Introduction

In Kazakhstan, the risk assessment criteria in the area of anti-money laundering and counter-terrorist financing (AML/CFT) have been updated.

The changes were approved by a joint order of the Chairman of the Financial Monitoring Agency of the Republic of Kazakhstan dated 5 January 2026 No. 1 and the Acting Minister of National Economy of the Republic of Kazakhstan dated 6 January 2026 No. 1.

The document comes into force on 23 January 2026.

The order was developed within the framework of the Law “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on AML/CFT and Countering the Financing of the Proliferation of Weapons of Mass Destruction” and has been aligned with the Entrepreneurial Code of the Republic of Kazakhstan.

CONTROLLED ENTITIES

Controlled entities include, among others:

  • accounting firms and professional accountants;
  • legal consultants and independent legal professionals;
  • individual entrepreneurs and companies engaged in unlicensed leasing activities;
  • intermediaries in real estate tansactions;
  • participants in the market of precious metals, stones, and jewellery;
  • mobile network operators;
  • the State Corporation “Government for Citizens”;
  • the Social Health Insurance Fund.

 HOW RISK ASSESSMENT IS CONDUCTED

Risk assessment is carried out in two stages:

  1. based on objective criteria, taking into account the entity’s area of activity;
  2. based on subjective criteria, considering the results of the entity’s activities.

Based on the assessment, one of the following risk levels is assigned:

  • high — from 71 to 100 points;
  • medium — from 31 to 70 points;
  • low — from 0 to 30 points.

RISK LEVEL CLASSIFICATION

Under objective criteria, the high-risk category includes:

  • entities engaged in activities involving jewellery made of precious metals and stones;
  • mobile network operators;
  • the Social Health Insurance Fund.

The medium-risk category includes:

  • accounting firms and professional accountants;
  • unlicensed lessors;
  • legal consultants involved in transactions with clients’ funds and property;
  • real estate market intermediaries;
  • participants in the circulation of precious metals and stones.

The low-risk category includes:

  • independent legal professionals involved in certain types of operations.

SUPERVISORY MEASURES DEPENDING ON RISK LEVEL

For entities with high and medium risk levels, the following measures may be applied:

  • preventive control with an on-site visit;
  • preventive control without an on-site visit;
  • unscheduled inspections.

For entities with a low risk level, the following measures apply:

  • preventive control without an on-site visit;
  • unscheduled inspections.

Preventive control with an on-site visit may be conducted no more than twice a year.

FACTORS CONSIDERED IN RISK ASSESSMENT

The assessment takes into account:

  • reports and information submitted by the entity;
  • results of previous inspections and preventive controls;
  • information from government authorities;
  • outcomes of preventive control without an on-site visit.

If at least one gross violation is identified, the entity is automatically assigned the maximum risk level and included in the plan for preventive control with an on-site visit.

Entities that have fully eliminated previously identified violations are not included in control lists for the next period.

RISK ASSESSMENT AUTOMATION

Risk assessment and management will be carried out using an information system that automatically:

  • assigns entities to risk levels;
  • generates lists for supervisory control.

In the absence of such a system, the number of entities subject to inspections must not exceed 5% of the total number.

VIEW APPENDIX 1 – Severity levels of violations of the legislation of the Republic of Kazakhstan on AML/CFT and countering the financing of the proliferation of weapons of mass destruction.

VIEW APPENDIX 2 – List of subjective criteria for determining risk levels based on subjective indicators.

Source: Uchet.kz