Kazakhstan's financial intelligence authority, the Komitet finansovogo monitoringa (Financial Monitoring Committee), has issued a package of AML measures that took effect in early 2025. The changes tighten know-your-customer and beneficial ownership requirements across a broad range of business sectors. International companies operating in Kazakhstan – or transacting with Kazakhstani counterparties – face significant compliance exposure if they have not yet updated internal procedures.
Kazakhstan's updated anti-money laundering legislation expands AML and KYC obligations to a wider set of entities, including non-bank financial institutions, payment service providers, and designated non-financial businesses. Companies must verify the beneficial owner of every client relationship and report suspicious transactions within the timeframes prescribed by financial monitoring legislation. The primary compliance deadline for existing client files is mid-2025, with new onboarding rules effective immediately.
This alert explains which business categories are affected, what the threshold criteria are, and what immediate steps international companies should take to remain compliant.
What changed and when it took effect
Kazakhstan's financial monitoring legislation was amended to align with recommendations issued by the Evraziiskaya gruppa po protivodeystviyu legalizatsii prestupnykh dokhodov i finansirovaniyu terrorizma. the Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG). Of which Kazakhstan is a member.
The core changes are as follows. First, the definition of a beneficial owner has been broadened. Any natural person who directly or indirectly holds a qualifying ownership interest in a legal entity, or who exercises effective control through other means, must now be identified and verified. The qualifying threshold has been reduced, so more ownership structures fall within scope than before.
Second, KYC procedures must now be conducted on a risk-weighted basis. Entities subject to the legislation must assign each client a risk rating – low, medium, or high – and apply proportionate due diligence measures accordingly. High-risk clients require enhanced due diligence, including verification of the source of funds and the purpose of the business relationship.
Third, correspondent banking relationships are now subject to stricter pre-approval requirements. Kazakhstani banks entering or maintaining a correspondent banking arrangement with a foreign institution must document the institution's AML controls before the relationship commences. Existing arrangements must be reviewed within a defined period following the effective date.
Fourth, the legislation now expressly covers credit facility documentation. Lenders must verify beneficial ownership and conduct ongoing monitoring for any credit facility above a specified threshold value. The threshold applies per transaction as well as on a cumulative basis where structuring is suspected.
These amendments took effect on January 1, 2025. Transitional provisions allow a six-month window – to July 1, 2025 – to remediate existing client files that do not yet meet the new beneficial ownership standards.
Who is affected – threshold criteria and business categories
The updated rules apply to all entities classified as sub"ekty finansovogo monitoringa (subjects of financial monitoring) under Kazakhstani law. The list is materially wider than under the prior regime. It now includes:
- Banks and non-bank financial institutions, including microfinance organisations
- Payment service providers and electronic money issuers
- Securities dealers, investment funds, and asset managers
- Auditors, accountants, and tax advisers when conducting covered transactions
- Lawyers and notaries involved in real estate transfers, corporate restructurings, or management of client assets
For designated non-financial businesses, the trigger is transaction value. A single cash or cash-equivalent transaction at or above the monetary threshold set in the legislation requires mandatory identification and reporting. Cumulative transactions with the same counterparty within a 30-day period are aggregated for threshold purposes.
International companies with a Kazakhstani subsidiary, branch, or representative office are subject to local AML legislation directly. Parent companies that provide services to Kazakhstani entities – including intragroup credit facilities or treasury functions – may also be drawn into compliance obligations if those transactions meet the threshold criteria.
The bank account opening process for foreign-owned entities has also changed. Kazakhstani banks must now collect and verify beneficial ownership documentation before an account is opened, rather than within a post-opening remediation period. This affects the timeline for market entry and treasury setup.
For a broader view of how these banking obligations interact with securities and investment activities, see our overview of capital markets regulation in Kazakhstan.
To receive an expert assessment of your company's AML exposure in Kazakhstan, contact us at info@ferrazwhitmore.com.
Immediate actions for international companies
Companies that fall within the scope of the updated legislation should take the following steps without delay.
Review your beneficial ownership records. Map the full ownership chain for each Kazakhstani entity in your group. Confirm that every natural person who meets the qualifying threshold is identified, that copies of identity documents are on file, and that residency and nationality data is current. Where ownership is held through trusts or nominee arrangements, documentary evidence of effective control is required.
Update your KYC procedures. Existing onboarding templates and client due diligence questionnaires should be reviewed against the new risk-based requirements. Risk ratings must be assigned and documented for all active client files before the July 1, 2025 remediation deadline. New onboarding must apply the updated procedures immediately.
Assess correspondent banking arrangements. If your group maintains correspondent banking relationships through a Kazakhstani bank, obtain and review the institution's AML policy documentation. Confirm that the pre-approval assessment required under the new rules has been completed or is underway.
Audit credit facility documentation. Any active credit facility above the threshold must include a beneficial ownership verification record. If existing facility documentation pre-dates the January 2025 amendments, a supplemental KYC exercise is required before the transitional window closes.
Establish a suspicious transaction reporting protocol. The legislation prescribes specific timelines for reporting suspicious transactions to the Financial Monitoring Committee. Companies must designate a responsible compliance officer, define internal escalation procedures, and test the reporting pathway before it is needed operationally.
Practitioners in Kazakhstan note that the Financial Monitoring Committee has increased the frequency of thematic inspections since the amendments took effect. Entities that cannot demonstrate a documented compliance programme – not merely a written policy, but evidence of actual implementation – face administrative penalties and, in serious cases, suspension of operating licences.
Companies operating across CIS jurisdictions should note that comparable AML tightening has occurred in neighbouring markets. Our alert on AML updates in Russia covers parallel developments relevant to cross-border groups.
For a full review of your compliance position under Kazakhstan's banking and financial monitoring legislation, contact our team at info@ferrazwhitmore.com.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our team combines Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions in banking regulation, AML compliance, and financial monitoring matters across CIS and emerging markets. We have advised international companies on AML obligations, bank account opening procedures, and beneficial ownership structuring in Kazakhstan and across the broader CIS region. Engaging a lawyer in Kazakhstan with cross-border experience is essential when navigating compliance obligations that carry both local administrative and international regulatory consequences. As an international law firm advising on law firm Kazakhstan matters, Ferraz & Whitmore provides results-oriented counsel to international entrepreneurs, institutional investors, and in-house legal teams operating across multiple legal systems. To discuss your AML compliance situation in Kazakhstan, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.