ALUMNI Partners highlights the latest regulatory developments in the Republic of Kazakhstan (the “RK”) setting restrictions in respect of non-residents’ legal status and financial activities in the RK.

1. RESTRICTIONS ON NON-RESIDENTS’ PAYMENT CARDS

With a view to reducing the risks of using banking services in illegal activities, including turnover of drugs and digital assets, the RK Agency for regulation and development of the financial market introduced amendments into the legal acts[1] regulating financial operations with effect from 19 January 2025[2]. Here are the most significant enactments affecting non-residents:

1.1. Limitation of the validity period of payment cards

(a) the validity period of payment cards is capped at 12 months;

(b) exemptions are made for entrepreneurs and business entities, diplomatic professionals and investors[3];

(c) the new rules do not apply to bank cards issued before 19 January 2025.

1.2. Limitation of the number of payment cards

(a) the maximum number of payment cards per non-resident has been reduced from ten to five issued by:

(I) one bank;

(II) three banks out of which more than three payment cards are issued by each bank per non-resident (provided the bank has such information).

(b) exemptions are made for additional payment cards issued to children and credit cards used only for granting and repaying bank loans[4].

1.3. Stricter requirements on issuance of payment cards

(a) personal presence is now required for establishing and extending business relations and when more than one payment card is issued and re-issued to clients who are residents in countries with a high risk of money-laundering/financing of terrorism[5] with reference to the factor of illegal production, turnover and/or transit of drugs;

(b) an exemption is made for EAEU countries whose residents need to submit documents substantiating their stay in the Republic of Kazakhstan (employment contract, education contract, a foreigner’s residence permit and other documents)[6].

2. ISSUE OF PERSONAL IDENTIFICATION NUMBERS TO FOREIGN CITIZENS THROUGH RK FOREIGN MISSIONS SUSPENDED

ALUMNI Partners also highlights that, with effect from 1 January 2025, issue of PINs[7] to foreign citizens through RK foreign missions is temporarily suspended.

This is due to expiry of the pilot project “Assignment of personal identification numbers to foreign citizens through the foreign missions of the Republic of Kazakhstan” on 31 December 2024[8].

In practical terms, it means that:

(a) foreign citizens intending to receive a PIN should take into account suspension of this service by foreign missions. If the process is resumed or organised differently, an additional notice will follow;

(b) if this service is needed before it is resumed through RK foreign missions (for reference: in 2024, the service was resumed in April), foreign citizens can receive their PIN in the RK directly by filing an application with any branch of NAO State Corporation “Government for citizens” either personally or through a representative acting pursuant to a notarised power of attorney.

ALUMNI Partners legal updates are a brief overview of new developments in law and law enforcement and should not be viewed as a legal opinion or advice.

If you have any questions or comments in relation to this legal update, please contact us and we will be happy to discuss them.