Regimes
How the question is answered under each regime
Kazakhstan · national regimeNational Bank of Kazakhstan licence
- an operator exchanging unbacked digital assets requires an NBK licence for exchange operations with unbacked digital assets
- charter capital is formed before applying; the minimum amount is set by the NBK
- the application package includes, among other things, the charter, operating rules and a document governing interaction with a bank and a digital asset exchange
- the application is reviewed within 20 working days of submission of a complete package
- the operator must implement a transaction analysis and monitoring system
Kazakhstan · AIFC / AFSAAFSA authorisation
- AIFC firms carrying on digital asset activities are treated as Digital Asset Service Providers (DASPs)
- an exchange model is classified under AIFC rules, for example as dealing in investments as principal or as agent
- registering a company in the AIFC is not the same as AFSA authorisation
Other jurisdictionsAssessed on request
- classification of exchange activity differs between countries
- we carry out the analysis with local counsel
- the jurisdiction is chosen based on the actual model and target markets
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.