AML Documents for AIFC and Kazakhstan Licensing
A licence application is read by a person who looks for contradictions in your documents. We prepare a pack where the documents agree with each other and with how the firm will actually operate.
- Duration
- Two to five weeks
- Format
- Remote
- Result
- Document pack and answers to comments
What the pack contains
The exact contents depend on the licence you are applying for and on who issues it, but the core repeats from application to application.
- AML internal control rules built for your business, not generic ones
- The enterprise risk assessment with its methodology and conclusions
- Customer due diligence procedures, including enhanced due diligence and politically exposed persons
- Sanctions screening and transaction monitoring procedures
- The role and powers of the responsible officer, how they are appointed and who they report to
- The staff training programme and how records are kept
- A description of the business model and the flow of funds. Nothing shows more clearly whether the documents were written apart from the real business.
How the work runs
First we work out which regime fits you and what the specific authority requires, and only then start writing.
We do
Before filing
- We confirm the list of requirements for the chosen regime and activity.
- We gather the data about the firm, its products, customers and geography.
- We prepare the pack and review it with you piece by piece, rather than in one block at the end.
You do
Filing
- The application is filed by the applicant. We do not act as your representative before the registrar or the regulator.
Together
Review
- We work through the regulator's comments and draft the answers; you submit them.
If it emerges along the way that the declared model does not match how the firm intends to operate, we say so before filing. A contradiction found by the regulator costs more.
What we do not do
We do not guarantee that a licence will be granted. The decision belongs to the authority, and anyone promising the result is promising something that is not theirs.
We do not write procedures you have no intention of following.
A document that diverges from practice creates risk rather than removing it.
What you get
The AML document pack
Internal control rules, the risk assessment, and the procedures for customer due diligence, screening and monitoring.
Business model and fund flows
How the business works and how money moves, in the form a regulator reads it.
Roles and training
The responsible officer, their powers and reporting line, the training programme and the records.
Answers to comments
The regulator's questions during the review, worked through and answered.
Timing
The timeline depends on the chosen regime and the size of the pack. We name it more precisely after the first look at your situation.
Frequently asked questions
How is this different from developing internal control rules?
Internal control rules are one document inside the pack. Here the task is wider, tied to a filing date, and the contents are set by the requirements of the chosen regime.
When is the best time to start?
Before filing, once the business model is clear. The earlier the documents are reconciled with how the firm will work, the fewer grounds there are for comments during the review.
Would generic templates from open sources do?
As a reference point yes, as a pack no. A generic document is recognised immediately, and the first question becomes how it relates to your business.
What if the requirements change after the licence is granted?
The pack has to be updated. That is separate work, and we say so in advance rather than after the change.
What does it cost?
The fee depends on the regime, the type of activity and the size of the pack. We name an exact figure after the first look at your situation and fix the scope in the contract.
Shall we look at your case?
Tell us the task and we will say whether it needs the full piece of work or a narrower one.
Book a consultationNorthhold Advisory is an independent consultancy. We are not affiliated with, and do not represent, the AFM of Kazakhstan, the AIFC (AFSA) or the National Bank of Kazakhstan.