Kazakhstan

**AIFC Financial Services Authority (AFSA):** The independent regulator of the AIFC, responsible for licensing, supervision, and enforcement of financial services, including virtual asset activities.

**AIFC Court and International Arbitration Centre:** Provides independent resolution of disputes.

**Financial Monitoring Agency of the Republic of Kazakhstan:** The national financial intelligence unit (FIU) for anti-money laundering and counter-terrorist financing (AML/CFT) oversight, which works in coordination with AFSA for AIFC entities.

**License Type:** Operating a **Digital Asset Trading Facility (DATF)**.

**Definition:** A person who provides a facility where multiple third-party buying and selling interests in Digital Assets are able to interact in the facility in a way that results in a Contract for sale or purchase. This broadly covers cryptocurrency exchanges.

**Key Services:** Matching orders, trade execution, offering a trading platform for various digital assets (utility tokens, security tokens, potentially payment tokens/cryptocurrencies).

**License Type:** Providing **Custodian (Digital Assets)** services.

**Definition:** A person who provides services for the safekeeping, administration, and segregation of Digital Assets (or instruments enabling control over Digital Assets) on behalf of clients.

**Key Services:** Secure storage of private keys, multi-signature wallets, cold storage solutions, segregated client accounts, record-keeping.

**License Type:** Providing **Payment Services Provider (PSP)** services.

**Definition:** While not exclusively for digital assets, a PSP license is required for firms handling fiat-to-crypto and crypto-to-fiat conversions, remittances, or other payment-related services where digital assets are involved in the transaction flow. AFSA's rules define specific "payment services" that require licensing, and these can extend to services involving digital assets.

**Key Services:** Fiat-to-crypto on/off-ramps, crypto remittances, facilitating payments using stablecoins or other digital assets.

**Broker (Digital Assets):** Acting as an agent for clients in buying and selling digital assets.

**Dealer (Digital Assets):** Dealing in digital assets as a principal, either buying or selling for one's own account.

**Legal Form & Local Presence:**

Must be incorporated or established as a legal entity within the AIFC.

Maintain a physical office presence in the AIFC.

Have key personnel (e.g., CEO, Compliance Officer) primarily based in the AIFC.

**Base Capital:** This varies significantly based on the type and scope of the license.

**Digital Asset Trading Facility (DATF):** Typically **USD 300,000** (or KZT equivalent) for non-dealing DATFs. If the DATF also acts as a Dealer, higher capital may be required.

**Custodian (Digital Assets):** Typically **USD 300,000** (or KZT equivalent).

**Payment Services Provider (PSP):** Varies depending on the specific payment services and tiers of authorization, ranging from **USD 50,000 to USD 200,000** (or KZT equivalent) for higher-tier PSPs.

**Ongoing Capital:** Firms must maintain capital sufficient to cover their regulatory capital requirements (base capital plus operational risk requirements) at all times.

**AML/KYC (Anti-Money Laundering / Know Your Customer):**

Adherence to AIFC AML Rules, which are aligned with FATF (Financial Action Task Force) recommendations.

Robust AML/CFT policies, procedures, and controls.

Appointment of a qualified Compliance Officer (MLRO - Money Laundering Reporting Officer).

Customer due diligence (CDD) and enhanced due diligence (EDD) procedures.

Suspicious activity reporting (SAR) obligations to the Financial Monitoring Agency.

All senior management, shareholders (above a certain threshold), and key personnel must meet AFSA's "Fit and Proper" criteria regarding honesty, integrity, reputation, competence, and financial soundness.

Comprehensive business plan outlining proposed activities, target market, operational structure, and financial projections.

Adequate risk management systems and controls, including cybersecurity, operational risk, market risk, and compliance risk.

Internal audit function (or outsourced equivalent).

Demonstrated ability to protect client assets and data.

Robust IT infrastructure and cybersecurity measures.

Business continuity and disaster recovery plans.

**Initial Consultation:** Informal discussion with AFSA to clarify regulatory requirements and the application process.

Completion of detailed application forms (typically Forms 1-4).

Submission of comprehensive documentation, including:

Detailed Policies and Procedures (AML/KYC, Risk Management, Cybersecurity, etc.)

CVs and Fit & Proper forms for all key individuals and significant shareholders

Legal entity documents (incorporation certificates, constitutional documents)

IT architecture and security assessments.

**Review and Assessment:** AFSA reviews the application, may request additional information, and conduct interviews with key personnel. This stage involves detailed scrutiny of the business model, financial projections, risk management framework, and compliance arrangements.

**In-Principle Approval:** If satisfied, AFSA may issue an "in-principle" approval, subject to certain conditions (e.g., establishing a local office, hiring specific personnel).

**Final Approval and Licensing:** Once all conditions are met, AFSA grants the license.

**Post-Licensing Obligations:** Ongoing reporting, compliance with AIFC Rules, and regular audits.

**Prohibition:** The general law of the Republic of Kazakhstan historically prohibited the issuance and unlicensed circulation of "unsecured" digital assets (i.e., cryptocurrencies not backed by a tangible asset or security) as a payment instrument.

**Digital Assets Law (Recent Developments):** Kazakhstan has recently been active in developing national legislation for digital assets. The Law "On Digital Assets in the Republic of Kazakhstan" (signed into law in February 2023) regulates various aspects, including:

**Mining:** Legalized and regulated. Miners must register, obtain licenses, and are subject to energy consumption quotas and taxation.

**Issuance of Secured Digital Assets:** Permits the issuance of digital assets backed by specific assets or rights, with the National Bank of Kazakhstan overseeing this area.

**Unlicensed Activity:** Reaffirms the prohibition on the issuance and circulation of unsecured digital assets *outside* the AIFC. This means that exchanges, custodians, and payment processors dealing with cryptocurrencies generally *must* operate within the AIFC framework to be legal in Kazakhstan.

**AIFC General Regulations:** The foundational regulatory document.

Can typically be found in the "Legal Framework" or "Rules and Regulations" section of afsa.kz.

**AIFC Digital Asset Rules:** Contains the specific framework for regulating digital assets and related services.

**AIFC Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Rules (AIFC AML Rules):** Crucial for compliance requirements.

Search for "AIFC AML Rules" on afsa.kz.

**AIFC Conduct of Business Rules:** Governs how firms conduct their business with clients.

Search for "AIFC Conduct of Business Rules" on afsa.kz.

**AIFC Payment Services Rules:** Relevant for PSPs.

Search for "AIFC Payment Services Rules" on afsa.kz.

**AIFC Fees Rules:** Details application and annual supervision fees.

Search for "AIFC Fees Rules" on afsa.kz.

**Application Packs and Guidance:** AFSA provides detailed application forms and guidance notes for each license type, which often include specific capital requirements and detailed checklists.

Look under "Licensing" or "FinTech" sections on afsa.kz for "Application Forms" or "Regulatory Guidance."

**Requirement:** As a UN member state, Kazakhstan is obligated to implement all UN Security Council resolutions imposing sanctions. These are universally binding.

**Compliance:** VASPs must screen customers and transactions against the **UN Security Council Consolidated List** (individuals and entities associated with terrorism and proliferation of weapons of mass destruction, and other sanction programs).

**Legal Reference:** UN Security Council Resolutions.

**URL:** UN Security Council Consolidated List

**Requirement:** While OFAC sanctions are primarily U.S. law, their extra-territorial reach is significant. Any VASP that deals with U.S. persons (citizens, residents, entities), uses U.S. financial systems (e.g., for USD transactions), or handles U.S.-origin technology or services, falls under OFAC's jurisdiction. Given the global nature of crypto, avoiding a U.S. nexus can be challenging.

**Compliance:** VASPs must screen against OFAC's **Specially Designated Nationals And Blocked Persons List (SDN List)** and other relevant sanctions lists specific to programs (e.g., Russia/Ukraine, Iran, North Korea).

**Legal Reference:** Executive Orders and U.S. Treasury Department Regulations (e.g., 31 CFR Chapter V).

**URL:** OFAC Sanctions List Search

**Requirement:** Similar to OFAC, EU sanctions have extra-territorial implications for any entity or individual doing business with EU persons, entities, or utilizing EU financial infrastructure. Many international crypto exchanges and platforms have an EU presence or serve EU customers.

**Compliance:** VASPs must screen against the **EU Consolidated Financial Sanctions List**.

**Legal Reference:** EU Council Regulations.

**URL:** EU Sanctions Map / Consolidated List

**Law of the Republic of Kazakhstan "On Counteracting Legalization (Laundering) of Criminal Proceeds and Financing of Terrorism" (No. 191-IV dated August 28, 2009, as amended):** This is the primary AML/CFT law. It designates the Financial Monitoring Agency (FMA) as the competent authority and outlines the obligations of "financial organizations" and other reporting entities (which, under FATF standards, includes VASPs). It requires reporting entities to identify customers, monitor transactions, and report suspicious activities, including those related to terrorism financing and proliferation, which often involves sanctions screening.

**Legal Reference:** Закон Республики Казахстан "О противодействии легализации (отмыванию) доходов, полученных преступным путем, и финансированию терроризма" от 28 августа 2009 года № 191-IV.

**URL (Kazakh/Russian):** Adilet.zan.kz - Law on AML/CFT

**Law of the Republic of Kazakhstan "On Digital Assets in the Republic of Kazakhstan" (No. 4-VIII dated February 6, 2023):** This law regulates the issuance, circulation, and mining of digital assets. While primarily focused on licensing and operations, it integrates digital asset activities into the existing AML/CFT framework, thereby extending sanctions compliance obligations to licensed crypto entities.

**URL (Kazakh/Russian):** Adilet.zan.kz - Law on Digital Assets

**Financial Monitoring Agency (FMA):** The FMA is Kazakhstan's Financial Intelligence Unit (FIU) and the primary body responsible for enforcing AML/CFT laws, including monitoring compliance with international sanctions.

**B. Astana International Financial Centre (AIFC):**

**Specific Regime:** The AIFC operates under a separate legal system based on English common law, with its own independent financial regulator, the AIFC Financial Services Authority (AFSA). The AIFC is a key hub for crypto regulation in Kazakhstan.

**AFSA Rules:** The AFSA has specific rules for VASPs (referred to as "Distributed Ledger Technology Businesses" or DLT Businesses). These rules comprehensively incorporate FATF standards for AML/CFT and explicitly require compliance with international sanctions regimes. AFSA-regulated firms are expected to:

Identify, assess, and understand their money laundering and terrorist financing risks, including sanctions risks.

Implement robust Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures.

Screen customers and transactions against relevant sanctions lists (UN, OFAC, EU).

Report suspicious transactions (STRs) to the AFSA and/or relevant law enforcement bodies.

**Legal Reference:** AIFC Acts, AIFC Financial Services Authority (AFSA) Rules, particularly the **AIFC Anti-Money Laundering and Counter-Terrorist Financing Rules** and **Conduct of Business Rules**.

**URL:** AIFC Regulatory Framework - AFSA (Look for AML/CTF Rules and DLT Rules).

**Know Your Customer (KYC) and Customer Due Diligence (CDD):** Thorough identification and verification of customers, including beneficial owners, source of funds, and nature of business.

**Sanctioned Entity Screening:** Automated and ongoing screening of all customers, beneficial owners, and transaction counterparties against the UN Consolidated List, OFAC SDN List, EU Consolidated Financial Sanctions List, and any other relevant national or international lists.

**Transaction Monitoring:** Real-time and retrospective monitoring of all crypto transactions for unusual patterns, high-risk jurisdictions, and direct/indirect links to sanctioned entities or jurisdictions.

**Geographic Restrictions:** Implementing controls to prevent transactions involving sanctioned jurisdictions (e.g., North Korea, Iran, sanctioned regions of Ukraine/Russia) or entities based in those regions.

**Risk-Based Approach:** Developing and implementing a risk-based approach to AML/CFT and sanctions compliance, proportionate to the VASP's risk profile, customer base, products, and geographies of operation.

**Reporting Obligations:** Prompt reporting of any confirmed or suspected sanctions hits, as well as suspicious transactions, to the Financial Monitoring Agency (FMA) or the AFSA (for AIFC-regulated entities).

**Training and Internal Controls:** Regular training for staff on sanctions compliance, maintaining up-to-date policies and procedures, and conducting independent audits of the compliance program.

**UN-sanctioned countries:** E.g., North Korea (DPRK), Iran (specific programs), Afghanistan (Taliban).

**OFAC-sanctioned jurisdictions:** E.g., Cuba, Iran, North Korea, Syria, Venezuela, and specific regions of Ukraine (Crimea, DPR, LPR).

**EU-sanctioned jurisdictions:** Similar to OFAC, with specific focus on certain regions or entities.

**Administrative Fines:** Significant monetary penalties for non-compliance, varying based on the severity and frequency of the violation.

**Criminal Charges:** Individuals and corporate officers can face criminal prosecution, imprisonment, and asset forfeiture for serious breaches, particularly those involving terrorism financing, money laundering, or willful evasion of sanctions.

**License Revocation:** VASPs found to be in egregious non-compliance may have their licenses suspended or revoked by the FMA or AFSA.

**Reputational Damage:** Loss of trust and severe damage to reputation, impacting business viability.

**International Sanctions:** Firms or individuals operating in Kazakhstan who violate OFAC or EU sanctions may also face direct penalties from U.S. or EU authorities, including being added to sanctions lists themselves.

**UN Security Council sanctions lists.**

**Lists of individuals and entities associated with terrorism and proliferation of weapons of mass destruction, compiled by the competent national authorities (e.g., the FMA in conjunction with other law enforcement/security bodies), which are often based on or mirror UN lists.**

Through its AML/CFT obligations, Kazakhstan implicitly requires compliance with other major international lists (like OFAC and EU) for entities with international operations or exposure to those jurisdictions.

**Adopted:** Yes, Kazakhstan has officially adopted legislation implementing the FATF Travel Rule.

**Legislation:** The key legislative act is the **Law of the Republic of Kazakhstan "On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Combating Legalization of Criminal Proceeds (Money Laundering) and Financing of Terrorism"** (No. 182-VII dated February 2, 2023).

**Effective Date:** The amendments came into effect approximately **60 calendar days after their official publication**, which means around **early April 2023**. This law brought virtual assets and virtual asset service providers (VASPs) within the scope of the national AML/CFT regime.

**Compliance with FATF R.16:** These amendments aim to align Kazakhstan's legislation with FATF Recommendation 15 (Virtual Assets and VASPs) and its Interpretive Note, which includes the Travel Rule (Recommendation 16).

**Threshold:** Transactions involving virtual assets equal to or exceeding **1,000,000 KZT (one million tenge)** are subject to enhanced information requirements. (As of mid-2024, 1,000,000 KZT is approximately USD 2,200).

Information Required for Transactions < 1,000,000 KZT: For transactions below the threshold, VASPs are generally required to collect and transmit only the originator's and beneficiary's wallet addresses and the transaction identifier. However, a risk-based approach dictates that VASPs should still be able to identify customers and obtain more information if a transaction is deemed suspicious.

**Originator Information:** Name, surname, patronymic (if any), individual identification number (IIN), address of residence, wallet address.

**Beneficiary Information:** Name, surname, patronymic (if any), individual identification number (IIN), address of residence, wallet address.

**Information Required for Transactions < 1,000,000 KZT:**

For transactions below the threshold, VASPs are generally required to collect and transmit only the originator's and beneficiary's **wallet addresses** and the **transaction identifier**. However, a risk-based approach dictates that VASPs should still be able to identify customers and obtain more information if a transaction is deemed suspicious.

**Exchange:** Exchanging virtual assets for fiat currency or other virtual assets.

**Transfer:** Facilitating the transfer of virtual assets.

**Custody/Administration:** Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets.

**Participation and provision of financial services related to:** The offering and/or sale of virtual assets by an issuer.

**Other services:** Any other activities related to virtual assets that fall under the FATF VASP definition.

**Choose a compliant solution:** Implement or integrate with a Travel Rule solution (e.g., those offered by TRISA, OpenVASP, Sygna, Notabene, Verite, etc.) that enables the secure, real-time transfer of required data between VASPs.

**Interoperability:** Ensure their chosen solution is interoperable with those used by other VASPs, especially for cross-border transactions.

**Internal Policies & Procedures:** Develop and implement robust internal policies, procedures, and controls for:

Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD).

Screening for sanctions and politically exposed persons (PEPs).

Data security and privacy (e.g., in compliance with Kazakhstan's data protection laws).

Record-keeping of Travel Rule information.

Reporting suspicious transactions to the Agency for Financial Monitoring.

**Remedial Orders:** The AFM can issue binding instructions requiring VASPs to take specific actions to rectify deficiencies in their AML/CFT systems and procedures.

**Suspension or Revocation of Licenses/Registrations:** For serious or repeated non-compliance, a VASP's operating license or registration may be suspended or revoked, effectively preventing it from conducting business.

**Criminal Liability:** In cases of egregious or willful non-compliance, particularly where it facilitates money laundering or terrorist financing, individuals (e.g., executives, compliance officers) may face criminal charges, leading to imprisonment.

**Reputational Damage:** Beyond legal penalties, non-compliance can severely damage a VASP's reputation, leading to loss of customer trust and business.

**Law of the Republic of Kazakhstan "On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Combating Legalization of Criminal Proceeds (Money Laundering) and Financing of Terrorism" (No. 182-VII dated February 2, 2023):** While a direct English link to the full official text can be difficult to find publicly, information about its adoption is widely reported.

**Agency for Financial Monitoring of the Republic of Kazakhstan (AFM):** This is the primary regulator and source for official guidance. Their website (afm.gov.kz) would contain relevant information, though often in Kazakh or Russian.

**FATF Mutual Evaluation Reports for Kazakhstan (via EAG):** As a member of the Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG), a FATF-style regional body, Kazakhstan is subject to peer reviews. These reports detail their compliance with FATF standards.

Eurasian Group (EAG) website: https://www.eurasiangroup.org/en/ (Look for Kazakhstan's mutual evaluation reports)

**Legal Reference:** Закон Республики Казахстан "О цифровых активах в Республике Казахстан" от 6 февраля 2023 года № 4-VIII ЗРК.

**Astana Financial Services Authority (AFSA):** The independent regulator for the AIFC.

**AIFC Digital Asset Business Rules (DABR):** Contains specific requirements for firms involved in digital asset activities.

**AIFC Conduct of Business Rules (COB):** General rules for how firms must conduct business with clients.

**AIFC Prudential Rules (PRU):** Rules related to capital, risk management, and financial soundness.

**AIFC Anti-Money Laundering and Counter-Terrorist Financing Rules (AML):** Mandatory for all regulated firms.

**License Type:** Firms typically seek a license for "Providing Digital Asset Custody Services" under the AIFC Digital Asset Business Rules. This falls under the broader category of "Digital Asset Business."

Submission of a comprehensive application form.

Detailed business plan outlining operations, risk management, technology, and compliance.

Demonstration of "fit and proper" criteria for all significant shareholders, directors, and senior management (background checks, experience, integrity).

Proof of adequate financial resources (capital requirements – see Prudential Rules).

Robust Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) policies and procedures.

Demonstration of robust IT systems and cybersecurity measures.

**Regulatory Reference:** **AIFC Digital Asset Business Rules 2020** (DABR), specifically Part 3 (General Requirements for Digital Asset Business) and other relevant sections detailing specific activities.

**URL (AFSA Rulebook):** https://afsa.aifc.kz/rulebook/ (Navigate to "Digital Asset Business Rules")

**Mandatory Segregation:** Licensed custodians are required to segregate client digital assets from their own proprietary assets. These assets must be clearly identifiable as client assets.

**Record-Keeping:** Detailed and accurate records of client assets, including ownership and transaction history, must be maintained.

**Trust Accounts/Safeguarding:** Assets must be held in a manner that protects clients' interests, typically implying a trust or fiduciary arrangement where client assets are not subject to the custodian's creditors in case of insolvency.

**Regulatory Reference:** **AIFC Conduct of Business Rules 2020 (COB)**, particularly sections relating to client money and client asset safeguarding. Also implied by the **Digital Asset Business Rules** emphasizing client protection.

**Capital Requirements:** Licensed firms must meet specific minimum capital requirements (financial resources) based on the nature and scale of their business, as detailed in the Prudential Rules. This serves as a buffer against operational losses.

**Risk Management Framework:** Firms are required to implement robust risk management systems covering operational risks, technology risks, and security risks. This indirectly encourages firms to consider appropriate insurance as part of their risk mitigation strategy, although not explicitly mandated as a bonding requirement.

**Operational Resilience:** Firms must demonstrate operational resilience, including contingency plans for security breaches or loss of assets.

**Regulatory Reference:** **AIFC Prudential Rules 2020 (PRU)**, and relevant sections of the **Digital Asset Business Rules** concerning operational risk.

**Robust Cybersecurity:** Firms must implement and maintain robust cybersecurity frameworks to protect client digital assets from theft, loss, or unauthorized access. This includes multi-factor authentication, encryption, and secure network protocols.

**Private Key Management:** Detailed policies and procedures for the generation, storage, backup, and recovery of private keys are mandatory. This strongly implies the use of offline (cold) storage for a significant portion of client assets, especially those not actively traded.

**Risk Assessment:** Custodians must conduct regular risk assessments of their storage solutions (hot, warm, cold) and implement appropriate controls.

**Operational Procedures:** Clear and secure operational procedures for moving assets between different storage types are required.

An entity that is **licensed by the Astana Financial Services Authority (AFSA)** to provide "Digital Asset Custody Services" in accordance with the AIFC Digital Asset Business Rules.

Such an entity must comply with all relevant AFSA rules, including those pertaining to capital adequacy, client asset segregation, governance, risk management, and AML/CTF.

Kazakhstan's President Kassym-Jomart Tokayev signed a law in February 2023 "On Digital Assets in the Republic of Kazakhstan" which legalizes and regulates activities related to digital assets, including their issuance, circulation, and mining outside the AIFC. However, note that subsequent implementing regulations and amendments may have been introduced.

**Focus:** This law primarily focuses on regulating cryptocurrency mining, mandating licensing for crypto exchanges operating within the country (outside AIFC), and outlining the procedures for their operation.

**Custody Implications (Outside AIFC):** While not explicitly creating a standalone "custody license" as detailed as the AIFC's, the licensing of crypto exchanges by the **Agency for Financial Monitoring** (AFM) implies that these exchanges offering custodial services will be subject to general financial regulations, AML/CTF requirements, and potentially rules on client asset safeguarding from the AFM. However, the specific, granular rules for custody are not as detailed as within the AIFC.

**Agency for Financial Monitoring (AFM):** https://www.gov.kz/memleket/entities/afm/about?lang=en

**News Reference for 2023 Law:** Search for "Kazakhstan Digital Assets Law February 2023" for various news reports. (e.g., Reuters, local news sites).

The February 2023 law was a significant step in formalizing the national crypto industry. However, given the rapid evolution of digital assets, further refinements and specific regulations, especially regarding "custody as a standalone service" outside the AIFC, could still be in development.

The government and regulatory bodies (AFSA, National Bank, AFM) continue to monitor the market and update regulations as needed. Kazakhstan has shown a willingness to adapt its legal framework to embrace digital innovation while ensuring financial stability and consumer protection.

Discussions often revolve around integrating digital assets into the broader financial system and addressing emerging risks. Any new legislation would likely aim to harmonize national standards with international best practices.

**AIFC** is the most comprehensive regulatory environment for digital asset custody in Kazakhstan, with specific licensing, asset segregation, and robust security requirements enforced by the AFSA.

**Outside AIFC**, the national framework is developing, with recent laws legalizing crypto activities and licensing exchanges through the Agency for Financial Monitoring, which will have implications for custody offered by those exchanges.

Firms seeking to offer robust and compliant digital asset custody services in Kazakhstan will primarily look to the **AIFC's AFSA regulatory framework**.

**Regulator Name:** Agency of the Republic of Kazakhstan for Financial Monitoring (AFM), in cooperation with the Ministry of Energy, National Security Committee, and local authorities.

**Entity Targeted:** Numerous unregistered cryptocurrency mining farms operated by various individuals and organizations across the country.

**Violation Type:** Unlicensed business activity, illegal electricity consumption, tax evasion, sometimes money laundering, and operating outside the legal framework for crypto mining.

**Outcome:** Shut down of operations, seizure of equipment (hundreds of thousands of mining devices), criminal charges against operators, and significant administrative fines. While individual penalty amounts for each entity are not publicly disclosed, the total economic impact and asset seizures were substantial. For instance, in 2022 alone, the AFM reported stopping 51 illegal mining farms and confiscating equipment worth billions of tenge.

**Date:** Ongoing, but major crackdowns and public announcements occurred particularly between **January 2022 and March 2023**.

**Outcome:** Over 50 illegal mining farms were shut down, leading to the confiscation of equipment and initiation of criminal cases. This action significantly reduced the strain on the national energy grid and established a precedent for strict enforcement against unregistered mining.

AFM: Kazakhstan clamps down on illegal crypto mining farms (This link provides context on various AFM actions, including illegal crypto-related activities.)

Reuters: Kazakhstan clamps down on illegal crypto miners as electricity crunch looms

Kazinform: 51 illegal crypto farms shut down in Kazakhstan

**Entity Targeted:** Operators and websites of unregistered cryptocurrency exchanges and peer-to-peer trading platforms.

**Violation Type:** Unlicensed financial activity, facilitation of illegal financial operations (e.g., fraud, money laundering), violation of financial regulations.

**Penalty Amount:** Not specified as a direct fine in publicly available reports.

**Outcome:** Blocking of website access, criminal charges against individuals involved, seizure of funds (if traceable).

**Date:** Multiple instances reported, for example, a significant operation in **February 2023**.

**Outcome:** Websites were blocked, and criminal investigations were launched against individuals involved in operating these platforms. This reinforces Kazakhstan's stance against any crypto trading outside the regulated AIFC framework.

AFM: Activities of a large cryptocurrency exchange in Almaty were suppressed by law enforcement agencies (This specifically refers to an operation in February 2023, though penalty details aren't itemized.)

**Entity Targeted:** Individuals and organized groups operating pyramid schemes and financial frauds that solicited investments in cryptocurrencies.

**Violation Type:** Financial fraud, creation and promotion of financial pyramids, illegal attraction of funds, money laundering.

**Penalty Amount:** Not specified as a single fine, but involves restitution to victims, asset forfeiture, and criminal sentences (imprisonment).

**Date:** Ongoing, with several high-profile cases reported throughout **2022 and 2023**.

**Outcome:** Arrests, criminal prosecutions, and convictions of perpetrators, aiming to recover assets for victims. These actions highlight the regulatory focus on consumer protection and combating crypto-related scams.

AFM: Financial Monitoring Agency prevented a financial pyramid scheme using crypto currency (This example from Nov 2022 details a specific case of a pyramid scheme involving cryptocurrency.)