, key-management process, reconciliation procedures.
• Technology audit scope: Terms of reference for the mandatory third-party audit, including penetration testing.
• Approved individuals forms: Personal questionnaires for SEO, CCO, MLRO and CITO.
• Financial projections: Capital-adequacy calculations demonstrating the higher of USD 200,000 or 12 months’ working capital.

A consolidated AIFC licensing checklist is available as a downloadable PDF for firms preparing their submission.

Case Studies

Exchange Operator Sandbox to Full DATF Licence

A mid-size exchange operator initially entered the AIFC through the FinTech Lab (regulatory sandbox), which allowed it to test its matching engine and onboarding processes in a controlled environment with limited client volumes. After demonstrating operational viability and completing all required compliance and technology upgrades including a full third-party technology audit the firm applied for and received a full DATF authorisation from AFSA. The transition from sandbox to full licence required enhanced capital, the appointment of additional approved individuals and the establishment of a banking relationship for fiat settlement. AFSA’s 2024 growth report confirmed multiple successful transitions of this kind, underscoring the viability of the sandbox-to-licence pathway.

Custody Provider Full Authorisation and Bank Settlement

A specialist digital-asset custody provider incorporated an AIFC company with fully segregated cold-storage infrastructure and a multi-signature governance framework. The firm commissioned its technology audit concurrently with the documentation-drafting phase, which compressed the overall timeline. After receiving AFSA authorisation, the custody provider worked with an AIFC-licensed bank to open settlement accounts a process that required extensive KYC, proof-of-reserves documentation and a live demonstration of its transaction-monitoring platform. The firm now provides custody services to multiple AIFC-licensed trading facilities, illustrating the ecosystem benefits of early market entry.

Testimonial

“The AIFC framework gave us the regulatory credibility we needed to scale across the CIS and Middle East. The process was rigorous, but the clarity of AFSA’s expectations and the responsiveness of the regulatory team made it manageable.” Compliance Director, [Company name redacted]

Next Steps and Related Reading

Firms exploring the AIFC digital assets licence Kazakhstan pathway may also benefit from the following resources:

• AIFC company formation a practical guide to incorporating an AIFC entity, tax registration and payroll.
• AFSA compliance and AML a deep dive into AML/CFT implementation, travel-rule compliance and independent audit requirements.
• AIFC custody rules and best practice custody architecture, key management and proof-of-reserves standards.
• Banking in Astana for fintechs opening settlement accounts, navigating bank due diligence and securing fiat on-ramps.

Sources

• AIFC Rules on Digital Asset Activities (DAA) AIFC
• AFSA Operating a Digital Asset Trading Facility
• AIFC / AFSA Fees Rules Application Fees Schedule
• AFSA Guidance for AIFC Banks Settlement for DATF/DASP Entities
• Constitutional Statute on the Astana International Financial Centre Adilet
• AFSA Closes 2024 with Record Growth AFSA Press Release
• AIFC Financial Services Framework Regulations (FSFR)