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Digital asset exchange

We prepare the company for licensing of exchange activity: structure, licence application, financial model and a platform with a KYC/AML perimeter.

KZ: NBK licenceAIFC: AFSA licence
Discuss your projectRegulatory regimes
Who it is for

For projects where the company buys digital assets from and sells them to clients

  • new exchange services in Kazakhstan
  • existing exchangers moving to a regulated model
  • fintech apps adding digital asset exchange
  • international groups entering the Kazakhstan market
  • banks and payment companies considering a partnership model
  • investors assessing an exchange business
Regulatory questions

What must be settled before documents are drafted

  1. 01

    Is the company a party to the transaction with the client or only an intermediary

  2. 02

    Which regime to operate under: Kazakhstan's national regime or the AIFC

  3. 03

    How fiat settlement works and with which bank or other organisation

  4. 04

    Where the company sources digital assets: an exchange, liquidity providers or other parties

  5. 05

    Which assets and limits are permitted, who the clients are and how they are identified

  6. 06

    What capital, management and staff are needed to meet qualification requirements

Regimes

How the question is answered under each regime

Kazakhstan · national regime

National 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 / AFSA

AFSA 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 jurisdictions

Assessed 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.

Preparation

Three workstreams on one project

Lawyers

Legal preparation

  • choice of regime and legal form
  • company registration or reorganisation
  • operator's operating rules
  • contracts with clients, the bank and liquidity providers
  • AML/CFT, KYC, sanctions screening and travel rule policies
  • internal control and risk management
  • application and supporting documents
  • responses to the regulator's comments
Finance

Financial preparation

  • business plan for the regime's requirements
  • financial model: volumes, spreads, fees, costs
  • capital and liquidity buffer calculation
  • launch and first-year budget
  • cash flow forecast
  • management reporting templates
Engineers

Technology

  • technical specification for the exchange platform
  • client area and admin panel
  • integration of a KYC provider and transaction analysis system
  • integrations with liquidity sources and payment services
  • limits, logging, access control
  • documentation for information security requirements
Stages

Stages and deliverables

  1. 01

    Model assessment

    Regime chosen, structure and scope of work defined

  2. 02

    Structure and capital

    Company registered or adapted, capital plan

  3. 03

    Documents and platform

    Rules, policies, contracts, financial model, platform under way

  4. 04

    Filing and review

    Application filed, comments addressed

  5. 05

    Launch preparation

    Processes, roles, banking connection, testing

  6. 06

    Ongoing support

    Reporting, document updates, product development

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

You can order a model assessment, the licence application only, a financial model or platform development.

Full scope

Turnkey launch

We run the whole project: structure, documents, finance and platform are prepared under one plan and kept consistent.

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
Do we need a licence if we only exchange crypto for crypto?

Whether a licence is needed depends on the actual operations and the regime. Under Kazakhstan's national regime, buying, selling and exchanging unbacked digital assets is permitted through licensed exchange operators or registered trading platform operators. We classify your specific model during the assessment.

Can we start operating before the licence is granted?

No. The company, documents and platform can be prepared in advance, but clients can be served only after the licence is granted.

National regime or AIFC?

It depends on your clients, product, capital requirements and banking infrastructure. We compare both options on your specific model.

Do you guarantee the licence?

No. The decision rests with the regulator. We are responsible for the quality of preparation and support.

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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