Regimes
How the question is answered under each regime
Kazakhstan · national regimeNBK payment regime
- payment organisations are registered with the NBK
- digital asset operations within the product are classified separately under the Law on Digital Assets
- unbacked digital assets are not recognised as a means of payment in Kazakhstan
- the NBK special regulatory regime also covers payment services
Kazakhstan · AIFC / AFSAMoney Services in the AIFC
- providing money services in relation to digital assets in the AIFC requires AFSA authorisation
- AIFC currency regulation rules apply
- issuing fiat stablecoins requires a separate authorisation
Other jurisdictionsAssessed on request
- payments and e-money are governed by the national law of the client's country
- we compare regimes and settlement routes
- 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.