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 officerand Money Laundering Reporting Officer (MLRO)。Senior executive officers must spend substantial time in the country performing their duties。
AFSA authorized capital and buffers
MSP licenseThe basic paid-in capital is 200,000 Dollar。also，Mandatory additional possession 200,000 Dollar，Or enough to support real-life scenarios 12 monthly operating expensesFiat currency funds(Whichever is higher) as an 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
Onshore payment institutionNew regulations on ladder capital：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 monthsFunding 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。
4. Hong Kong Huitong Legal Agency：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 not a residentbankApplication for establishing 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.。
7. Industry cutting edge：Compliance implementation cases for foreign-invested entities
Binance (Binance) Obtained AFSA license with Bybit
globalizationDigital asset trading platform，Access AIFC through the AFSA regulatory pathway in accordance with the law FinTechregulatory sandbox (FinTech Lab)。After meeting statutory compliance tests and localization requirements for senior executives，Successfully obtained official license from AFSA。
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
Implement a dual-track system。Astana International Financial Center (AFSA regulated) money services provider license subject to English common law，and onshore (NBK regulated) payment institution licenses subject to civil law systems。
Minimum basic paid-in capital 200,000 Dollar。In addition, additional configuration is mandatory 200,000 US dollars may be enough to cover the future 12 Monthly forecast expenditures as operating buffer (whichever is higher)。
since 2024 Year 7 A tiered system will be implemented starting from this month：Single service required 1.5 billion tenge；Two items 2 billion tenge；three items 2.5 billion tenge；All services are the best 3 billion tenge，Must pay in tenge cash。
Absolutely prohibited。Both AFSA and NBK conduct substantive examination。The AFSA system further stipulates that the Anti-Money Laundering Reporting Officer (MLRO) must be a permanent resident of Kazakhstan。
Legally compulsory appointment of approved individuals (Approved Individuals)，including senior executives、financial officer、Compliance Officer and Money Laundering Reporting Officer (MLRO)。
Not compliant with the law。In addition to appointing a permanent MLRO, the agency，It is also mandatory to appoint a Deputy MLRO to ensure the legal and uninterrupted functioning of the system。
Prohibited by law。If the candidate is in bankruptcy liquidation or delisted before the financial institution 1 Served as senior executive during the year，He will be directly deprived of his qualification as the head of the payment institution.。
Belongs to the absolute red line。If the organization the candidate once managed is delisted due to regulatory violations，From the date of removal 5 Shall not serve as an executive of Kazakhstan’s payment institution again during the year。
Yes。If a non-resident bank opens a branch in Kazakhstan，Its executive team must by law be equipped with at least two local residents of Kazakhstan as executive executives。
Implement strong penetration verification。Applicants must provide funds for initial capital verification up to the past consecutive 12 Months of legal transfer records，To prove that the funds are not money laundered。
no absolute limit，But must meet equivalent executive education requirements、AML Background Screening and Sanctions List Verification。Foreign directors are also subject to no criminal and bankruptcy records.。
