Kazakhstan Adopts Comprehensive 2025–2027 AML/CFT Measures Under Government Resolution No. 934

Regulation Name: Resolution No. 934
Date Of Release: 07 Nov 2025
Region: Kazakhstan
Agency: Agency for Financial Monitoring of the Republic of Kazakhstan

Kazakhstan Approves Comprehensive AML/CFT Risk-Reduction Measures for 2025–2027

The Government of the Republic of Kazakhstan has taken a decisive step to strengthen its national AML/CFT framework by adopting Resolution No. 934 on 7 November 2025, which formally approves a broad set of measures aimed at reducing the risks of money laundering, terrorist financing, and the financing of weapons of mass destruction. According to the Resolution, these measures were developed in line with Article 11-1 of the national AML/CFT law and require coordinated implementation across multiple ministries, the Agency for Financial Monitoring (AFM), the National Bank, the financial regulator, and other state bodies. Reporting on progress must be submitted every six months to the AFM and subsequently to the Government’s Executive Office, ensuring continuous oversight. The Resolution comes into force ten days after its official publication but not earlier than 20 November 2025.

Overview of Kazakhstan’s New AML/CFT Risk-Reduction Framework

The newly approved framework introduces a structured set of 44 coordinated AML/CFT initiatives across a wide range of sectors, including banking, digital assets, foreign trade, real estate, corporate structures, luxury goods, precious metals, and gaming services. These initiatives reflect Kazakhstan’s growing alignment with FATF standards and address both traditional and emerging financial crime risks. The measures emphasise the prevention of illicit capital outflows, the detection of concealed beneficial ownership structures, the monitoring of high-risk industries, and the enhancement of statistical, analytical, and supervisory tools used by state institutions. Through this multi-sectoral approach, Kazakhstan aims to fortify its national defences against illicit finance and ensure strong compliance with evolving global AML/CFT expectations.

Strengthening Controls Against Money Mules (“Drops”)

A substantial part of the Resolution focuses on countering the widespread misuse of подставные лица, commonly known as “drops” or money mules. The Government mandates the development of detailed typologies describing how mule accounts are used in cash-out schemes and illegal financial operations, which will then be distributed to second-tier banks to strengthen their internal controls. The regulatory framework will also be updated to incorporate new suspicious transaction indicators specifically targeting mule-related activities. To complement these technical measures, a recurring public information campaign titled “Don’t Become a Drop!” will be conducted with the participation of state agencies and financial institutions. This campaign aims to raise public awareness of criminal schemes that exploit individuals’ banking credentials and reinforces Kazakhstan’s commitment to combating money-mule operations, which have become a global AML challenge.

Monitoring Cross-Border Transactions and Capital Outflows

The Resolution introduces several measures to mitigate risks associated with cross-border transfers and international trade operations. Authorities will conduct strategic analyses of capital outflows facilitated through fictitious foreign economic contracts, a practice often linked to trade-based money laundering and value-transfer schemes. In addition, the Government will prepare recommendations aimed at strengthening tax controls on foreign economic contracts that require full prepayment before goods are actually imported—a high-risk mechanism often exploited for illicit fund transfers. Banks will also receive enhanced methodological guidance to assess the economic purpose of cross-border payments, enabling them to better identify unusual activity related to fake import-export operations or invoice manipulation. Together, these measures directly address vulnerabilities in Kazakhstan’s financial system that have historically facilitated illicit capital flight.

Combatting Illegal Cash-Out Schemes

Illicit cash-out operations represent a major money-laundering risk, and the Resolution dedicates significant resources to understanding and preventing them. Authorities will analyse types of cash-out transactions that are not currently captured in AFM reporting systems, thereby identifying blind spots in existing monitoring mechanisms. A specialised methodology will be designed to calculate the volume of criminally derived funds being withdrawn in cash, followed by the introduction of new statistical formats for collecting and tracking such data. Once these tools are operational, the AFM will conduct regular twice-yearly monitoring to assess the scale and trends of illegal cash withdrawals. Suspicious transaction indicators within the financial monitoring rulebook will also be updated to help banks detect cash-intensive schemes more effectively. This unified approach strengthens oversight of cash-based ML patterns and enhances Kazakhstan’s national risk-assessment capabilities.

Enhanced Regulation of Digital Assets and VASPs

Recognising the increasing ML/TF risks associated with digital assets, Kazakhstan introduces a forward-looking regulatory framework targeting virtual asset service providers (VASPs). A sectoral risk assessment of digital-asset-related operations within the Astana International Financial Centre (AIFC) will be completed, and new statistical mechanisms will be developed to monitor criminal cases involving crypto-assets. The Resolution requires authorities to assess the legal responsibility of foreign, unlicensed VASPs operating in Kazakhstan, reflecting a strong commitment to regulating cross-border digital-asset activity. Suspicious transaction indicators will be updated to address illegal digital-asset turnover, while typologies outlining crypto-related laundering schemes will also be developed. Additional measures include blocking unlicensed VASP applications on major platforms such as AppStore and PlayMarket and establishing a national register of high-risk crypto wallets by the end of 2026. These initiatives align Kazakhstan with FATF Recommendation 15 and global best practices in virtual-asset regulation.

Property and Real Estate AML Measures

The Resolution places significant emphasis on mitigating risks in the real-estate sector, a globally recognised channel for laundering large sums of money. Authorities will analyse real-estate transactions reported to AFM to identify ML risks and will develop tools for financial monitoring entities to assess market prices based on location, property type, size, and other factors. Banks and real estate agents will receive tailored guidance to enhance due diligence procedures, particularly with respect to beneficial ownership verification and the identification of legitimate sources of funds. New indicators will be designed to assess sector-specific vulnerabilities, while a specialised methodology will be created to detect signs of unexplained wealth through the purchase of elite property without documented legal income. Statistical record-keeping mechanisms will also be established to track luxury property associated with questionable wealth sources. Collectively, these reforms bring Kazakhstan closer to FATF standards for transparency in real-estate transactions.

Oversight of Precious Metals, Stones, Jewellery and Luxury Goods

To address ML risks in high-value goods, the Resolution outlines a series of supervisory enhancements. Authorities will analyse transactions involving precious metals, stones, and jewellery that are not currently reported to the AFM, thereby identifying gaps in market oversight. Methodological recommendations will be provided to industry operators to help them verify whether their clients’ spending aligns with official income levels, and new statistical tools will be developed to measure the criminal misuse of precious metals and jewellery assets. Awareness initiatives will be conducted regularly to ensure that operators understand their legal obligations to report suspicious activity. Furthermore, the Resolution introduces a unique coding system for transactions involving luxury goods—following amendments to the national Tax Code—allowing the AFM to better track high-value purchases. Quarterly monitoring of luxury-goods transactions and the addition of suspicious transaction indicators for automotive purchases further strengthen the regulatory framework for this vulnerable sector.

Strengthening Corporate Transparency and Beneficial Ownership Controls

The misuse of legal entities and foreign structures for concealment remains a critical AML concern, and Kazakhstan’s Resolution addresses it comprehensively. A sectoral risk assessment will examine the use of domestic and foreign legal structures in money-laundering schemes, while suspicious transaction indicators for such operations will be updated accordingly. Authorities will also develop a risk-profiling framework for legal entities, implementing a risk-based approach that aligns with FATF Recommendations 24 and 25 on beneficial-ownership transparency. The introduction of typologies related to the misuse of trust structures further enhances corporate transparency requirements and strengthens the country’s ability to prevent the concealment of illicit funds through complex ownership layers.

Strengthening Controls in the Gaming and Tourism Sectors

The Resolution also introduces enhanced oversight mechanisms for the gaming sector. It mandates the expansion of information transmitted through integrated IT systems used by gambling operators, building on previous regulatory requirements issued in 2024. This update ensures that the AFM receives more comprehensive and timely data on transactions occurring within the gaming industry, a sector known internationally for elevated ML/TF risks. By increasing transparency and ensuring systematic data collection, Kazakhstan aims to better identify unusual betting patterns, cash flows, and other potential indicators of illicit financial activity.

Combating Financing of Terrorism and Weapons Proliferation

Kazakhstan has reaffirmed its commitment to preventing terrorism financing and the financing of weapons of mass destruction by introducing a multi-year national action plan. A new strategy covering the period 2025–2027 will be developed, focusing on strengthening regulatory mechanisms and enhancing cooperation between intelligence, law-enforcement, and financial-monitoring institutions. In addition, the Resolution calls for the creation of specialised training courses for financial monitoring entities to deepen their understanding of proliferation financing risks. These steps reinforce Kazakhstan’s compliance with FATF Recommendation 7 and relevant UN Security Council obligations, signalling the country’s intention to maintain a robust national security posture.

Conclusion

Kazakhstan’s Government Resolution No. 934 marks a pivotal milestone in the country’s ongoing efforts to build a modern, risk-based AML/CFT ecosystem. Through 44 interconnected measures spanning digital assets, cross-border payments, real estate, high-value goods, corporate transparency, and financial monitoring, Kazakhstan demonstrates a clear commitment to strengthening its financial-crime prevention capabilities. This comprehensive framework not only aligns with evolving FATF standards but also reinforces national resilience against illicit financial flows, enhances supervisory efficiency, and promotes greater transparency across high-risk sectors. As implementation progresses, these measures are expected to significantly elevate the country’s overall AML/CFT maturity and global compliance standing.

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