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Brokerage and intermediary services

An intermediary in digital assets often ends up in a regulated role even without holding assets. We identify the company's role and build the structure, documents and product around it.

KZ: classified by modelAIFC: AFSA licence
Who it is for

For companies acting on behalf of or in the interest of clients

  • brokerage apps offering access to digital assets
  • agency and referral models
  • order routing to external venues
  • OTC intermediaries for large clients
  • investment firms adding digital assets
  • exchange and exchanger partner programmes
Regulatory questions

How an intermediary's role is determined

  1. 01

    Does the company accept and execute client orders

  2. 02

    In whose name and for whose account the transaction is made

  3. 03

    Do client funds or assets pass through the company

  4. 04

    Which venues are used and where they are regulated

  5. 05

    Who the marketing is aimed at and who the clients are

  6. 06

    Does the model amount to exchange or trading platform activity

Regimes

How the question is answered under each regime

Kazakhstan · national regime

Model analysed against the statuses in the law

  • organising the circulation of unbacked digital assets in Kazakhstan is permitted through licensed exchange operators, registered trading platform operators and licensed AIFC participants, or within the NBK special regulatory regime
  • an intermediary model is mapped against these statuses
  • regulation of the circulation of digital financial assets, except stablecoins, rests with the ARDFM
Kazakhstan · AIFC / AFSA

AFSA licence

  • in the AIFC, dealing as agent and arranging deals are regulated activities
  • the scope of the licence follows the set of services
  • client classification and risk disclosure rules apply
Other jurisdictions

Assessed on request

  • intermediation in digital assets often requires authorisation where the clients are located
  • we take marketing and cross-border service rules into account
  • opinions are prepared with local counsel

How an activity is classified depends on the actual model: who is the client's counterparty, where assets and keys are held, how settlement works, who the services are for. Information is current as of October 2026 and is confirmed during the project assessment.

Preparation

Three workstreams on one project

Lawyers

Legal preparation

  • classification of the intermediary role
  • structure of agreements with clients and venues
  • risk disclosure and marketing rules
  • client classification
  • AML/CFT and KYC
  • documents for a licence or a change of model
Finance

Financial preparation

  • revenue model: fees, spread, venue remuneration
  • capital and counterparty risk calculation
  • launch budget
  • management reporting
Engineers

Technology

  • client app and account area
  • order routing and venue integrations
  • KYC and transaction monitoring
  • order records and client reports
Stages

Stages and deliverables

  1. 01

    Role assessment

    Whether and where the activity is regulated

  2. 02

    Structure

    Contract model, jurisdiction, company

  3. 03

    Documents and product

    Policies, agreements, app and integrations

  4. 04

    Permits

    Application prepared and supported

  5. 05

    Launch

    Processes, partners, testing

  6. 06

    Ongoing support

    Compliance, reporting, changes

The sequence depends on the regime. Some work runs in parallel, but regulated activity starts only after the required permits are obtained.

Format

A single workstream or a full project

Single

Order one workstream

Separately: intermediary model classification, venue agreements, risk disclosure policy, technical integration.

Full scope

Turnkey launch

Full scope: from choosing the role and jurisdiction to launching the app and ongoing support.

Turnkey launch

Cost and timing are set after the project assessment.

FAQ

Frequently asked questions

Describe your project in a few sentences. We will give you a substantive reply: which questions need answering and where to start.

Discuss your project
If we only pass orders to a foreign exchange, is that regulated?

Often yes. What matters is who the clients are, where they are located and through whom the transaction is made. We answer after analysing the specific structure.

Can we act as an agent of a licensed operator?

This is possible under some regimes. It must be checked against the requirements for the operator and for the marketing of services.

Contact

Tell us about your project

We will review the description and give you a substantive reply: which regime may apply and where to start.

Prefer e-mail? Write to us directly.info@paralex.kz

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