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Legal services

Service offering

AIFC licence for a digital asset trading facility

Obtain an AIFC licence for a digital asset trading facility

A digital asset trading venue in the AIFC

A comprehensive service for preparing the company, documents, and application to obtain an AIFC licence for a digital asset trading facility.

The service is suitable for projects that want to organise a regulated digital asset trading venue in the AIFC.

Obtaining an AIFC licence for a digital asset trading facility is relevant for projects that want to launch a trading venue or similar digital asset infrastructure in the AIFC and understand that a general crypto memorandum is not enough here. This type of model simultaneously affects product design, market structure, custody logic, onboarding, market abuse concerns, corporate governance, and interaction with liquidity providers, customers, and technology contractors.

Usually, exchange-like projects, broker platforms, token market infrastructure projects, groups seeking an AFSA licensing base to work with digital assets, and teams that already have a technology product but have not yet checked how it fits into the AIFC digital assets framework come for this service. In such projects, it is especially risky to first build the listing, trading logic, and client interface, and only then discover that the licensed role of the venue operator has been described incorrectly.

The practical value of the service lies in determining the scope of regulated activity, the architecture of flows, the limits of permissible outsourcing, the requirements for internal control, management, disclosures, and how the company will explain its model to the regulator and the market. This is the foundation not only for authorisation, but also for a sustainable live launch.

The earlier a team connects technology, operations, and law, the lower the risk that already developed exchange logic, user screens, listing materials, and counterparty agreements will turn out to be inconsistent with the AIFC regulatory regime.

Who this service is especially suitable for

Which companies, roles and tasks this work usually brings the greatest practical value to

Crypto projects that actually custody, exchange, transfer, or otherwise service clients’ digital assets - 96%

This offering is most useful for companies whose model has already moved beyond a simple showcase or software development and includes exchange, custody, transfer of digital assets, execution of client instructions, or other sensitive activity in the "AIFC and Kazakhstan" environment. For them, precise qualification of the model is critical from the start.

Teams launching an exchange, custody service, brokerage, or OTC model - 90%

If the project is already building its product around trading, asset custody, work with fiat, commissions, counterparties, and user onboarding, it does not need a general overview, but rather a link between the licence, internal policies, website, contractual chain, and AML/KYC.

Holdings and investors selecting a jurisdiction for a crypto business line - 82%

The service is suitable for international groups comparing several countries and wanting to assess requirements for management, capital, real presence, risk control, and banking relationships. This helps avoid overpaying for a jurisdiction that looks convenient only at the marketing level.

In-house legal teams and compliance leaders assembling a defensible model without hidden gaps - 85%

If you are responsible for ensuring that agreements, AML/KYC, asset custody rules, customer disclosures, incident handling procedures, and the company’s actual role all align with one another, this block is addressed to you as well. This kind of assembly is what later determines how smoothly the project passes partner and regulatory review.

Why this offering is often especially timely

At which project stages the service has the greatest effect and what it helps fix in advance

At what stage this service provides the most value

The service line "AIFC licence for a digital asset trading facility" is especially useful for teams that already understand the product and commercial objective in the AIFC but have not yet fixed the final legal architecture. At this stage, the company structure, contract logic, website, onboarding, and sequence of work with the regulator or key partners can still be adjusted without unnecessary cost.

What is reviewed first

At the start of the service line "AIFC licence for a digital asset trading facility," the analysis usually focuses on trading rules, listing/admission standards, custody dependencies, corporate governance, and incident management. The purpose of this review is to separate the company’s real activity from how the service is described on the website, in the presentation, and in the team’s internal expectations. This is exactly where it becomes visible which part of the model is legally defensible and which part requires redesign before filing or launch.

Why this work should not be postponed

Late legal analysis is expensive because the business has already tied the product, marketing, and commercial agreements to an assumption that may turn out to be wrong. For "AIFC licence for a digital asset trading facility," a typical mistake is trying to license a polished exchange interface without formalised venue rules. After live launch, such mistakes affect not just one document, but the customer journey, support, contractor agreements, and internal controls.

What the service provides beyond formal documents

The practical result of the service "AIFC licence for a digital asset trading facility" is not an abstract folder of texts, but a working structure for the next stage: a clear roadmap, priorities for documents and procedures, a list of weak points in the model, and a stronger position in negotiations with a bank, regulator, investor, or infrastructure partner.

What is included in the service

The scope of work, documents and stages of support

01

Corporate structure and preliminary requirements

  • Review of the initial corporate structure and project participant composition for obtaining an AIFC licence for a digital asset trading facility
  • Recommendations on jurisdiction of incorporation, governing bodies, capital, office, and key functions

  • 02

    Legal analysis of the business model

  • Legal analysis of the model, services, customer flows, and payment or investment infrastructure for the AIFC digital asset trading facility licence project
  • Determination of the regulatory perimeter, restrictions, and adjacent authorisations that may be required for the project

  • 03

    Licensing plan and roadmap

  • Preparation of a step-by-step launch and approval plan for obtaining an AIFC licence for a digital asset trading facility
  • Definition of the document set, timelines, roles, and external providers

  • 04

    Business plan and financial model

  • Preparation or refinement of the business plan, financial forecast, growth scenarios, and operating model
  • Description of the organisational structure, control functions, IT landscape, and outsourcing

  • 05

    AML/KYC and internal control

  • Development or adaptation of the AML/KYC approach, customer onboarding, monitoring, and escalation procedures
  • Formation of the compliance model, risk management, internal audit, and reporting

  • 06

    Internal policies and procedures

  • Preparation of internal regulations, approval procedures, reporting, incident management, and business continuity procedures
  • Documentation of corporate governance, conflicts of interest, information security, and access control

  • 07

    Documents for customers and partners

  • Preparation of user terms, disclosures, privacy documents, and agreements with technology and financial partners
  • Adaptation of documents for B2B, B2C, marketplace, or white-label models

  • 08

    Application preparation and submission

  • Collection, completion, and final review of the document package for obtaining an AIFC licence for a digital asset trading facility
  • Preparation of the package for approval of management, beneficial owners, and other persons before the regulator

  • 09

    Communication with the regulator and partners

  • Support with responses to regulator requests and coordination of comments on the application
  • Support in negotiations with the bank, EMI, processing provider, acquiring, custody, issuance, or other infrastructure partners

  • 10

    Launch and post-licensing readiness

  • Preparation of the project for the start of operations, reporting, and internal control after approval
  • Recommendations on ongoing compliance support, document updates, and expansion of the model

  • Regulatory and legal framework

    Which rules and requirements usually determine the content of the service

    Legal framework. The AFSA publishes separate regulated activities related to digital assets, including Operating a Digital Asset Trading Facility. For such projects, the analysis usually covers not only the application itself, but also interaction with the rules on digital asset activities, corporate governance, conduct, outsourcing, custody arrangements, and internal controls.

    For the service line "Obtaining an AIFC licence for a digital asset trading facility," it is important to describe exactly which functions the platform performs: admission of assets, trading logic, participant access, interaction with client assets, relationships with liquidity providers, and the connection to payment rails. This affects both the content of the documents and the architecture of the control framework.

    Which risks proper legal preparation addresses

    Typical mistakes because of which projects lose time, money and partners

    Costly rework after launch

    For the service "AIFC licence for a digital asset trading facility," the basic risk is building the model on an incorrect qualification of the actual activity. If the team has not analysed trading rules, listing/admission standards, custody dependencies, corporate governance, and incident management, it can easily mistake the marketing name of the service for legal reality and start moving in the wrong direction in the AIFC.

    Incorrect qualification of the actual model

    Even a strong product looks weak if the website, public promises, Terms of Service, internal procedures, and agreements with partners describe different roles of the company. In that condition, "AIFC licence for a digital asset trading facility" almost always leads to unnecessary questions during due diligence, bank review, or the authorisation process in the AIFC.

    Misalignment between website, contracts, and operations

    A separate risk under the service "AIFC licence for a digital asset trading facility" arises at points of dependency on counterparties and internal control. If the project does not determine in advance who is responsible for critical functions, how procedures are updated, and where the provider’s responsibility ends, it remains vulnerable precisely in the areas that make up trading rules, listing/admission standards, custody dependencies, corporate governance, and incident management.

    Misalignment between website, contracts, and operations

    The most expensive mistake for "AIFC licence for a digital asset trading facility" is postponing legal restructuring until a late stage. Once it becomes clear that the company tried to license a polished exchange interface without formalised venue rules, it ends up rewriting not only documents, but also the customer journey, product texts, support scripts, onboarding, and sometimes even the corporate structure in the AIFC.

    What result the business receives

    What can be done next after the service is completed

    What the business receives in the end. The company receives the legal and operational foundation for obtaining an AIFC licence for a digital asset trading facility in the AIFC: a clear regulatory perimeter, a set of key documents, and a list of issues that need to be resolved before authorisation and launch. This helps avoid building market infrastructure on assumptions that would later be expensive to correct.

    In practical terms, this accelerates communication with the AFSA, banks, custody partners, and investors because the company can consistently explain how exactly the venue is structured and which control and governance mechanisms are built into it.

    A well-prepared digital asset trading facility model remains useful after licensing as well. It helps organise internal processes, separate management and control functions, and structure relationships more precisely with liquidity providers, custody partners, vendors, and clients. For regulated market infrastructure, this is critical: a weak regulatory perimeter quickly shows up in operational incidents and reputational risk.

    For founders and investors, such preparation also provides management clarity. It becomes clear which functions are core regulated activities, where additional resources will be required, which dependencies on external providers are most sensitive, and what exactly should be presented to the market as licensed scope and what should not.

    The result of the work under the service "Obtaining an AIFC licence for a digital asset trading facility" should be real trading infrastructure compatible with the AIFC framework, not a formal set of texts prepared only for filing.

    Frequently asked questions

    Short answers to practical questions about the service scope and its result

    Can you engage if the project is not yet fully structured?

    It is better to engage before filing, before signing key agreements, and before public scaling of the product. For the service "AIFC licence for a digital asset trading facility," this is especially important in the AIFC because early scoping allows the structure and documents to be changed without cascading rework of the website, onboarding, the contract chain, and relationships with counterparties.

    Can the service be limited to only one part?

    Yes, for the service line "AIFC licence for a digital asset trading facility," the work can be split into a memorandum, roadmap, document package, filing support, or review of a specific agreement. But before that, it is useful to briefly check trading rules, listing/admission standards, custody dependencies, corporate governance, and incident management. Otherwise, you may end up ordering a fragment that does not eliminate the main risk for this model in the AIFC.

    What most often causes timing to slip?

    Most often, a project is delayed not by one form or one regulator, but by the gap between the product, customer-facing texts, contractual logic, internal procedures, and the company’s real role. For "AIFC licence for a digital asset trading facility," this gap is usually the most expensive because it affects partners, the team, and ongoing compliance in the AIFC.

    What is considered a good result for such a service?

    A good result for the service "AIFC licence for a digital asset trading facility" is when the business has a defensible and clear model for the next steps: which functions are permitted, which documents and procedures are mandatory, what needs to be corrected before launch, and how to speak about the project with a bank, regulator, investor, or technology partner without internal ambiguity in the AIFC.