Crypto licensing • AIFC (Kazakhstan)

CASP / Digital Asset licensing in AIFC (AFSA).

End-to-end support for AIFC structures and AFSA interactions: licensing perimeter, corporate setup, compliance documentation, governance, outsourcing model, capital planning, and regulator Q&A — built around your real operating model.

Best fit for exchanges, broker/dealers, custody, tokenization infrastructure, and crypto service providers planning regulated operations from AIFC.

What we clarify first

Your regulated activity in AFSA terms (perimeter, permissions, restrictions).
Client asset flows (fiat + crypto), custody and settlement responsibilities.
Governance roles: CEO, CO, MLRO, Internal Auditor and reporting lines.
Capital & liquidity planning, substance, outsourcing and vendors.

If you need a fixed starting scope, see Packages.

Overview

AIFC licensing is about substance and controls.

AFSA will look beyond policy wording. We align documents with your staffing, processes, outsourcing chain, systems, and real client flows.

Perimeter

Correct permission set

Define the right regulated activities and avoid licensing “overreach” or gaps that break your model.

Activity mapping and permission shortlist.
Client categorisation and product boundaries.
Marketing and cross-border positioning baseline.

Outcome: clear license perimeter and assumptions.

Governance

Roles, independence, reporting

Governance that works in practice: controlled functions, delegations, and independence where required.

CO / MLRO model and continuity planning.
Internal audit approach and oversight.
Conflicts, complaints, incident response baseline.

Outcome: an org and reporting model AFSA can sign off.

Compliance

Policies that match your operations

AML/CFT, sanctions, risk and BCP aligned with your actual onboarding, monitoring and vendor stack.

Risk assessment and control design baseline.
Sanctions screening and monitoring logic.
Recordkeeping, reporting, escalation procedures.

Outcome: documents + procedures implementable by your team.

What we do

Core workstreams for CASP in AIFC.

You can start from a perimeter assessment, then move to documentation and regulator Q&A support. We scale scope based on your license type and complexity.

Phase 1

Pre-application readiness

Get the model “AFSA-ready” before heavy drafting and filings.

License mapping and structuring logic.
Substance, staffing and outsourcing baseline.
Application plan + document list + timeline.

Phase 2

Compliance documentation pack

Policy set built around your real onboarding/monitoring flows and operational responsibilities.

AML policy + onboarding procedures.
Sanctions policy + screening/monitoring.
Compliance manual, risk/BCP baseline, incident handling.

Phase 3

Application & AFSA Q&A

Support through regulator questions, revisions, and alignment of narrative with evidence.

AFSA comment handling and redrafting.
Controlled function packs and supporting statements.
Alignment of financial model and capital buffers.

Support

AIFC corporate setup

Company setup, governance and contracts structured for licensing and substance.

Private company registration route.
Constitutional documents and governance.
Key commercial contracts alignment.

Open Corporate →

Support

Ongoing compliance

Post-licensing support: updates, audits, reporting, vendor changes, incident handling.

Policy updates and control testing baseline.
Periodic reporting and governance support.
Remediation and regulator interactions.

Open Compliance →

Support

IT/IP & data layer

Legal layer for platform, vendors, data processing, IP chain and client-facing terms.

Vendor DPAs and outsourcing contracts baseline.
IP clean-up and assignments.
Client terms, privacy and disclosures.

Open IP/IT →

Process

How CASP licensing work typically runs in AIFC.

We keep the process predictable: scope → perimeter → evidence → documents → regulator Q&A. You always know what’s next.

Step 1

Kick-off & model mapping

Products, clients, flows (fiat/crypto), custody, settlement, vendors, and operational responsibilities.

Step 2

Perimeter & structure

Permission shortlist, substance plan, governance roles and outsourcing map aligned with AFSA expectations.

Step 3

Documents & evidence

Policies, procedures, org charts, role descriptions, risk framework, financial model and supporting packs.

Step 4

AFSA Q&A cycle

Handle regulator questions, redrafting, clarifications, and implementation adjustments.

What we need from you

Short description of services and target markets.
Client types and onboarding flow (incl. KYB if B2B).
Asset flows: who holds keys, who can move funds, settlement logic.
Vendors: custody, KYC/KYB, blockchain analytics, payment providers, tech stack.

If some parts are not defined yet, we map them together in the kick-off and build a workable baseline.

Typical deliverables

Licensing perimeter memo + assumptions.
Compliance documentation pack (AML, sanctions, compliance manual, risk/BCP baseline).
Governance & controlled functions baseline (roles, reporting, independence).
AFSA Q&A support and revision rounds.

If you want a fixed-scope start, see Packages or request a tailored scope via Contact.

FAQ

Common questions about CASP licensing in AIFC.

Short, practical answers. For your case we confirm details in the initial assessment.

Can we start without full local team in AIFC?

AFSA evaluates substance and governance. Outsourcing can help, but key roles, reporting lines, and oversight must be realistic and documented. We design the model accordingly.

What triggers the most AFSA questions?

Asset flows (custody/settlement), outsourcing chain, conflicts of interest, AML controls, and whether the documents match real operations and staffing.

Do you support the full application cycle?

Yes. We typically start from perimeter and readiness, then move to document drafting, controlled function packs, and AFSA Q&A handling and revisions.

Can we combine AIFC route with EU or UAE planning?

Yes. Many projects plan multi-jurisdictional expansion. We can map AIFC requirements in parallel with MiCA/UAE routes to avoid rework later.

Want a practical AFSA licensing roadmap?

Send a short description: what you do, whether you custody client assets, your target clients/markets, and what vendors you rely on. We’ll reply with the best starting scope (readiness → documentation → AFSA Q&A).

If your project is multi-jurisdictional, we can compare AIFC with MiCA/UAE and build a staged plan.

Useful to include in your message:

Entity and shareholders, where the team will sit.
Asset flows: wallets, custody, settlement, fiat rails.
Client onboarding (retail/professional, KYB/KYC approach).
Vendors and outsourcing (custody, KYC, blockchain analytics, PSPs).

Even 8–10 lines is enough to start.

CASP (AIFC / AFSA)

CASP / Digital Asset licensing in AIFC (AFSA).