Kazakhstan FSP payment service provider license

Kazakhstan FSP payment service provider license

Legally licensed under the dual-track regulation of the AIFC offshore system and the NBK onshore system

Kazakhstan Payment Services License (Legal name under the AFSA system is "Money Service Provider MSP", Under the onshore NBK system, it is legally called a “payment institution”, In practice, they are often collectively referred to as FSP/PSP licenses) and are strictly subject to Kazakhstan’s dual-track financial regulations.. According to current laws and 2024 Year 7 moon 1 effective on 10 resolution, Industry access is subject to statutory paid-in capital (up to 3 billion tenge or 40 An absolute verification red line has been set up in terms of the substantial performance of duties (Fit and Proper) of core executives.. Hong Kong Express provides applicant entities with statutory assessments covering the dual-track structure, Corporate establishment, Full-case legal agency services for executive qualification review and anti-money laundering (AML/CFT) penetrating verification..

Release time: Application preparation reference
Hong Kong Huitong service teamApply for support
Document preparation and project coordination
work focus: business needs, Document consistency and matters to be confirmed
Service direction: Business description, Sorting out application materials and ongoing compliance matters
Service Description: Organize disclosure regulatory requirements based on proposed business operations, Material list and project nodes. Involving legal opinions, During audit or professional assurance, The corresponding professionals and service scope should be confirmed separately.; Competent agencies and banks make independent review decisions.
Familiar with the regulatory application process
Professional compliance team
Standardized compliance process
Multi-jurisdictional services

1. FSP license staffing and capital access statutory requirements

⚖️

AFSA core executive statutory establishment

The AIFC system mandates the appointment of “approved persons” who pass the substantive review (Fit and Proper). Statutory positions include: Senior Executive Officer (Senior Executive Officer), financial officer, Compliance Officer and Money Laundering Reporting Officer (MLRO). Senior executive officers must spend substantial time in the country performing their duties.

💼

AFSA authorized capital and buffers

The basic paid-in capital of MSP license is 200,000 Dollar. also, Mandatory additional possession 200,000 Dollar, Or enough to support real-life scenarios 12 Fiat currency funds for monthly operating expenses (whichever is higher) as operating buffer.

🛡️

NBK executive prohibition red line

The onshore system implements strict access exclusions: Those with unexpunged criminal records are strictly prohibited, Before bankruptcy liquidation 1 Executives held during the year, and has not yet been removed from supervision due to violation of regulations 5 years of personal responsibility.

🔐

MLRO localization and deputy position compulsory

For the AFSA system, The Money Laundering Reporting Officer (MLRO) must be a resident of Kazakhstan, Never accept remote performance of duties. And the organization must compulsorily appoint a deputy MLRO to ensure that the compliance system operates without interruption..

2. The latest capital legislation and regulatory developments (2024Effective in year)

  • 2024Effective July 1

    New regulations on stepped capital for onshore payment institutions: NBK according to Article 10 resolution, Capital Threshold for Execution of Number of Linked Services. The lowest single service 1.5 billion tenge; Increment each time an item is added 5000 Ten thousand, Four types of all-inclusive package must be paid in accordance with the law 3 100 million tenge (only in cash form).

  • Anti-Money Laundering Review Guidelines

    source of funds (SoF) Penetrating traceability: Regardless of the regulatory path applied for, Regulators have uniformly extended the initial capital traceability standards to the past consecutive 12 Months of funding history, Absolutely block the penetration of illegal capital.

  • Sanctions Compliance

    Counterterrorism and Sanctions List Verification: NBK enforces a strict ban on any activities listed as financing of terrorism, Individuals or associated entities on the Extremism and Weapons of Mass Destruction Proliferation List, Participate in company management or hold equity shares.

3. Statutory Application Submission File and Substantive Examination Elements

Articles of Association, Legal person registration certificate and statutory penetration structure disclosure document traceable to the ultimate beneficiary (UBO).

issued by an independent auditing agency, For the paid-in capital verification funds (continuous in the past 12 Months) Source of Legal (SoF) Traceability Audit Report.

Covers the future under realistic prediction scenarios (including positive and negative) 12 Monthly financial budget model and business plan for operating expenses.

Internal Control Procedures and Anti-Money Laundering (AML/CFT) Compliance Operations Manual, It also comes with a deputy MLRO (Deputy MLRO) performance mechanism plan..

Certification of higher education qualifications for senior executives and heads of executive agencies, No criminal record and no bankrupt practice prohibition affidavit.

Astana International Exchange (AIX) logo
Astana International Exchange (AIX) logo.

4. Hong Kong Huitong application and compliance support: End-to-end process for license application

Stage one: Jurisdiction Assessment and Incorporation (3-5week)

Determine whether the AIFC offshore system or the NBK onshore system applies. Establishing a legal entity, And complete the verification of the full cash (US dollars or tenge) capital deposit in accordance with the law.

Stage 2: Personnel screening and compliance document preparation (4-6week)

Match executives with academic qualifications and no bankruptcy/violation records in accordance with regulations. Hong Kong Huitong Drafting AML Manual, and guide customers to issue 12 Monthly source of funds (SoF) prove.

Stage three: Submission of Application and Eligibility Hearing (3-6months)

Submit registration application to AFSA or NBK. Cooperate with supervision of senior executives, The MLRO and its deputies conduct rigorous fit and proper penetration verification and administrative hearings.

Stage four: Approval in principle and formal licensing (3-6week)

Obtain regulatory in-principle approval, After confirming operating buffer funding (such as an additional $200,000 from AFSA) and physical office space being in place, Officially obtain license.

5. Dual-track capital access requirements and forensic audit standards

Supervision system and verification categories Legally regulated amounts and mandatory standards
AFSA Base Capital and Buffer Funding Legal minimum paid 200,000 Dollar. In addition, it is mandatory to hold additional 200,000 Dollar Or meet the predicted scenario 12 Legal funds for monthly operating expenses (whichever is higher).
NBK onshore stepped capital threshold Must be paid in tenge cash: single category 1.5 billion tenge; Two categories 2 billion tenge; Category three 2.5 billion tenge; Four categories of all-inclusive 3 billion tenge.
Senior management qualifications and localized configuration AFSA requires the MLRO to be a resident and have a deputy. If a non-resident bank applies to establish a branch, The executive team must include at least 2 name Kazakhstan Resident Executive.
Fund traceability compliance costs Hong Kong Huitong forensic audit covers the past 12 months Fund history traceability report preparation and executive background (no bankruptcy/delisting history) statement notarization services.

6. Trigger deal rejection (Refuse to approve) absolute red line

Executive ban history: If the proposed executive is before bankruptcy/compulsory liquidation of the financial institution 1 Served during the year, Or have been removed from supervision due to violation of regulations. 5 Year, Directly trigger qualification rejection.

Substantial lack of compliance station: In the AFSA system, If attempting to remotely assign a Money Laundering Reporting Officer (MLRO), Or the senior executive officer does not have substantial time in residence to perform his duties., Will be filed and returned.

Fund verification broken chain: The actual controller cannot issue a certificate for 12 Months of legal source of funds records, Or the NBK applicant fails to pay the full legal registered capital in the form of tenge cash..

Astana city architecture in Kazakhstan
Astana city architecture in Kazakhstan.

7. Industry cutting edge: Compliance implementation cases for foreign-invested entities

Digital asset compliance

Binance (Binance) Obtained AFSA license with Bybit

Global digital asset trading platform, Enter the AIFC Fintech Regulatory Sandbox through the AFSA regulatory path in accordance with the law (FinTech Lab). After meeting statutory compliance tests and localization requirements for senior executives, Successfully obtained official license from AFSA.

Full onshore license

CITIC Altyn Bank (CITIC Altyn Bank) Operation established

Altyn Bank, in which China CITIC Bank has a stake, meets NBK’s extremely high capital and senior management access standards in accordance with the law., Obtain full license qualification, Establishing a benchmark for onshore financial compliance operations.

8. Practical Legal Questions and Answers (FAQ): Analysis of capital and personnel access

9. Relevant regulations, Regulatory information and further reading