As the financial world embraces digital transformation and cross-border payments, Kazakhstan’s Astana International Financial Centre (AIFC) has emerged as a gateway to Central Asia and the Eurasian Economic Union. Operating under a common law framework and offering a competitive tax and regulatory environment, the AIFC is increasingly attractive to payment service providers, e-money issuers, and digital remittance platforms.

At Zitadelle AG, we support fintech companies, virtual currency service providers, and payment institutions with end-to-end solutions for licensing under the AIFC regime—specifically for money services businesses (MSBs).

What Is a Money Services Business in the AIFC?

A Money Services Business (MSB) operating under the AIFC/AFSA framework may include:

• Currency exchange services

• Issuance and sale of stored value (e-money)

• Money remittance and transfer services

• Payment execution through cards or telecom channels

• Issuing payment instruments such as prepaid cards

These activities are classified as Regulated Activities under the AIFC Financial Services Framework and require proper licensing from the Astana Financial Services Authority (AFSA or AIFC).

How Zitadelle AG Supports Your AIFC MSB License Application

Whether you're launching a startup or expanding your payment footprint into Central Asia, Zitadelle AG provides comprehensive assistance throughout the entire licensing journey:

1. Regulatory Feasibility & Licensing Strategy

We begin by assessing your business model to determine if your services qualify for MSB licensing under AIFC rules. Based on this, we design a licensing roadmap aligned with AFSA's expectations.

2. Incorporation in the AIFC

Zitadelle AG assists with incorporating your legal entity within the AIFC, including name reservation, registration with the Registrar of Companies, and digital residency setup.

3. Preparation of Core Documents

Our team drafts or reviews all required documents, including:

• Detailed business plan

• Financial projections (3-year forecast)

• AML/CFT policy and risk assessment

• Internal governance structure

• Client onboarding and due diligence policies

• IT and cybersecurity frameworks

4. Appointment of Approved Individuals

We help you identify and appoint qualified personnel for roles such as:

• CEO or Managing Director

• Compliance Officer

• Money Laundering Reporting Officer (MLRO)

• Risk and IT Officers (where applicable)

We also assist in preparing and submitting Fit & Proper declarations and CVs for AFSA review.

5. Portal-Based Application Support

Zitadelle AG manages the end-to-end online application process via the AFSA Digital Portal, ensuring timely submission of:

• Authorization forms

• Supporting documents

• Ownership charts and shareholding declarations

• Policies, agreements, and manuals

6. Liaison With AFSA

We act as your liaison with the AFSA, responding to follow-up queries and clarifying regulatory expectations during the review process. Our compliance-first approach reduces delays and increases approval success rates.

7. Post-Licensing Compliance & Operations

Once licensed, Zitadelle AG can assist with:

• Ongoing compliance monitoring and AML audits

• Annual filings and financial reporting

• Staff training on AIFC AML/CFT and reporting obligations

• Assistance with local partnerships and banking solutions

AML/CFT Requirements

• Must comply with both Kazakhstan’s AML Law and AIFC AML/CFT Rules

• Setup robust governance:

  • MLRO (an Approved Individual; resident in Kazakhstan)

  • KYC/CDD, transaction monitoring, screening employees

  • Ongoing due diligence and AML audit (internal or external at least every two years)

• Record retention: all KYC, STRs/TTRs, transaction logs → for at least six years

• No cash-intensive operations permitted

Application Documentation

You’ll need to submit:

• Completed application & approved individual forms

• Financial projections (3-year)

• Fit & Proper questionnaires for controllers

• Organizational documents (inclusion of parent/head office)

• CVs for Board & controllers; ownership charts

• Audited accounts (if available)

• Shareholders' agreements, onboarding evidence (for start-ups)

• Standard client agreements and policy framework

Organizational & Governance Requirements

• Must appoint: Board of Directors; Approved/Designated Individuals (e.g. CEO, CFO, Compliance Officer, MLRO + Deputy)

• Must establish committees (e.g., Risk, Compliance)

N.B. - it is expected that at least one director and at least one member of the compliance/ aml department is a resident of Kazakhstan

Why Choose AIFC for Your Payment or E-Money Business?

• Common law-based legal framework

• 0% corporate and personal tax (until 2066 for AIFC entities)

• 100% foreign ownership permitted

• Flexible currency and capital flow regime

• Strategic location bridging Europe, Asia, and the Middle East

Partner With Zitadelle AG for Your AIFC Licensing Needs

With years of experience in regulatory consulting across fintech, crypto, and payment sectors, Zitadelle AG is ideally positioned to help you navigate the AIFC landscape.

Our presence in key financial hubs, including Labuan, Cyprus, and Mauritius, gives us a global edge—allowing your business to launch confidently and compliantly in Kazakhstan.

Contact Us Today

Whether you’re exploring the AIFC for the first time or ready to begin your license application, contact Zitadelle AG for a confidential consultation: