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Digital asset trading platforms and exchanges

Preparing a trading platform operator: trading rules, listing, transaction monitoring, capital, and technology that meets regulatory requirements.

KZ: NBK registrationAIFC: AFSA licence
Who it is for

For operators that organise trading in digital assets

  • new exchange projects
  • international exchanges considering Kazakhstan
  • operators moving on from pilot regimes
  • projects with their own order book and matching
  • digital financial asset platforms planning secondary trading
  • investors assessing an exchange business
Regulatory questions

Key questions for an exchange model

  1. 01

    Who is the party to the trade: the operator or clients with each other

  2. 02

    Which assets are admitted to trading and under what listing rules

  3. 03

    Where and by whom client assets are held and how they are segregated

  4. 04

    How fiat settlement works and who the partner bank is

  5. 05

    Who can be a client: residents, non-residents, retail and professional

  6. 06

    What the requirements are for management, capital, information security and reporting

Regimes

How the question is answered under each regime

Kazakhstan · national regime

Registration with the National Bank

  • a digital asset trading platform operator must register with the NBK and is entered in its register
  • operating without registration is not permitted
  • a digital financial asset platform operator may act as a trading platform operator if it holds the relevant registration
  • document and capital requirements are set by NBK regulations
Kazakhstan · AIFC / AFSA

AFSA licence for operating a trading facility

  • organising trading in digital assets in the AIFC is a regulated activity (Operating a Digital Asset Trading Facility)
  • operator rules: business rules, admission of assets, client relations
  • an updated version of the AIFC Rules on Digital Asset Activities has applied since 1 January 2026
Other jurisdictions

Assessed on request

  • exchange activity requires separate authorisation in most jurisdictions
  • we compare regimes on capital, staffing requirements and market access
  • foreign law is handled 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

  • model classification and choice of regime
  • corporate structure and governance bodies
  • trading, listing and client admission rules
  • client agreements and risk disclosure
  • AML/CFT, KYC, transaction monitoring, market abuse
  • internal control, risk management, conflicts of interest
  • documents for registration or a licence
  • dealings with the regulator
Finance

Financial preparation

  • business plan and fee revenue model
  • capital and operating reserve calculation
  • budget for technology, staff and compliance
  • volume and cash flow forecast
  • load scenarios and break-even point
  • management reporting
Engineers

Technology

  • technical specification for the trading system
  • trading engine: in-house, adapted or white-label
  • client area, administration, roles
  • KYC and transaction analysis system
  • integrations with custody, liquidity, payment services
  • logging, reporting, information security
Stages

Stages and deliverables

  1. 01

    Model assessment

    Regime, operator's role, list of requirements

  2. 02

    Structure

    Company, governance bodies, capital plan

  3. 03

    Rules and platform

    Trading rules, policies, trading system

  4. 04

    Registration or licence

    Application filed, review supported

  5. 05

    Launch

    Testing, processes, partner connections

  6. 06

    Ongoing support

    Reporting, listings, rule 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: model assessment, trading and listing rules, licence application, financial model, technical specification or development.

Full scope

Turnkey launch

Full scope: the exchange model, documents, finance and trading system are prepared by one team under one plan.

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
How is a trading platform different from an exchanger?

An exchanger is itself the party to the transaction with the client. A trading platform organises trading between clients through its trading system. The requirements and the type of permit depend on this.

Do you have a ready-made exchange platform?

We do not sell a proprietary ready-made platform. We prepare the technical specification, develop or adapt a solution, including white-label, and prepare it for the regime's requirements.

Can we serve clients from other countries?

That depends on the regime and the law of the client's country. Market restrictions are part of the project assessment.

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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