Crypto License in Kazakhstan: AIFC Requirements & Cost 2026

The Astana International Financial Centre was established by Constitutional Law No. 438-V of the Republic of Kazakhstan, signed on 7 December 2015. It operates as a special economic zone in Astana with its own legal system based on English common law, an independent court (the AIFC Court), and a dedicated regulator — the Astana Financial Services Authority (AFSA). AFSA is the sole body authorized to issue crypto licenses within the AIFC, and it maintains a public register of authorized firms that anyone can verify.

AIFC participants benefit from a constitutionally guaranteed tax regime: 0% Corporate Income Tax (CIT), 0% VAT on qualifying financial services, and 0% Personal Income Tax (PIT) for foreign employees — all guaranteed until 1 January 2066. Article 6(3) of the Constitutional Statute formally excludes “digital asset exchange” from the CIT and VAT exemptions; however, the May 2020 Joint Order of Kazakhstan’s finance and economy ministries re-includes Digital Asset Trading Facility (DATF) operations in the exempt activities list (item 34). In practice, DATF operators apply the 0% CIT and 0% VAT rates on the basis of the Joint Order. Ancillary digital asset activities — custody, advisory, brokerage — are unambiguously exempt. For a full breakdown, see the taxation section below.

The default entity type for crypto businesses registering in the AIFC is the Private Company. AIFC Private Companies are formed under AIFC company law (not Kazakhstani national company law) and registered with the AFSA Registrar of Companies. There is no minimum share capital requirement at formation; the regulated-activity capital minimums (e.g., $200,000 for a DATF) apply separately once you file your AFSA licence application.

To claim the tax exemptions, firms must satisfy the AIFC’s Substantial Presence Rules — maintaining real employees, operational expenses, and core income-generating activity inside the AIFC. This effectively requires a genuine physical presence in Astana, not just a registered address. Budget for office costs as a recurring annual expense alongside the supervision fees.

The primary legislation governing digital assets at the national level is the Law “On Digital Assets” No. 193-VII, which entered force on 1 April 2023. This law establishes a clear statutory basis for AFSA’s licensing activities and defines approximately ten categories of regulated digital asset activity — from operating a trading facility and dealing in investments as agent to providing custody and advisory services. The full list of license types is covered in a dedicated section below.

For businesses that are not yet ready for a full AFSA licence, the AFSA FinTech Lab offers a regulatory sandbox pathway. FinTech Lab participation is granted for an initial period (typically two years) and is renewable, allowing firms to test products in a controlled environment under lighter requirements before graduating to a full licence. Bitfinex Securities, for example, has operated under this framework since September 2021.

Each activity category carries its own capital requirements, compliance obligations, and fee structure. The choice between FinTech Lab and a full licence depends on business maturity, target market, and the scale of operations you intend to run from day one. Firms planning to operate a full-scale exchange or custody service should apply directly for a full AFSA licence rather than routing through the sandbox.

AIFC participants pay 0% Corporate Income Tax on income from regulated financial services, 0% VAT on those same services, and 0% Personal Income Tax for qualifying foreign employees. These rates are not policy positions that can be changed at the next budget cycle — they are locked in by Kazakhstan’s Constitutional Statute on the AIFC, which guarantees them until 1 January 2066. That is a 50-year window from the AIFC’s establishment in 2016.

To put this in context: a crypto business operating outside the AIFC under standard Kazakhstani corporate rules faces a 20% CIT rate. Inside the AIFC, that same business pays nothing on its financial services income for the next four decades. The difference compounds significantly once you factor in hiring international talent, where the 0% PIT rate makes remuneration packages substantially more competitive than in higher-tax jurisdictions.

• CIT: 0% — versus 20% standard rate for non-AIFC entities in Kazakhstan
• VAT: 0% — on financial services provided by AIFC participants
• PIT: 0% — for foreign employees of AIFC-registered firms
• Guaranteed until: 1 January 2066, under Constitutional Statute

Full details are published by the AIFC on their tax benefits page.

The AIFC Court and its International Arbitration Centre operate under English common law — an arrangement that is unique in Central Asia. This matters for crypto businesses for a concrete reason: your contracts, disputes, and enforcement mechanisms are governed by a legal tradition that global investors, banks, and counterparties understand and trust. You are not asking them to learn a new system.

The legal foundation is the Constitutional Statute of the Republic of Kazakhstan on the AIFC, which enshrines the AIFC’s separate legal status and mandates that AIFC law be based on the principles of English common law. AIFC Court proceedings are conducted in English. Judges include international jurists with backgrounds in English law.

For businesses that deal with institutional counterparties, raise capital from overseas investors, or need enforceable contracts across borders, this is not a cosmetic feature. It is the difference between a jurisdiction where your legal documents travel well and one where they need extensive re-working to be recognised abroad.

Astana sits at the intersection of European and Asian markets. The AIFC was designed from the outset as a bridge between these two economic zones, and Kazakhstan’s position as a major transit corridor — bordering both Russia and China while maintaining trade relationships with the EU — gives AIFC-licensed businesses access to a broad geographic footprint from a single operational base.

On the infrastructure side, the AIFC operates as a purpose-built financial district with office space, serviced addresses, and a resident business community of financial services firms. AFSA maintains its own registry (publicreg.myafsa.com) where licensed entities are publicly listed, which supports due diligence by partners and clients. Kazakhstan also has a developed banking sector capable of servicing regulated crypto businesses, which is a practical consideration that matters when correspondent banking relationships need to be established post-licensing.

The AIFC FinTech Lab functions as a pre-licensing pathway. Businesses that are not yet ready for a full AFSA licence — whether due to early-stage product development, incomplete capitalisation, or the need to pilot a model before committing to full compliance overhead — can operate within the sandbox under controlled conditions while they prepare their full application.

Major exchanges have used the FinTech Lab as an entry point before moving to full AFSA authorisation. The sandbox gives AFSA visibility into your business before formal licensing, which can streamline the subsequent application review since the regulator already understands your model and your team. It also gives your business time to build out the AML/KYC policies, appoint an MLRO and compliance officer, and prepare the three-year financial projections that a full application requires — without operating in a regulatory grey area.

The distinction between sandbox participation and full AFSA authorisation matters for your timeline planning. A business entering via the FinTech Lab should expect additional lead time before a full licence is issued, but the tradeoff is lower early-stage risk and a clearer regulatory relationship with AFSA from the outset.

Three mandatory government charges apply to every applicant. The AIFC registration fee is a one-time cost at company formation. The AFSA application fee is paid when you submit your licence dossier and is non-refundable regardless of the outcome. The annual supervision fee begins once your licence is granted and recurs every year for as long as you hold the licence.

Our service packages cover the work we do on your behalf — from AIFC entity formation and business plan drafting through AFSA application filing and post-approval compliance setup. Government fees listed above are paid separately and are not included in the package prices below.

A Digital Asset Trading Facility license authorises a company to operate a platform where buyers and sellers of digital assets meet to execute trades. This covers centralized exchanges, order-book platforms, and similar multilateral trading systems where the operator matches or executes orders on behalf of participants. Regulatory details are published on the AFSA DATF page.

The capital threshold for this license is the higher of two figures: $200,000 base capital or 12 months of projected working capital. For most early-stage exchanges, 12 months of working capital — covering staff, infrastructure, and operating costs — will exceed $200,000, making it the binding requirement. AFSA calculates working capital based on the business plan submitted with the application. See capital requirements for the full breakdown.

Applicants must also submit comprehensive AML/KYC policies, a three-year financial projection, and demonstrate that all Approved Individuals (including an MLRO and compliance officer) meet AFSA’s fitness and propriety standards. Licenses are issued for up to five years, commonly two years initially, and are renewable.

A Dealing in Investments as Agent license covers firms that execute or arrange transactions in digital assets on behalf of clients, without taking the opposite side of the trade themselves. This is the applicable license for brokers, introducers, and intermediaries who route client orders to a trading facility or exchange rather than operating one directly.

The minimum capital requirement is $50,000 — significantly lower than the DATF threshold, reflecting the reduced systemic exposure of an agency model. The firm holds no client assets and does not carry principal risk. Despite the lower capital bar, AFSA applies the same conduct and AML standards: the firm must have a compliant AML framework, an appointed MLRO, and a physical presence within the AIFC. Regulatory details are available on the AFSA Dealing in Investments as Agent page.

A Custody Services license authorises a firm to hold and safeguard digital assets on behalf of third parties. A custodian maintains control of private keys, segregates client assets from its own, and is responsible for the security of the underlying infrastructure — whether hot wallets, cold storage, or multi-party computation (MPC) systems.

Custody is a standalone regulated activity under AFSA’s digital asset framework. Firms that already operate a DATF may provide custody as an ancillary function if permitted under their existing license, but dedicated custodians must obtain this authorization separately. AFSA assesses the firm’s technical safeguards, key management procedures, and insurance arrangements as part of the application. Regulatory details, including applicable capital thresholds, are set out in the AFSA Digital Asset Activities Rules.

Crypto mining in Kazakhstan operates under an entirely separate legal regime from the AIFC. The Ministry of Digital Development, Innovation and Aerospace Industry — not AFSA — issues mining licenses under the national Law “On Digital Assets” (No. 193-VII, in force since 1 April 2023).

A mining license has a three-year term and is subject to Kazakhstan’s energy consumption rules. Licensed miners must report their power usage and comply with quotas set by the government, which periodically restricts industrial mining during peak electricity demand periods. Applicants register under Kazakhstani national law rather than through the AIFC company registry, meaning the AIFC tax exemptions (0% CIT, 0% VAT) do not automatically apply to mining operations. Companies considering mining in Kazakhstan should treat this as a distinct licensing track from any AFSA-regulated activity — a business that mines and also wishes to trade or custody assets will need both the relevant AFSA authorization and the national mining license.

AFSA sets regulatory capital thresholds at the activity level. The two most common licensed activities for crypto businesses — operating a Digital Asset Trading Facility and acting as a Dealing in Investments as Agent — carry different base capital requirements. The table below sets out the confirmed figures from AFSA’s DAA Rules.

The $200,000 base for a Digital Asset Trading Facility is a hard floor — it is not a recommended amount or a guideline figure. If your 12-month projected working capital exceeds $200,000, AFSA requires you to hold that higher amount. In practice, for most trading platforms with meaningful operational costs, the working capital calculation will drive the actual requirement above $200,000.

Source: AFSA DAA Rules.

For operators of a Digital Asset Trading Facility, AFSA applies a dual test: your regulatory capital must equal the higher of the $200,000 base threshold or your projected working capital for the next 12 months. This is documented in the AFSA DAA Rules applicable to Digital Asset Trading Facility operators.

Several competitor guides state the operating capital period as six months. That is incorrect. The AFSA rule specifies 12 months of projected working capital, not six. This distinction matters materially when calculating how much capital you need to have ready before applying.

• Step 1 — calculate 12-month working capital: Add up all projected operational costs for the first year: staff salaries, office lease, technology and infrastructure, compliance costs, and professional fees.
• Step 2 — compare to the base: Take the higher of your Step 1 total or $200,000. That is your minimum regulatory capital.
• Step 3 — document it for AFSA: Your application must include a business plan with three-year financial projections. The working capital figure must be consistent with the projections you submit.

For a lean operation — a small team, a virtual AIFC office, and outsourced compliance — a realistic first-year cost base will typically fall between $200,000 and $350,000, meaning the base threshold and the working capital test often yield a similar result. For larger operations with multiple staff and a full in-house compliance function, the 12-month working capital figure will be the binding constraint.

Capital must be paid in and available at the time of licensing, not merely committed. AFSA reviews financial statements and may request evidence of available funds during the application review period, which typically runs two to three months. Source: AFSA DAA Rules.

AIFC operates its own company registry, separate from Kazakhstan’s national corporate law. When you incorporate inside the AIFC, you choose from AIFC entity types, not standard Kazakhstani forms. The AFSA public register shows that the Private Company is the predominant structure chosen by licensed crypto firms in the AIFC.

A Private Company in the AIFC carries no statutory minimum share capital for incorporation itself. However, once you apply for a digital asset licence, AFSA imposes capital thresholds tied to the activity type (for example, $200,000 base capital for a Digital Asset Trading Facility). Other AIFC entity types (such as a Limited Liability Partnership) exist and are eligible, but the Private Company structure fits most crypto business models and is the default recommendation.

AFSA designates certain roles as Approved Individuals and Designated Individuals, positions whose holders must pass a fit-and-proper assessment before the licence can be granted. For a digital asset firm, AFSA requires several controlled functions including Senior Executive Officer, Finance Officer, and (for trading facility operators) Chief Information Technology Officer. The two most commonly referenced Approved Individual roles are:

• Money Laundering Reporting Officer (MLRO) — responsible for AML/CFT compliance, reporting obligations, and the integrity of transaction monitoring under the AML Law No. 191-IV.
• Compliance Officer — oversees adherence to AFSA rules, internal governance frameworks, and regulatory reporting cycles.

AFSA permits smaller firms to combine the MLRO and Compliance Officer roles under a single individual; however, for larger or more complex operations such as a Digital Asset Trading Facility, AFSA may require these functions to be held by separate people from the outset. A Deputy MLRO must also be appointed to provide continuity in the MLRO’s absence. Directors and senior managers are also subject to fit-and-proper review, which assesses professional experience, financial probity, and absence of relevant criminal history.

AFSA requires a full application pack. Incomplete submissions are a common cause of delay; assembling documents in parallel with entity formation saves time. The core documents include:

• Business plan with 3-year financial projections — must cover revenue model, target markets, anticipated transaction volumes, and a projected profit-and-loss statement for years one through three.
• AML/KYC policies and procedures — a detailed written framework covering customer due diligence, enhanced due diligence triggers, transaction monitoring rules, and suspicious activity reporting procedures.
• Governance framework — board structure, management organogram, internal controls, conflict-of-interest policy, and delegation of authority document.
• Proof of capital — bank statements or audited accounts confirming the company meets the applicable minimum capital threshold for the intended activity.
• Fit-and-proper documentation for each Approved Individual and director — typically includes a curriculum vitae, criminal background check, credit history, professional references, and a personal questionnaire prescribed by AFSA.
• Technology and security description — an overview of the platform, custody arrangements, cybersecurity controls, and any third-party technology providers.
• Draft client agreements and terms of service — to demonstrate that customer-facing contractual documents align with AFSA conduct rules.

AFSA reviews applications on a rolling basis and may issue requests for additional information (RFIs) at any stage. Responding to RFIs promptly keeps you within the 2–3-month formal review window.

All AIFC participants must maintain a registered office within the AIFC territory in Astana. For crypto firms claiming tax exemptions, the Substantial Presence Rules additionally require real employees, operational expenses, and core income-generating activity inside the AIFC — effectively meaning a genuine physical workspace (either a dedicated office or a serviced desk within an AIFC-approved co-working facility), not just a registered address.

The AIFC occupies a defined zone within Astana (the former EXPO 2017 site). Office space in the AIFC hub is available from a range of providers at varying price points, and AFSA can refuse or revoke a licence if it finds that a firm’s stated address does not reflect actual substance. Applicants should budget for office costs from the point of company formation, since AFSA may conduct on-site visits as part of its authorisation review.

The Astana International Financial Centre offers a comprehensive set of tax exemptions to all AIFC participants engaged in financial services, including digital asset activities licensed by the AFSA. These exemptions are not administrative policies that can be reversed by a ministry decree — they are embedded in the Constitutional Statute “On the Astana International Financial Centre” and carry the force of constitutional law, which means ordinary legislation cannot override them.

• Corporate Income Tax (CIT): 0% — AIFC participants pay no CIT on income derived from financial services conducted within the AIFC framework. This applies to exchange fees, advisory income, custody fees, and related digital asset revenues.
• Value Added Tax (VAT): 0% — Services provided by AIFC participants in the course of regulated financial activities are exempt from Kazakhstani VAT. For crypto businesses dealing in high transaction volumes, this removal of a 12% cost layer matters operationally.
• Personal Income Tax (PIT): 0% — Foreign employees of AIFC participants are exempt from Kazakhstani personal income tax. This reduces the gross-up cost of attracting international compliance officers, developers, and senior managers.

All three exemptions are confirmed by the AIFC official tax benefits page and by the May 2020 Joint Order exempt activities list. The exemption period runs until 1 January 2066 — 50 years from the AIFC’s establishment in 2016. No comparable jurisdiction in Central Asia offers a tax guarantee of this duration backed by constitutional authority.

Crypto businesses that hold a national-level license issued outside the AIFC — or that conduct activities beyond the AIFC’s regulated perimeter — fall under Kazakhstan’s general tax code. The rates are set out by the Kazakhstani Tax Code and summarised by PwC’s Kazakhstan tax summary.

• Corporate Income Tax (CIT): 20% — The standard rate for most legal entities. From 1 January 2026, banks and gambling operators face an elevated rate of 25%; for crypto businesses the 20% rate remains applicable.
• Value Added Tax (VAT): 16% — Applied to taxable supplies made inside Kazakhstan. Crypto exchange and trading services outside the AIFC are generally subject to this rate unless a specific exemption applies.
• Personal Income Tax (PIT): 10% + 15% — A 10% flat rate applied to employment income of Kazakhstan-resident employees. Non-residents face a 15% withholding rate on Kazakh-source income. No blanket exemption exists for foreign staff outside the AIFC.
• Withholding Tax (WHT): 5–20% — Applicable to dividends, interest, royalties, and service fees paid to non-residents. The specific rate depends on the payment type and whether a double-tax treaty applies.

For a crypto exchange processing $10 million annually in fees, the difference between 0% and 20% CIT, plus 16% VAT on taxable supplies, is operationally decisive. The standard regime is not designed for high-volume financial services activity — it is the default for businesses that have not structured to use the AIFC framework.

The strongest argument for the AIFC tax regime is not the rate — it is the certainty. Most zero-tax jurisdictions rely on administrative decisions, ministerial rules, or ordinary legislation that can change with a budget cycle. The AIFC exemptions rest on a constitutional instrument. This matters for businesses making five- or ten-year investment decisions, for institutional investors conducting due diligence, and for boards that need to represent stable unit economics to shareholders.

No other jurisdiction in Central Asia — not Uzbekistan, Kyrgyzstan, or Georgia — offers a constitutionally-anchored tax exemption for crypto financial services running to 2066. The guarantee covers all three major business taxes simultaneously (CIT, VAT, PIT for foreign employees), removing the risk that one lever gets pulled while others remain in place.

The comparison table above reflects figures confirmed by the AIFC tax benefits page and PwC’s Kazakhstan corporate tax summary. For crypto businesses planning a Kazakhstan presence, the structural question is straightforward: licensing through the AIFC/AFSA framework secures the zero-tax position; operating outside it does not.

All entities licensed under the AIFC Digital Asset Activities framework must undergo an annual external audit. This is not discretionary — AFSA requires submission of audited financial statements prepared by an approved auditor. The audit must confirm that the firm maintains the required minimum capital (for a Digital Asset Trading Facility, that means the higher of $200,000 or 12 months’ working capital) and that client assets are properly segregated.

Beyond the audit, licensed firms have ongoing reporting obligations directly to AFSA:

• AML/CFT reports — periodic suspicious transaction reports and compliance monitoring summaries submitted to AFSA under Kazakhstan’s AML/CFT framework (Law No. 191-IV)
• Material change notifications — any change to key personnel (MLRO, compliance officer, directors), ownership structure, or business model requires prior AFSA notification or approval
• Regulatory returns — AFSA may require periodic prudential and operational data returns; the exact schedule depends on your license category
• Incident reporting — material operational failures, cybersecurity incidents, or significant client complaints must be reported promptly

The MLRO and compliance officer roles sit at the centre of all of this. AFSA requires these Approved Individual positions to be in place throughout the license lifecycle. Initially both roles may be filled by one person, but AFSA retains the right to require separation as the business scales.

An AFSA crypto license can be issued for up to five years, but most firms receive an initial term of two years. At the end of that term, you must apply for renewal — AFSA does not renew automatically.

Renewal is not a formality. AFSA will assess whether the firm has met its compliance obligations throughout the license period. A clean audit trail, up-to-date Approved Individual registrations, and a record of timely fee payments all feed into the renewal assessment. Firms that have had regulatory notices, unresolved complaints, or compliance gaps face a more intensive review.

Key renewal checkpoints to track from day one:

• Supervision fees paid on time — quarterly payments must not fall into arrears; AFSA can suspend authorisation for non-payment
• Approved Individuals current — if the MLRO or compliance officer changes during the license term, the new appointment must be approved before the previous holder departs
• Audited accounts filed — each annual audit must be submitted within the AFSA-specified deadline; late filing is a compliance breach recorded on your regulatory history
• Business plan still accurate — if the firm’s activities have expanded or changed materially since the original application, AFSA may treat renewal as a variation application requiring additional review

Budget for renewal costs well in advance. Application fees were amended effective 1 December 2025 and stand at approximately $75,000 for a new application; renewal fees are lower but not trivial. Confirm the current schedule on the AFSA regulated activities page before projecting costs.

AFSA’s enforcement toolkit runs from warnings through to full license revocation. The graduated response means that minor, promptly-corrected breaches rarely reach the most serious outcomes — but firms that ignore obligations or fail to engage with AFSA during an investigation face severe consequences.

• Public censure — AFSA can publish findings of non-compliance, with immediate reputational damage for a firm operating in a relationship-driven market
• Financial penalties — fines imposed directly on the entity or on responsible Approved Individuals
• License suspension — AFSA can suspend authorisation while an investigation is ongoing, effectively halting the firm’s regulated activities
• License revocation — the most serious outcome; a revoked license cannot simply be re-applied for — AFSA will scrutinise any future application from the same principals
• Approved Individual disqualification — the MLRO, compliance officer, or directors can be personally disqualified from holding regulated roles, not just within AIFC but potentially across other jurisdictions that recognise AFSA’s findings

The most common triggers for enforcement action are AML/CFT failures (inadequate customer due diligence, unreported suspicious transactions), failure to maintain minimum capital, and operating outside the scope of the granted license. The annual audit is AFSA’s primary mechanism for detecting all three.

On fees specifically: the annual supervision fee starts at $30,000 per year, paid in quarterly instalments, plus variable components depending on business volume. Missing a quarterly payment is not just a financial issue — it signals to AFSA that the firm may be under stress, and AFSA can move quickly to a suspension notice. Build the quarterly schedule into your treasury management from the day the license is issued.

Kazakhstan and Dubai share the most features of any pairing in the table. Both operate within English common law environments — Kazakhstan through the AIFC Court and Dubai through the DIFC or ADGM courts. Both offer 0% CIT within their respective free zones. And both quote 50-year tax incentive windows, though the mechanisms differ: Kazakhstan’s exemption is written into the Constitutional Law on the AIFC, locking the 0% CIT and VAT rates until 1 January 2066. Dubai’s free zone charters are renewable but not constitutionally entrenched in the same way.

The clearest difference is capital. Dubai’s VARA requires operators to hold at least AED 1,000,000 (~$272,000) in minimum capital, plus additional prudential buffers depending on the activity class. Kazakhstan’s AFSA sets the threshold at $200,000 for a Digital Asset Trading Facility, which is modestly lower. For firms that do not need Gulf market access, Kazakhstan reduces both the capital requirement and, typically, the ongoing supervision fees.

Neither jurisdiction offers EU passporting, so the choice between them depends on target markets, team preferences, and whether the operator values Kazakhstan’s constitutional tax guarantee over Dubai’s established international reputation.

Lithuania and Estonia were the go-to EU crypto jurisdictions before MiCA tightened requirements across the bloc. Both now operate under the EU’s Markets in Crypto-Assets framework, which means any VASP licensed there can passport into all 27 EU member states — a significant distribution advantage Kazakhstan cannot match.

Kazakhstan’s case against EU licensing is tax and capital. AIFC participants pay 0% CIT, 0% VAT on financial services, and 0% personal income tax for foreign employees, all guaranteed until 2066. By contrast, Lithuania charges 15% CIT on profits and Estonia defers tax but imposes 20% on any distribution. For a profitable exchange or brokerage, the difference in after-tax cash flows over a five-year horizon can exceed the cost of setting up a second legal entity in Kazakhstan entirely.

On capital, Kazakhstan’s $200,000 DATF requirement sits above Estonia’s €100,000 VASP floor but below what MiCA mandates for larger CASPs (Crypto-Asset Service Providers). For operators running lean, EU minimums look attractive on paper, but MiCA compliance costs — ongoing regulatory reporting, audit obligations, and legal fees for a 27-country passport — erode that advantage quickly.

The banks most frequently approached by AIFC crypto participants are Halyk Bank, Altyn Bank, and Eurasian Bank — all three have participated in AIFC pilot programmes and have existing relationships with the AIFC ecosystem. Halyk Bank is Kazakhstan’s largest retail and corporate bank and is the first port of call for most AIFC-registered firms; it has a dedicated corporate onboarding team familiar with AFSA-authorised businesses. Altyn Bank, a subsidiary of China CITIC Bank, provides access to yuan-denominated correspondent banking alongside standard KZT and USD accounts. Eurasian Bank has positioned itself as accommodating to fintech and digital asset businesses, though its compliance process is equally thorough. Kaspi Bank — while dominant in consumer payments — focuses on its proprietary ecosystem and does not routinely serve corporate crypto clients.

The account opening process for an AIFC crypto firm typically runs four to eight weeks from first contact to an active account, assuming your documentation is complete. Banks will request your AFSA licence or authorisation-in-principle letter, AIFC certificate of incorporation, beneficial ownership register, AML/KYC policy documentation, a description of your business model and expected transaction flows, and passport copies with source-of-funds declarations for each ultimate beneficial owner. Banks apply enhanced due diligence to crypto businesses regardless of licensing status, so gaps in your compliance documentation are the single most common reason for rejection or prolonged delays.

One structural challenge is that Kazakhstani banks primarily operate in Kazakhstani Tenge (KZT), and their USD and EUR correspondent banking relationships can be limited. If your business model requires holding or moving significant volumes in USD or EUR — for example, to fund capital requirements or pay international vendors — you may need to combine a domestic KZT account with a supplementary account at a payment institution outside Kazakhstan. Several European Electronic Money Institutions (EMIs) accept AIFC-licensed crypto businesses as clients, provided you can demonstrate active AFSA authorisation and a clean compliance record. These EMI accounts are not a substitute for a domestic bank account (AFSA may require evidence of a Kazakhstani banking relationship as part of your ongoing supervision), but they function well for cross-border settlement and multi-currency treasury management.

For firms that handle crypto-to-fiat conversion directly, it is worth noting that AFSA-licensed entities are permitted to process digital asset transactions within the AIFC framework under the Law “On Digital Assets” No. 193-VII. The banking layer covers fiat movement only; your crypto custody and settlement infrastructure sits separately, typically with a qualified custodian or under a self-custody arrangement that you describe to AFSA in your technology documentation. Banks do not custody your crypto — they manage the fiat side of the business. For details on how AIFC tax exemptions interact with your banking structure, see the taxation section above.

If domestic banking proves difficult in the short term, payment aggregators and crypto-native banking partners operating under EU or offshore licences can bridge the gap for operational expenses. However, treat these as interim solutions: AFSA expects licensed firms to maintain demonstrable banking relationships commensurate with their activity level, and relying solely on personal accounts or informal payment channels is a compliance risk that can trigger a supervisory inquiry.