Company Registration in the Astana International Financial Centre (AIFC) and Obtaining a Providing Money Services Licence. Service offer

The provision of money and payment services in the AIFC is regulated by the Financial Services Framework Regulations and other legislation. A licence to carry on the regulated activity of Providing Money Services (PMS) is required to provide the following services:

1. Currency Exchange.
2. Selling or Issuing Payment Instruments.
3. Issuing, Redeeming or Selling Electronic Money.
4. Execution of Payment Transactions – making payments, including transfers of money to a user’s account (including a bank account) held with the PMS-licensed company or with another money service provider. This includes, but is not limited to:
   1. execution of direct debits, including one-off direct debits;
   2. execution of payment transactions through a payment card or a similar device.
5. Execution of Payment Transactions where the funds are covered by a credit line. Providing the credit line may additionally require a licence to carry on the regulated activity of Providing Credit.
6. Money Remittance – a transfer or transmission of money where no payment accounts are created in the name of either the payer or the payee. This includes, but is not limited to:
   1. receiving money from a payer for the purpose of then transferring it to the payee;
   2. receiving money on behalf of, and making it available to, the payee.
7. Execution of Payment Transactions through a telecommunication, digital or IT device – a service where the consent of the payer to execute a payment transaction is given by means of any telecommunication, digital or IT device and the payment is made to the operator of the relevant system or network, acting only as an intermediary between the client and the supplier of the goods and services.
8. Account Information Services.

The appointment of a Board of Directors is mandatory.

The company must also appoint:

• Senior Executive Officer (SEO);
• Finance Officer;
• Compliance Officer (CO);
• Money Laundering Reporting Officer (MLRO) and his/her deputy.

The appointment and change of each Director, SEO, Finance Officer, CO and MLRO must be approved by the Regulator.

The positions of Director, SEO, and Finance Officer can be held by one person, provided that this person meets the Regulator’s requirements. The SEO must be present in Kazakhstan sufficient time to be able to effectively manage the company (usually at least once a year).

One person can act as both CO and MLRO, and that person must be a resident of Kazakhstan.

The minimum number of shareholders and beneficial owners of a company is 1.

A shareholder can be either an individual or a legal entity (including a non-AIFC registered one). A company’s beneficial owner is always an individual who ultimately controls the company.

A company’s beneficial owner is an individual who directly or indirectly holds at least 10% of the company’s shares or voting rights, or who is otherwise able to significantly influence the company’s management.

The company must maintain a registered office within the geographical boundaries of the AIFC at all times. Official correspondence and notifications will be sent to this address.

The mandatory capital resources are the greater of the following:

• base capital of USD 50 000; or
• 10% of the company’s annual audited expenditure.

For a new company, the expenditure is determined based on the forecast expenditure for the first 12 months, as reflected in the budget and business plan submitted along with the licence application.

The company must maintain its capital resources at or above the required level at all times. Capital resources may include, in particular, fully paid-up ordinary equity share capital. Any intangible, illiquid, and other assets that do not meet the requirements must be deducted from the calculation.

The Regulator assesses whether all directors, key employees, beneficial owners, and other persons who influence the company’s activities are fit and proper.

The assessment takes into account:

• integrity and business reputation;
• professional competence, education and experience;
• ability to perform the relevant role;
• financial solvency;
• criminal record, regulatory breaches, disqualifications, and bankruptcies;
• potential conflicts of interest;
• group structure and influence of related parties;
• origin of capital and sources of funds.

This assessment is not limited to the licence application stage. The company must continuously monitor the compliance of all approved persons with the Regulator’s requirements, promptly correct violations, and notify the Regulator of any changes in the composition of approved persons.

0. Incorporate a company in the AIFC and rent an office.

1. Hire a SEO, CO, and all the other required personnel of the company.

2. Prepare documents reflecting the company’s PMS activities, including:

• Business plan, budget;
• Description of the payment and IT infrastructure, measures to ensure the security of client funds and personal data;
• Compliance manual and AML/CFT risk management policy;
• Internal policies and procedures;
• Templates of client agreement.

3. Submit to the Regulator an application for in-principle approval, and applications for approval of individuals. Pay application fees.

4. Key personnel are interviewed by the Regulator. Answer the Regulator’s questions.

5. Obtain in-principle approval. Deposit the company’s capital resources, open the necessary bank accounts, make agreements with key counterparties, and finalize the operational infrastructure.

6. Obtain the final PMS licence.

7. Register with the financial intelligence unit* to report suspicious and threshold transactions.

*The financial intelligence unit in charge of supervising the activities of financial companies registered in the AIFC is the Financial Monitoring Agency of the Republic of Kazakhstan (FMA).

The overall time to obtain a PMS licence is approximately 4–6 months, provided that documents are submitted promptly, the Regulator’s requirements are met, and the Regulator does not have a lot of further queries.

The total of licence fees payable depends on the company structure. The main fees are:

• Licence application fee – USD 14 000;
• Application registration fee – USD 500;
• Application fee for approval of an individual – 500 USD per individual;
• Annual supervision fee* – USD 4 200;
• Additional application fee, if a company conducts activities in relation to crypto assets – USD 2 800.

*From 1 January 2027, a variable component, calculated on a quarterly basis, will be added to the fixed annual supervision fee:

• for annual transaction value of up to USD 280 000 000 – not applicable;
• for annual transaction value above USD 280 000 000 – 0.0015% annually of the amount exceeding USD 280 000 000 (minimum – USD 250 000 per year).

The licence remains valid continuously until it is amended or revoked by the Regulator, or until the company applies for its termination.

Along with the payment of annual supervision fee, the company must also submit an Annual AML Return to the Regulator.

The initial supervision fee is payable within 21 days of the licence being granted and is pro-rated over the remaining full months till the end of the year. Thereafter, it is payable annually by 1 January.

Payment for PMS licence application services is made in three stages:

Stage I – services of:

• company incorporation and first-year administration;
• finding office premises for a PMS company;
• appointing local Kazakhstani staff as CO and MLRO; OR
• appointing your foreign staff as SEO, CO and MLRO.

Payment must be made before we proceed with incorporation of the company.

Stage II – services of:

• developing a full set of mandatory regulatory policies and procedures;
• advising on the drafting of a regulatory business plan and financial model in line with the Regulator’s requirements;
• preparing and approving key personnel (SEO, CO, MLRO and others);
• preparing the licence application form and the Money Services Supplement;
• providing comprehensive support and liaising with the Regulator during the application review (phone calls, replies to queries);
• other legal actions necessary to obtain the licence.

Payment must be made before we proceed to draft policies and submit the application.

Stage III – assistance with opening necessary accounts for the company.

Payment must be made before we proceed to help with account opening.

[1] The fees are valid as of September 2026.

[2] The cost of renting a suitable office in the AIFC starts at USD 8 000 per year.

[3] The fees of local Compliance Officers and MLROs start at USD 2 000 per month.