Regimes
How the question is answered under each regime
Kazakhstan · national regimeModel 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 / AFSAAFSA 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 jurisdictionsAssessed 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.