Investment licenses in the Astana International Financial Centre of Kazakhstan.

Nikita Veremeev

15.02.2026 | 6 min read

Updated: 15.02.2026

I often start a conversation with entrepreneurs with a simple question: *what is your goal in choosing a new jurisdiction for an investment business*? The answer almost always comes down to a combination of three factors: regulatory predictability, access to capital, and operational efficiency. In recent years Astana International Financial Centre (AIFC) has become one of the few hubs where the balance of these factors works to the benefit of both international and regional players. During this time the COREDO team has carried out dozens of projects for legal entity registration, obtaining investment licenses, building an AML function, and launching funds within the AIFC.

In this article I organize COREDO’s practice: how the registration of a legal entity in the AIFC is carried out, which licenses are available, what the capital and substance requirements look like, what is important to know about the AIFC’s AML and KYC requirements, and how to strategically assess the ROI of operating through the AIFC. The text is aimed at entrepreneurs and finance directors who value concreteness and clear steps without unnecessary theory. My goal – that you leave the article with a clear plan and an understanding of whether an AIFC license suits your business model.

AIFC legal framework: the role of AFSA

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The AIFC uses a separate “AIFC legal framework” based on common law principles, with its own court, the AIFC Court, and an independent regulator, the Astana Financial Services Authority (AFSA). This provides predictability and dispute-resolution principles close to the English tradition, which is important for high-stakes and cross-border transactions. In my practice, this often reduces legal frictions between investors and managers, especially when structures from the EU and the United Kingdom are involved.

AFSA regulates activities by means of a Rulebook – a detailed code of rules similar in logic to European and Middle Eastern standards. In spirit, the requirements are close to MiFID II: investor protection, management of conflicts of interest, risk disclosure and adequate capital requirements and management systems. At the same time, the AIFC allows reasonable proportionality: early-stage projects and niche strategies have flexibility provided there is an evidential basis of robust risk management.

COREDO’s practice confirms that when preparing for licensing in the AIFC a “European” approach helps: product regulations, clear client categorization, documented suitability/appropriateness and transparent fees. At the same time AFSA expects all of this to be implemented into the actual operational environment – a single paper policy is not enough.

Which licenses are in the AIFC?

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Investment licenses in Kazakhstan through the AIFC cover a wide range of activities, and correctly mapping a business model to the permitted types of activity saves months at the approval stage. Within the AIFC, available in particular are AIFC broker license (broker/dealer), the AIFC asset manager license (portfolio manager/asset manager), the investment adviser license, as well as the AIFC depository and custodian license. For fund activity, collective investment schemes (CIS) are provided, including closed structures for private equity and an investment fund license in the AIFC.

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Over the past two years we have observed strong demand for the AIFC private equity license and the AIFC venture fund license. Such structures are convenient for cross-border capital raising, and for working with investors familiar with common law. A separate vector is the AIFC license for digital asset operations: under it custody solutions, crypto exchanges and tokenization services develop while complying with requirements for storage technologies and cybersecurity.

For non-residents, the AIFC provides an investment license, and this is a real tool for accessing regional markets while minimizing legal conflicts. Our experience at COREDO has shown that a well-designed combination of an SPV in the AIFC and an operational core in another jurisdiction helps to flexibly allocate functions while maintaining compliance with AFSA regulatory standards.

Capital, substance and fit and proper

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Capital requirements for an AIFC license depend on the type of activity and the risk profile. By the typical ranges we encounter in projects, broker-dealer licenses sit at the top of the scale, while advisory and non-custodial management are lower. Capital adequacy for asset managers includes a fixed base amount and add-ons for operational risk and assets under management. I always recommend planning a “buffer” above the minimum level to smooth seasonal fluctuations and growth-related costs.

Economic presence (substance) at the AIFC: more than a nameplate on the door. AFSA expects a real team: at least one executive director resident in the AIFC, a competent head of compliance/AML, and, where appropriate, risk management and internal audit functions. In COREDO projects we include a responsibility matrix and job descriptions at the submission stage to pass the fit and proper checks for AIFC directors and senior management without delays.

Fit and proper test for directors and senior managers at the AIFC covers experience, qualifications, reputation and compliance history. Background checks include certificates of no criminal record, verification of education, previous roles and references. I honestly warn clients: it’s better to identify and work through “grey areas” in advance than to explain them to AFSA at a late stage.

AML and KYC in the AIFC: technologies and control

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AML and KYC requirements of the AIFC are based on the recommendations of FATF and integrate a risk-based approach. In practice this means an individual AML risk assessment for investment firms, client segmentation by geography and profile, as well as documentation of sources of funds. The solution developed at COREDO typically includes a risk matrix, playbooks for onboarding and instructions on procedures for detecting suspicious transactions (STR).

Modern KYC/eKYC technologies for the AIFC simplify remote onboarding, but AFSA pays attention to the quality of PEP and sanctions screening and to periodic review. We implement a transaction monitoring and AML screening system taking into account the business model profile, including scenario settings, trigger thresholds and an escalation procedure. A separate register of beneficial owners and beneficial owner verification in the AIFC are developed to resolve questions about ownership structures before submission.

A compliance policy for an investment firm in the AIFC should describe procedures for managing conflicts of interest, product acceptability, as well as whistleblowing channels. At AFSA audits, not only documents are valued but also implementation artifacts: monitoring logs, committee reports, and AML training for staff. COREDO’s practice confirms that a mature AML framework speeds up both Licensing and subsequent reviews.

Timelines and steps for registering a legal entity in the AIFC

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The registration of a legal entity in the AIFC starts with choosing a form: from ordinary companies to special SPVs. Registration is carried out through the electronic portal, and the basic timeframe with a properly prepared package takes from several working days to a couple of weeks. We agree names, types of activity and constitutional provisions in advance so as not to return to the amendment stage.

SPV structures and trusts in the AIFC are convenient for asset transactions, securitization or incorporating a holding level. For funds, fund registration procedures in the AIFC apply, including submitting fund rules, disclosing valuation policy and selecting a depositary/custodian. Economic presence is established through an office, local directors and key functions, which is reflected in subsequent tax and regulatory aspects.

In COREDO projects we prepare a corporate governance package: board provisions, audit and risk committees, a senior manager regime with role demarcation. This reduces AFSA queries and facilitates the integration of external and internal audit under IFRS.

Licensing of investment activities, timelines and costs

Obtaining an investment license in the AIFC begins with an accurate description of the business model and the selection of the appropriate “regulated activities”. This determines the set of policies, capital requirements and staff profile. At the pre-application stage the COREDO team conducts a gap analysis against the AIFC Rulebook, develops a roadmap and agrees key parameters with AFSA to avoid incorrect classification.

The timelines and cost of obtaining an AIFC license depend on the complexity of the model and the applicant’s readiness. In our experience, the advisory and regulatory phase takes 8 to 16 weeks for ‘clean’ models, while more complex combinations involving custody and dealing require 4–6 months. The cost consists of AFSA fees, legal and compliance preparation, technological solutions and hiring of key persons, as well as future ongoing compliance costs.

Preparation for an AFSA inspection (AIFC regulator) includes interviews with directors, demonstration of operational systems, testing of compliance controls and a walkthrough of the client journey. I always recommend conducting a pre-inspection simulation – in a risk-free mode we identify ‘bottlenecks’ and fix them before contacting the regulator.

CIS and SPV Fund Structures: Disclosure

For investment funds in the AIFC, open and closed collective investment schemes (CIS) are available; private placements and public offers in the AIFC are subject to different regimes. Preparing a prospectus and disclosure in the AIFC requires a description of the strategy, risks, fees and valuation procedures, as well as prospectus requirements for key metrics. Our clients value structuring SPVs and trust solutions for individual transactions when it is necessary to flexibly separate classes of assets or investors.

Depositary and custodian requirements place particular emphasis on independence, accounting systems and asset storage technologies. Agreements with depositaries and service providers must clearly record SLAs, liability and escalation procedures. We conduct Due Diligence on providers in advance so AFSA sees a considered selection of counterparties, not a formal one.

For closed funds pursuing private equity and venture strategies the regulatory framework remains pragmatic if governance and risk management correspond to the scale of the portfolio. Investment committees, clear management of conflicts of interest and external audit are not just a checklist but a prerequisite for LPs’ trust.

Taxes in the AIFC: incentives, transfer pricing

tax incentives and AIFC stimuli often become a decisive factor. The AIFC provides regimes that reduce the tax burden on certain types of income, as well as simplification mechanisms where there is economic presence. At the same time it is important to align tax residency and certificates in order to use Kazakhstan’s double tax avoidance agreements and correctly process payments to investors.

Transfer pricing and documentation require attention if you have a cross-border chain of services or IP. The COREDO team develops a transfer pricing policy and a supporting file with functional analysis so that regulatory and tax audits go through without surprises. Reporting under IFRS and external auditors close the loop of trust and transparency.

Taxation of investment companies’ income in the AIFC should be considered together with the profit allocation model at the fund, management company and investor levels. Smart structuring of flows reduces friction costs and simplifies subsequent exit decisions.

Digital assets: tokenization and custody

Regulation of digital assets and tokenization in the AIFC is evolving through specialized AFSA regimes and the regulatory sandbox. Licensing of crypto exchanges and custody is built around storage technologies, cybersecurity and resilience to operational disruptions. In COREDO projects we pay particular attention to custody technologies for digital assets, segregation of client funds and access recovery processes.

Smart contracts and the legal status of tokens are analyzed in every case: tokenized fund shares, debt instruments or utility models fall under different parts of the Rulebook. I recommend starting with the legal qualification of the token and only after that choosing the technology stack. The AIFC license for digital asset operations opens doors to new sources of liquidity, but requires mature risk management.

KYC/eKYC and PEP/sanctions screening in “crypto” models are especially important: monitoring scenarios and triggers for STR should take into account volatility and address behavior. COREDO’s practice confirms that “compliance-by-design” reduces the cost of holding a license as you scale.

Clearing, custody and partner banks

Capital market infrastructure and clearing at the AIFC are developing in tandem with regional operators and international providers. Partner banks and custodians in Kazakhstan provide access to settlement and safekeeping of assets, and the clearing and settlement infrastructure at the AIFC is integrated with global standards. During the due diligence stage we assess connection architecture, contingency scenarios and software interfaces.

Agreements with depositories and service providers set out procedures for corporate actions, corporate voting and dispute resolution. Requirements differ for retail and institutional segments, and this must be taken into account when developing compliance policies. As a result, the regulator builds confidence in the operational quality of your platform.

For broker-dealer licenses, issues of secondary market liquidity and market-making are important. We select models in which the risk profile aligns with capital and insurance measures, and a disclosure policy addresses questions from clients and AFSA.

Scaling cross-border capital

Cross-border capital raising through the AIFC relies on clear fund marketing rules and AIFC advertising regulations. Passporting and cross-border services restrictions require separate strategies for the EU, the UK, Singapore, and the Middle East. I recommend building marketing funnels that take local private placement regimes into account and using flexible side-letter structures for institutions.

ROI assessment when operating through the AIFC should include NPV, IRR and payback period approaches, as well as profitability metrics for investment platforms: investor CAC, commission LTV, LP churn and compliance operational KPIs. Scaling an investment business through the AIFC becomes predictable when your KPIs are tied to regulatory metrics, onboarding time, share of alerts, and incident closure speed.

Marketing without transparency regarding complaints and suitability leads to regulatory and reputational risk at the AIFC. Therefore I insist on balancing growth with quality control, supported by regular reporting to the board and committees.

Risk Management and Compliance System

Management of operational and regulatory risks in the AIFC is built around three lines of defense: business, risk/compliance and internal audit. Investor protection and compliance measures become part of the culture rather than a separate department. In COREDO solutions we configure conflicts of interest management, outsourcing compliance and third-party risk management, covering the key capital supply chains: investors and unit-holders in the AIFC.

Due diligence of investors and limited partners, counterparty checks and forensic due diligence, sanction risks and international restrictions, as well as reputational screening and KYP (Know Your Partner) are part of the standard package. For cybersecurity and data protection we build measures with GDPR compatibility in mind, including DLP, IAM, encryption and incident response plans. The senior manager regime and management accountability formalize personal accountability and improve the quality of decisions.

External and internal audit for funds provides an independent view of finances and processes. IFRS reporting and regular compliance reports for AFSA reduce the information gap and enable complex topics to be discussed in the language of facts.

COREDO cases — what worked

Recently the COREDO team supported the licensing of an investment company focused on managing portfolios of debt instruments. The client applied for non-custodial management with advisory rights. We strengthened governance, prepared a capital adequacy model and implemented a transaction monitoring system. AFSA approved the license within the stated window, and subsequent review confirmed the quality of AML controls.

In another project we launched a broker platform with restricted dealing for institutional clients. Requirements for minimum statutory capital and operational resilience turned out to be higher than planned. We rebuilt the financial model, engaged a partner custodian and strengthened IT controls. The AIFC broker license was issued after an additional interview, and the business started operations on the schedule set out in the plan.

A separate case — a license for a venture fund in the AIFC with a multi-strategy focused on early rounds. We drafted the fund documents, established procedures for valuing illiquid assets, and agreed the private placement memorandum and marketing materials. The solution developed by COREDO enabled the fund to quickly close the first closings from institutional LPs and to build succession planning processes at the management company level.

Finally, for a digital asset custody provider we designed the licensing, storage technology architecture and recovery scenarios. Special attention was paid to PEP and sanctions screening, segregation of funds and contingency procedures. The AIFC license for digital asset operations was approved after demonstrating technological and operational test cases.

Cost of license maintenance

The cost of license maintenance and ongoing compliance costs include annual fees, an IFRS audit, policy updates, staff training, as well as IT and cybersecurity support. For companies with active growth, budget for expanding the compliance team, upgrading monitoring systems, and independent model reviews. Our experience at COREDO has shown that planning OPEX as a function of AUM and the number of clients reduces the risk of underfunding the control system.

Outsourcing some functions is possible and reasonable if you retain accountability. AFSA is receptive to outsourcing provided there are clear SLAs, regulator access to data, and independent oversight. It is important to conduct vendor risk assessments regularly and incorporate the results into management reporting.

In the long term, savings are achieved through KYC automation, integration with data providers, and product line standardization. This reduces risk variability and simplifies regulatory communication.

Visas and personnel: how to build a team

Visas and employment of foreign personnel in the AIFC are simplified through the center’s special regimes. We plan in advance the relocation schedule for directors and the key compliance officer, taking into account document timelines and the readiness of the IT infrastructure. This reduces the risk of delays at the launch stage.

corporate governance: requirements for the board and committees imply independent directors, charters for the audit and risk committees and clear authorities. In COREDO projects we pay special attention to describing the senior manager regime and management responsibilities, including business continuity plans and delegation. This forms a mature “line of defense” and helps during inspections.

Migration of fund management to the AIFC is possible with a well-considered transfer of functions, taking into account regulatory arbitrage and legal risks when changing jurisdiction. We arrange a phased transition while maintaining client service and controls.

Exit strategies and liquidity

Exit strategies for funds registered in the AIFC depend on the asset class and investment horizon. Exit options are available: IPO in Kazakhstan, trade sale and secondary buyout, as well as listing instruments on regional exchanges. I recommend planning secondary market liquidity metrics and market making already at the fund structure stage.

Prospectus requirements and risk disclosure when preparing for a listing require consistent messaging, financial transparency and management discipline. External audit and independent asset valuation increase confidence and accelerate the marketing window. The COREDO team supports clients through to final closing, overseeing legal and compliance aspects.

Regulatory arbitrage is useful when you compare the requirements of different centers and build a hybrid structure. The key is not to lose substance and the ability to manage risks, and to properly document the reasons for the choice.

Is the AIFC suitable for your model?

To make a considered decision, I suggest going through a checklist. Assess which license categories are needed right now and in 12–24 months, and how they are affected by the requirements for obtaining a license in AIFC. Align capital, substance and fit and proper requirements with available resources and your staffing plan.

Analyze client jurisdictions to account for cross-border service restrictions and local marketing requirements. Assess ROI: apply NPV and IRR to three scaling scenarios and take into account the payback period for licensing and IT. Do not leave regulatory risks and reputational risk in the AIFC in the shadows: set an acceptance threshold and a response plan.

If the AIFC meets the key criteria, it’s worth proceeding. If some parameters are ‘yellow’, adjust the design: a combination of an SPV and a management company, phased licensing, a pilot with a regulatory sandbox and subsequent upscaling.

Why COREDO is a reliable AIFC partner

Over years of working in Europe, Asia and the CIS I have learned that success in the AIFC is built on careful process calibration and attention to detail. The COREDO team is used to being accountable for results: from registering a legal entity in the AIFC and licensing investment activities in the AIFC to deploying AML/KYC and preparing for an AFSA inspection. We do not promise miraculous timelines, but we design realistic roadmaps and ensure transparency at every stage.

If you are considering an AIFC investment license, an AIFC asset manager license, an AIFC broker license, an AIFC depository license, or fund structures, I am ready to discuss your business model and offer a practical solution. COREDO’s experience shows that a properly structured setup in the AIFC simplifies cross-border capital raising, strengthens investor confidence, and creates a foundation for strategic exit decisions. That is the kind of foundation needed for calm, steady scaling of an investment business.

Investment licenses in the AIFC in Kazakhstan