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Legal services

Service offering

AIFC licence for money services

Obtain an AIFC licence for money services

Providing Money Services in the AIFC

A comprehensive service for preparing the company, documents, and application to obtain an AIFC licence for money services.

The service is suitable for payment and settlement projects considering the AIFC as their core regulated jurisdiction.

Obtaining an AIFC licence for money services is relevant for teams that want to build a payment or payment-like service in the AIFC and understand in advance whether their product fits within the local regulated activity framework, how roles are distributed between the licensed company, group entities, and external providers, and what requirements will arise not only at the authorisation stage but also after launch. This is especially important in the AIFC now, because the framework for providing money services is actively developing and requires very careful attention to the actual functions of the business.

This service is especially useful for payment startups, cross-border solutions, corporate payments, e-wallet/stored value models, B2B infrastructure projects, and digital asset-related flows that view the AIFC as a standalone regulated jurisdiction. In practice, it is necessary not merely to understand whether the AIFC is suitable, but to structure the business so that the licensing story matches the product, the contractual chain, and the system of controls.

The most common mistake is trying to treat authorisation separately from the operating model. For money services, what matters is not only product statements, but also who exactly issues payment instruments or stored value, who executes transfers, how relationships with users and counterparties are documented, how client-funds-protection-like control mechanisms are structured, and how incident management, corporate governance, and outsourcing are organised.

That is why the legal service here acts as a design tool. It helps determine the correct regulatory perimeter in advance and remove from the model anything that would later create questions from the AFSA, a bank, or a technology partner.

Who this service is especially suitable for

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

Financial and crypto projects that need a licensed model specifically within the AIFC - 95%

This offering is aimed at companies that want to operate in the "AIFC and Kazakhstan" environment and already understand their product: a payment service, digital asset platform, crowdfunding platform, or custody model. For them, it is especially important to align the actual business functions in advance with the permitted activities under AFSA.

Groups that need to align corporate structure, management, and future authorisation - 87%

If a holding group first creates the company and only then separately thinks about the licence, there is almost always a gap between corporate architecture, management responsibilities, contractors, and the regulator’s expectations. The service helps assemble this as a single project rather than as a set of disconnected steps.

Heads of legal, operations, and product functions - 82%

This block is especially useful for those who need to turn an idea into a package of application materials, procedures, agreements, and internal rules, and also handle questions from a bank, investor, or regulator. They need not a general overview, but a very clear distribution of roles, control functions, and next actions.

Investors and shareholders who need a verifiable and scalable model - 77%

When a project is being built not for a short test, but for growth and capital raising, it is important to have a structure that can be explained to an investor, auditor, and regulator without internal contradictions. That is why the service is valuable not only for launch, but also for future transactions.

Why this offering is often especially timely

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

When the service is especially useful

The service line "AIFC licence for money services" 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 usually becomes the first point of analysis

At the start of the service line "AIFC licence for money services," the analysis usually focuses on the money services regulatory perimeter, real presence, management, outsourcing, IT contour, and policies. 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 late legal analysis is risky

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 money services," a typical mistake is entering the AIFC with a general presentation but without a provable operating model. After live launch, such mistakes affect not just one document, but the customer journey, support, contractor agreements, and internal controls.

What should remain with the team after the project

The practical result of the service "AIFC licence for money services" 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 money services
  • 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 money services 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 money services
  • 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 money services
  • 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 a separate regulated activity framework for Providing Money Services. According to the official description, this includes, without limitation, providing currency exchange, selling or issuing payment instruments, selling or issuing stored value, and execution of payment transactions. In 2025–2026, the AFSA also separately updated the framework on Providing Money Services, including phased entry into force of new requirements.

    For the service "Obtaining an AIFC licence for money services," this means that the legal analysis must rely on the specific functions of the business rather than only on the marketing description of the product. It is necessary to understand exactly which money services the project provides, how they are documented contractually and technologically, which control functions are required internally, and which dependencies arise from external providers and related entities.

    Which risks proper legal preparation addresses

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

    Misalignment between website, contracts, and operations

    For the service "AIFC licence for money services," the basic risk is building the model on an incorrect qualification of the actual activity. If the team has not analysed the money services regulatory perimeter, real presence, management, outsourcing, IT contour, and policies, it can easily mistake the marketing name of the service for legal reality and start moving in the wrong direction in the AIFC.

    Misalignment between website, contracts, and operations

    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 money services" almost always leads to unnecessary questions during due diligence, bank review, or the authorisation process in the AIFC.

    Costly rework after launch

    A separate risk under the service "AIFC licence for money services" 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 the money services regulatory perimeter, real presence, management, outsourcing, IT contour, and policies.

    Weak dependency management and control

    The most expensive mistake for "AIFC licence for money services" is postponing legal restructuring until a late stage. Once it becomes clear that the company entered the AIFC with a general presentation but without a provable operating model, 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 a practical AIFC model for obtaining an AIFC licence for money services, a set of key assumptions for authorisation, and a preparation roadmap. This helps structure dialogue with the AFSA and counterparties in the language of specific functions rather than general promises.

    For the business, this also reduces the risk of late rework. When the regulatory perimeter and control framework are defined in advance, it becomes easier to plan the development backlog, staffing, budget, banking route, and later expansion of the service range.

    After this preparation, the team receives a working model for launch in the AIFC rather than just a list of documents. This simplifies negotiations with banks, payment partners, vendors, and investors because the project gains a clear explanation of its role, range of services, and governance structure.

    The second important value is the ability to move in stages. Good scoping shows which functions can be launched immediately, which are better left to the next phase, and where product design should be adjusted before filing in order to avoid unnecessary questions about the authorisation perimeter.

    As a result, the service line "Obtaining an AIFC licence for money services" helps build an AIFC operation as a manageable business project rather than as a set of assumptions about what the regulator “should allow.”

    Frequently asked questions

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

    When is the best time to start this work?

    It is better to engage before filing, before signing key agreements, and before public scaling of the product. For the service "AIFC licence for money services," 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 just one stage be handled as a separate project?

    Yes, for the service line "AIFC licence for money services," 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 the money services regulatory perimeter, real presence, management, outsourcing, IT contour, and policies. 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 money services," this gap is usually the most expensive because it affects partners, the team, and ongoing compliance in the AIFC.

    How do you tell whether the service has been delivered well?

    A good result for the service "AIFC licence for money services" 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.