Jurisdiction • Kazakhstan • AIFC
AIFC (Astana): company setup, AFSA licensing and compliance for cross-border & digital asset business.
The Astana International Financial Centre (AIFC) is a special jurisdiction in Kazakhstan with its own regulatory environment.
It is widely used for international structuring, financial services licensing and fintech models — including projects with crypto and tokenization elements
(where applicable permissions and controls are required).
We focus on a “bankable, regulator-ready” setup: structure → governance → AML/KYC → operational procedures → narrative & evidence pack.
What founders use AIFC for
- Holding / HQ structure for cross-border operations.
- Regulated financial services (AFSA licensing routes).
- Fintech models requiring governance + compliance depth.
- Investor-ready setup with clear documentation and controls.
Related: Corporate and
Compliance.
Routes
Typical AIFC engagement routes
The correct route depends on the activity, target clients, custody responsibility, marketing footprint, counterparties and team substance.
Below are typical “starting points” we see.
Route
AIFC company setup
A clean structure for group operations, partnerships and contracts.
- Entity selection and corporate baseline.
- Ownership/UBO narrative and governance setup.
- Founders’ arrangements (control, vesting, exit).
- Banking/PSP readiness narrative (if needed).
Best for: holding/HQ, cross-border operations, investor structure.
Route
AFSA licensing readiness
If you provide regulated financial services in AIFC.
- Activity mapping and licensing scope memo.
- Governance, compliance, risk and outsourcing controls.
- Policies + procedures aligned to real flows.
- Application narrative and regulator Q&A support.
Best for: financial services firms, fintech, institutional models.
Route
Fintech / crypto / tokenization structuring
When legal classification, disclosure and controls are core.
- Product & flow classification (assets, rights, custody).
- Risk disclosures and restricted jurisdictions logic.
- AML/KYC + sanctions baseline (if needed).
- Contracts: counterparties, vendors, clients, IP.
Best for: projects where compliance and counterparties drive viability.
Deliverables
What we deliver for AIFC projects
We build a working legal layer: documents + governance + compliance that match your real operations, tools and transaction flows.
Core
Route memo & project plan
A clear recommendation with assumptions, risks and next steps.
- Activity mapping and regulatory positioning.
- Corporate structure & governance baseline.
- Compliance scope for banks/partners/regulator.
- Timeline + checklist for the team.
Outcome: fewer surprises and fewer revisions.
Corporate
Corporate & governance documents
A clean structure with clear control, roles and decision-making.
- Shareholder / founder arrangements (if needed).
- Board/management roles and delegated authorities.
- Resolutions, registers and governance baseline.
- Group structuring support (multi-jurisdiction).
Useful for investors, banks and future due diligence.
Compliance
AML/KYC & sanctions framework
Controls, onboarding and escalation designed around your flows.
- Client risk scoring and CDD/EDD logic.
- Sanctions/PEP screening workflow and escalation.
- Ongoing monitoring and recordkeeping baseline.
- Evidence trail checklist (what to keep & how).
Critical for banking and regulated/serious partnerships.
Risk
Risk & outsourcing controls
A practical risk map and vendor oversight framework.
- Risk taxonomy + risk appetite baseline.
- Operational, tech, custody and fraud risks.
- Outsourcing policy + vendor due diligence.
- Incident management and remediation plan.
Most “regulator questions” land here.
Ops
Operational procedures (SOPs)
Step-by-step procedures your team can execute.
- Onboarding procedures and periodic reviews.
- Approvals, escalation and reporting cadence.
- Complaints handling (if relevant).
- Business continuity baseline (if needed).
Designed for implementation, not “paper compliance”.
Legal
Contracts & client-facing docs
Legal documents aligned with your operating model.
- Client agreements, terms and risk disclosures.
- Vendor/outsourcing and IT/security clauses.
- IP assignment + contractor agreements.
- Counterparty agreements (banks/PSPs/custodians/LPs).
Goal: reduce friction and legal risk in operations.
Approach
How we run an AIFC engagement
We map your real flows first (clients → onboarding → transactions → custody → counterparties → outsourcing), then build the legal layer.
What we map first
- Client types and jurisdictions (retail/pro; markets served).
- Flow of funds/assets (fiat rails, wallets, custody model).
- Counterparties (banks, PSPs, LPs, custodians, vendors).
- Team roles and segregation of duties (who does what).
Output: a control map showing responsibilities, evidence, escalation and reporting.
Typical engagement paths
AIFC setup
Structure → governance → contracts → banking narrative (if required).
Licensing readiness
Scope memo → policies & procedures → application narrative alignment → Q&A.
Bank/PSP readiness
AML/KYC + sanctions → onboarding SOPs → evidence pack → counterparty alignment.
Existing business clean-up
Gap analysis → rewrite docs → implement procedures → reporting cadence baseline.
Related: Compliance and
Corporate.
FAQ
Common questions about AIFC
Short answers. We tailor the route to your model and the expectations of regulators, banks and counterparties.
Is AIFC only for financial services?
No. Many founders use AIFC for cross-border structuring and holding/HQ logic. However, if you provide regulated financial services, licensing and compliance expectations become central and must be mapped early.
Can we register first and “figure out compliance later”?
You can, but it usually slows down banking and partnerships. Banks and institutional counterparties typically ask for AML/KYC, sanctions screening, onboarding procedures and a coherent funds/asset flow narrative early.
What do regulators and banks care about first?
Clear roles (compliance/MLRO where relevant), custody and control logic, onboarding and monitoring procedures, outsourcing oversight, incident handling, and an evidence trail you can actually produce.
Can you start with a short “route memo” first?
Yes. It’s often the best starting point: we map your activities and goals and provide a short recommendation with assumptions, risks, and a concrete document scope.
Need an AIFC-ready setup or licensing scope?
Send a short description: what you do, target clients/markets, whether you touch client assets, and your banking/licensing goal.
We’ll propose a practical route memo and the first deliverables.
If you already have policies and procedures, we can start with a gap analysis and rebuild only what is missing.
Good fit for AIFC support:
- Cross-border businesses needing a clean HQ/holding layer.
- Fintech and financial services firms preparing for licensing.
- Projects needing AML/KYC + operational procedures for banks.
- Teams aligning governance, outsourcing and risk controls.
We map controls to real flows — that’s what regulators and banks care about.