On approval of the Financial Monitoring Development Concept for 2022-2026
Decree of the President of the Republic of Kazakhstan dated October 6, 2022 No. 1038.
I DECREE:
1. To approve the attached Financial Monitoring Development Concept for 2022-2026 (hereinafter referred to as the Concept).
2. Central government agencies, government agencies directly subordinate to and accountable to the President of the Republic of Kazakhstan, as well as interested organizations (as agreed) responsible for the implementation of the Concept:
1) take measures to implement the Concept;
2) provide information on the implementation of the Concept in accordance with the procedure and deadlines established by the Decree of the Government of the Republic of Kazakhstan dated November 29, 2017 No. 790 "On Approval of the State Planning System in the Republic of Kazakhstan".
3. The Agency of the Republic of Kazakhstan for Financial Monitoring shall take the measures resulting from this Decree.
4. Control over the implementation of this Decree is entrusted to the Administration of the President of the Republic of Kazakhstan.
5. This Decree shall enter into force from the date of its signing.
President of the Republic of Kazakhstan
K. TOKAEV
Approved by Decree of the President of the Republic of Kazakhstan on October 6, 2022 No. 1038
Financial Monitoring Development Concepts for 2022-2026
Astana, 2022
content:
Section 1.
Concept Passport
Section 2.
Analysis of the current situation
Section 3.
Overview of international experience
Section 4.
Vision of financial monitoring development
Section 5.
Basic principles and approaches for the development of financial monitoring
Section 6.
Target indicators and expected results
Section 7.
Action plan for the implementation of the Concept (appendix)
Section 1. Passport
The footnote. Section 1 as amended by Decrees of the President of the Republic of Kazakhstan dated 03/19/2025 No. 823; dated 08/26/2025 No. 975.
Name
Financial Monitoring development Concept for 2022-2026
The basis for the development
Instruction of the President of the Republic of Kazakhstan (resolution No. 21-5006 dated December 11, 2021)
The government agency responsible for the development of
Agency of the Republic of Kazakhstan for Financial Monitoring
Government agencies and organizations responsible for implementation
MU, AZRK, GP, EOM, M3, MTZN, VS, MF, AFM, ARFR, MCI, ADGS, MP, MPS, MIT, BNS ASPR, MFA, MTS, NB, KNB, MNE, ICRIAP, Ministry OF Internal Affairs
Terms of implementation
2022-2026 years
Section 2. Analysis of the current situation
2.1. Achieved results
The financing of terrorism and the legalization of criminal proceeds are recognized by the world society as global problems of a transnational nature and capable of undermining the existence of the State system.
Acts of terrorism can cause large-scale conflicts of a political, territorial and national nature. In turn, laundering of criminal proceeds harms the economic interests of the state, having a negative impact on fair competition and increasing the volume of the shadow economy.
Moreover, the causal factor of the vast majority of criminal acts is a selfish motive, which determines the priority of focusing efforts on solving criminal offenses related to money laundering.
In this regard, countering the legalization (laundering) of criminally obtained funds and the financing of terrorism (hereinafter referred to as AML/CFT) is becoming an extremely urgent task and necessitates the adoption of collective and effective measures by all States, both at the national and international levels.
Today, a stable AML/CFT system has been established in the Republic of Kazakhstan.
It includes a set of government, law enforcement and special agencies that implement state policy in the field of AML/CFT, in interaction and interconnection with financial monitoring entities.
The formation of the AML/CFT system of the Republic of Kazakhstan can be divided into three stages.
The first stage (2000-2008).
The United Nations Security Council Resolution of July 29, 2005 requires all Member countries of the United Nations (hereinafter referred to as the UN) to implement the recommendations of the Financial Action Task Force on Money Laundering (hereinafter referred to as the FATF).
In order to implement these recommendations, a separate type of criminal offense has been criminalized - the legalization (laundering) of money and other property acquired illegally.
International conventions have been ratified: on combating the financing of terrorism dated October 2, 2002, the United Nations against Corruption dated May 4, 2008 and the United Nations against Transnational Organized Crime dated June 4, 2008.
In 2004, in order to ensure economic security and prevent threats to financial stability, Kazakhstan became one of the founders of the FATF regional group, the Eurasian Group on Countering Money Laundering and Financing of Terrorism (EAG).
Its main activities are to ensure effective interaction and cooperation at the regional level, as well as integration at the level of the EAG member States into the international AML/CFT system.
The second stage (2008-2020).
In 2008, in order to implement the provisions of international acts obliging countries to establish a unit that will serve as a national center for the collection, analysis and dissemination of AML/CFT information, a financial intelligence unit was established in the form of a Financial Monitoring Committee within the Ministry of Finance of the Republic of Kazakhstan (such bodies have been established in 163 countries).
In 2009, the Law "On Countering the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism" (hereinafter referred to as the AML/CFT Law) was adopted, which laid the legal foundation for the formation of state policy in the field of AML/CFT.
He defined the basics of interaction and the terms of reference of government and law enforcement agencies, as well as subjects of financial monitoring, and introduced basic concepts.
At the same time, a unique information system for collecting and processing data from financial monitoring entities has been created that meets international quality and safety standards.
Agreements on interaction and cooperation have been concluded both between government agencies and with countries of the near and far abroad.
In 2011, Kazakhstan became a full member of the Egmont group of financial intelligence units, which increased the effectiveness of cooperation with financial intelligence agencies of foreign countries.
An active information exchange has begun with more than 100 financial intelligence units around the world.
Under the coordination of the Financial Monitoring Committee of the Ministry of Finance of the Republic of Kazakhstan, the AML/CFT system has successfully passed the first mutual assessment of the EAG.
The implementation of the fundamental norms of the UN Security Council resolutions and FATF standards regarding the activities of the financial intelligence unit, the powers and responsibilities of law enforcement agencies, international cooperation and mutual legal assistance and extradition, as well as enforcement of confiscation measures allowed Kazakhstan to receive ratings of "significantly compliant" and "partially compliant" with 24 of the 40 FATF recommendations.
Based on the results of the mutual assessment, Kazakhstan was subjected to the "standard monitoring" procedure, a monitoring mechanism applied to all EAG member states that do not have significant deficiencies in technical compliance with FATF recommendations and the AML/CFT system.
The recommendations developed by the EAG experts based on the results of the mutual assessment formed the basis for measures to improve the national AML/CFT system.
In order to develop measures to implement state AML/CFT policy, increase their effectiveness, and coordinate measures aimed at reducing the risks of money laundering and terrorist financing, an Interdepartmental Council on the Prevention of Money Laundering and Terrorist Financing has been established.
Conceptual amendments have been made to the national AML/CFT legislation:
A government regulatory body has been identified for four types of financial monitoring entities (realtors, lawyers, leasing companies, accounting organizations, and professional accountants).;
the responsibility of all financial monitoring entities for non-compliance with the requirements of the AML Law has been strengthened/ft;
The state body responsible for the accounting and use of confiscated property and the formation of a fund for such property has been identified.;
International cooperation has been strengthened regarding the exchange of information in the field of AML/CFT between financial control authorities and law enforcement agencies with foreign competent authorities.;
The operations of public officials have become subject to financial monitoring.
In 2014, Kazakhstan joined the Council of Heads of Financial Intelligence Units of the Member States of the Commonwealth of Independent States (hereinafter - CIS).
Another feature of this stage is the holding in 2018 of the first national assessment of the risks of money laundering and terrorist financing (hereinafter referred to as ML/FT), which identified and minimized the key ML/FT risks and vulnerabilities of the national AML/CFT system.
The third stage (from 2021 to the present).
The status of the financial intelligence unit has been increased by creating an independent and accountable body to the President of the Republic of Kazakhstan - the Financial Monitoring Agency of the Republic of Kazakhstan (hereinafter referred to as the Agency).
A characteristic feature of this body is the integration of financial monitoring functions in it, as well as the disclosure and investigation of economic offenses.
This synergy has further increased the effectiveness of the analytical work carried out, and has allowed us to shift the focus of work both in terms of prevention and in terms of dealing with consequences.
Today, the financial intelligence unit occupies a unique position in the AML/CFT system, being at the junction of the activities of financial institutions, as well as law enforcement and authorized bodies.
At the first level, financial monitoring entities identify suspicious transactions and transactions that fall under the criteria established by the AML/CFT Law, form special reports about them, and send them to the financial intelligence unit.
Each financial monitoring entity has a government regulatory body that monitors its activities.
At the second level, the financial intelligence unit processes and analyzes in detail the information received about suspicious financial transactions, and additional information is requested, including from the financial monitoring entities themselves and various government agencies.
The result of such an analysis is a conclusion on the presence or absence of signs of money laundering or terrorist financing in the information provided by the subjects of financial monitoring, which is sent to law enforcement agencies for the organization of verification activities.
At the third level, law enforcement agencies conduct verification activities, based on the results of which a decision is made to initiate a pre-trial investigation.
In 2021, the second national ML/FT risk assessment was conducted, which identified the main risks, threats and vulnerabilities.
An analysis of criminal law statistics has shown that in the Republic of Kazakhstan, crimes with a high risk of ML/FT are: tax crimes, illegal economic activity, corruption, embezzlement of budget funds, fraud and drug trafficking.
A high ML/FT risk is attributed to the banking sector, the sector of microfinance organizations, as well as the gambling business.
Based on the results of the national risk assessment, all participants in the AML/CFT system are implementing measures aimed at reducing identified risks and vulnerabilities.
In general, the dynamics of the AML/CFT system development in the Republic of Kazakhstan in the period from 2019 to 2021 demonstrates positive results.
The number of financial monitoring entities covered by the AML/CFT system increased from 6,000 to 9,000, including 2,000 entities from the financial sector and 7,000 entities from the non-financial sector. Thus, the level of cooperation between financial monitoring entities and the Agency increased by 50%.
During the specified period, more than 5 million reports of suspicious and threshold transactions were received from financial monitoring entities. At the same time, 99% of the messages were sent by the financial sector.
2,132 analytical materials were sent to law enforcement and special government agencies.
As a result of the adoption of comprehensive measures to improve analytical work, the effectiveness of the use of financial intelligence unit materials by law enforcement agencies increased from 43.6% to 64%.
The procedure for interaction between the financial intelligence unit, law enforcement and special government agencies on requests has been simplified. Work has begun on the introduction of parallel financial investigations.
In this regard, there has been an increase from 42 in 2019 to 56 in 2021 (by 33%) in the registration of offences related to the laundering of proceeds from crime.
The regular improvement of the AML/CFT system is evidenced by the trend of improvement in Kazakhstan's performance in the international index of the Basel Institute of Management on combating money Laundering: from 6.27 points in 2019 to 4.87 points in 2021.
2.2. Main problems and trends.
Despite the ongoing reforms, systemic problems remain, which include:
1) imperfect information work and training system in the field of/ft;
2) imperfection of the regulatory framework;
3) imperfection of analytical approaches;
4) insufficient automation of data analysis processes;
5) the risks of using digital assets in laundering criminal proceeds and financing terrorism;
6) insufficient attention is paid to the issues of establishing and returning proceeds from crime.
Imperfect information work and education system in the field of AML/CFT
The Council of Europe's Expert Committee on the Evaluation of Anti-Money Laundering Measures notes that one of the key elements of building a reliable AML/CFT system is the continuous training of its participants.
Despite the fact that AML/CFT is one of the priorities for law enforcement agencies and the financial sector, there is an erroneous stereotype that AML/CFT issues are "narrowly focused" and are more necessary for the financial intelligence unit.
At the same time, international experience shows that almost all financial monitoring entities in various spheres of life (accountants, lawyers, notaries, realtors, company managers, etc.) can be involved in money laundering and terrorist financing schemes.
The situation is aggravated by insufficient information work and lack of systematic training in the basics of AML/CFT and financial security.
Information on financial security in the context of ML/FT risks, adapted for different age groups, is not shared with citizens.
It should also be noted that currently there is no single educational center in Kazakhstan that trains specialists in the field of AML/CFT.
The current practice of training government, law enforcement and special agencies is to conduct one-time thematic trainings and seminars. The effectiveness of this approach is offset by staff turnover.
At the same time, the relevant subjects and disciplines in higher education institutions are not provided. This complicates the formation of a pool of qualified candidates for further selection into the talent pool.
During the 36th EAG Plenary Meeting, held on May 30, 2022 in Tashkent, the EAG Working group on mutual assessments and legal issues noted the lack of activity of delegations in providing qualified evaluators and reviewers for mutual assessments. This leads to the fact that some Member States rarely participate or do not participate at all in the mutual assessment processes.
The most common reason why experts are not ready to participate in mutual assessment is their superficial knowledge of FATF standards. Therefore, prior training in standards (prior to training for evaluators) will be a mandatory requirement of the EAG.
Imperfection of the regulatory framework
The developed system of countering the legalization (laundering) of criminally obtained funds and the financing of terrorism consists of institutional and legislative measures.
As you know, in a State governed by the rule of law, effective legislation is the most important condition for combating various socially dangerous phenomena, including the legalization of criminal funds and the financing of terrorism.
Despite its high regulatory effectiveness, the AML/CFT Law retains the shortcomings identified in the course of law enforcement practice, and also does not comply with certain FATF international recommendations, which are mandatory by virtue of UN Security Council Resolution 1617.
In particular, the rights and obligations of financial monitoring entities, other organizations and citizens are contained in various articles of the AML/CFT Law, which, of course, complicates the perception of the provisions of the regulatory legal act and, consequently, its compliance.
In addition, the Institute of International Finance in its expert report "The International System for Combating Financial Crimes" notes that the inconsistent application of international standards leads to the appearance of "loopholes" that can be used for money laundering purposes.
The reason preventing the achievement of potential positive effects is the lack of strategic and programmatic documents defining the main vision for the development of the national AML/CFT system, taking into account the identified risks.
Imperfection of analytical approaches
The ability of financial monitoring entities to identify and minimize risks is a key factor in ensuring the reliability of the AML/CFT system.
The current practice of reporting only suspicious or threshold transactions does not allow maximizing the potential of financial monitoring entities.
An assessment of just one transaction may not arouse suspicion, whereas a series of related transactions and a complete picture of the activities of individuals and organizations allow us to draw more comprehensive and complete conclusions about involvement in money laundering and terrorist financing.
The quality of the information provided is also affected by the lack of proper feedback in the form of information about the decision made on each message from financial monitoring entities.
The subjects of financial monitoring cannot fully assess the usefulness of the messages they send. The lack of feedback also reduces the ability of financial monitoring entities to improve their approaches to detecting suspicious transactions and improving the quality of messages sent.
In such circumstances, the resources of financial monitoring entities are focused on preparing reports, rather than on deeper risk analysis, which is of the greatest interest to financial intelligence units and law enforcement agencies.
Insufficient automation of data analysis processes
Well-established cooperation and an effective information exchange system between financial monitoring participants play a key role in AML/CFT risk management.
Today, the Unified Information Analytical System in the field of countering the legalization (laundering) of proceeds from crime and the financing of terrorism (hereinafter - EIAS) is integrated with the databases of the Ministries of Justice and Finance (information on legal entities and individuals, personal accounts, etc.). At the same time, the process of collecting and processing information is partially automated and is carried out in the "request-response" mode. The financial intelligence unit receives other information necessary for analysis outside of integration on the basis of requests (information on tax reports, public officials, property, etc.). This affects the efficiency of work, since for a full and high-quality analysis, it is necessary to have a large amount of data that allows you to identify ML/FT schemes.
With the current state of automation and integration of EIAS, it takes time to obtain information and the manual labor of analysts is saved during its processing.
There are no necessary tools for analyzing big data from open sources.
Similar problems of operational information exchange are observed between government regulators and financial monitoring entities.
The current functionality of the unified portal of the subjects of the AML/CFT system does not allow for the rapid exchange of information and information between the participants of the AML/CFT system.
In particular, government agencies analyze the activities of financial monitoring entities under their control based on information provided in response to their requests.
This approach is time-consuming and creates risks of failure by government agencies to take timely preventive measures in case of violation by controlled entities of the requirements of legislation in the field of AML/CFT.
In turn, financial monitoring entities need a prompt response from the state regulatory body to issues in their current activities that require clarification or methodological support.
The risks of using digital assets in laundering criminal proceeds and financing terrorism
There is a rapid growth of the digital asset market in the world. Kazakhstani citizens are active users of online platforms that trade cryptocurrencies.
According to the Basel Institute of Management's report "Cryptocurrencies in Asia and Beyond: Legislation, Regulation, and Enforcement," in 2021, Kazakhstan became the world's second largest cryptocurrency miner.
Meanwhile, the use of digital assets and tools such as mixers and protocols with zero disclosure of data about senders, recipients and amounts makes it impossible to fully monitor such financial transactions.
The lack of approaches that make it possible to de-anonymize all participants in digital asset transactions is a challenge for the current global AML/CFT system and necessitates its improvement.
The issuance and circulation of unsecured digital assets in the territory of the Republic of Kazakhstan is prohibited, except in cases provided for by law. This is the turnover of unsecured assets under the special legal regime of the Astana International Financial Center (hereinafter referred to as the AIFC) and is regulated by the rules of FinTechRules financial technologies.
In order to create balanced regulatory conditions for the creation and operation of AIFC crypto exchanges, measures are being taken to implement a pilot project for the operation of crypto exchanges on the AIFC site in cooperation with Kazakhstani banks and government agencies, one of the issues of which is the possibility of opening bank accounts for AIFC crypto exchanges.
According to reports from Chainalysis, the global adoption of cryptocurrencies increased by 880% in 2021, mainly due to the activity of P2P trading (a form of transaction between individuals in which the buyer and seller exchange funds directly with each other).
Currently, not all digital assets are anonymous. Many cryptocurrency exchanges and exchange services require the opening of a personalized account to work with digital systems. However, their extraterritoriality does not allow using this potential.
In turn, the anonymous nature of digital assets creates high risks of their use for making payments in the framework of illegal activities, including money laundering, terrorist financing, drug and arms trafficking, corruption, illegal withdrawal of funds abroad, etc.
Despite the ban on the release and circulation of unsecured digital assets in the territory of the Republic of Kazakhstan established by the norms of the Law "On Informatization", liability for its violation is not provided.
The current procedure for the seizure, accounting, storage, transfer and destruction of physical evidence and money in criminal cases does not provide for specifics related to digital assets.
There are no tools for seizing, accounting, storing, or transferring digital assets as part of criminal investigations.
At the same time, due to the global nature of digital assets and differences in regulation in different countries, there is a risk of transactions spilling over into jurisdictions with a more loyal regulatory regime.
Insufficient attention to the issues of identification and return of proceeds from crime
It is also important to exclude the benefits of ML through the search and return of proceeds from crime during parallel financial investigations.
An analysis of the criminal procedure legislation shows that the confiscation of proceeds of crime and compensation for damages are not priorities.
In this regard, the efforts of the pre-trial investigation authorities are focused on uncovering offenses and exposing the perpetrators. In turn, measures to identify and confiscate criminal proceeds are given secondary importance.
As practice shows, a long period of time passes from the moment the pre-trial investigation begins to the adoption of measures to identify, arrest and confiscate assets obtained by criminal means, which subsequently complicates ensuring their return.
The situation is aggravated by the withdrawal of criminal assets abroad, which directly affects economic security, damages the state budget, leads to a shortage of investments and working capital for economic development, reduces both investment attractiveness and public confidence in the state apparatus.
According to international ratings, Kazakhstan is among the 20 countries with "stable" capital outflow abroad. The return of illegally obtained assets from abroad is accompanied by a whole range of problems.
The execution of requests for legal assistance by the competent authorities of a foreign State takes a long time. The practice of law enforcement agencies to return assets from abroad, when the focus is on convictions and sentences only in Kazakhstan, and general requests are sent abroad without specific information about assets, is absolutely ineffective. Such requests are regarded worldwide as "fishing for evidence" and are not executed.
In some cases, this problem is caused by the lack of comprehensive information and analytical work prior to the initiation of criminal proceedings, including through a parallel financial investigation.
In addition, there are generally no mechanisms for monitoring and evaluating the measures taken to return criminally acquired income to the State, both domestically and from abroad. This does not allow for the development of appropriate corrective measures.
There is no methodology for calculating the volume of illegal financial flows.
The current statistics do not reflect the real picture of the confiscation of property obtained by criminal means.
In particular, there is no unified accounting of information on the amounts actually received by the state from confiscated property, including in the context of areas of legal relations (within the framework of criminal, civil and administrative cases) and articles of criminal and administrative legislation.
The information provided by the State Property and Privatization Committee of the Ministry of Finance of the Republic of Kazakhstan on the amounts received from the confiscated property also does not reflect the real picture, since movable and immovable property transferred to the communal property balance is treated at zero cost.
The cost of the sale of confiscated property in the framework of enforcement proceedings, as a rule, is underestimated.
Similarly, the reports of law enforcement and local executive bodies do not classify confiscated items into instruments of crime and criminally acquired property, and the amount of confiscated property is not reflected.
Section 3. Review of international experience
The practice of developed countries shows that building an effective AML/CFT system begins with a nationwide approach to educating citizens from an early age on the basics of financial literacy and security. Financial literacy and security represent the personal contribution of every citizen to ensuring the economic and financial security of the country.
For example, in the United States, federal and public programs are being implemented to improve financial literacy.
The Finance and Pedagogy program operates in the French Republic, which educates ordinary citizens, students, and schoolchildren.
Another striking example of improving the information, financial and legal literacy of children and youth, promoting their professional orientation and the development of scientific knowledge is the holding of the International Olympiad on Financial Literacy in the Russian Federation within the framework of the activities of the Council of Heads of Financial Intelligence Units of the CIS.
The Finance and Pedagogy program operates in the French Republic, which educates ordinary citizens, students, and schoolchildren.
Another striking example of improving the information, financial and legal literacy of children and youth, promoting their professional orientation and the development of scientific knowledge is the holding of the International Olympiad on Financial Literacy in the Russian Federation within the framework of the activities of the Council of Heads of Financial Intelligence Units of the CIS.
In this regard, given that the National Development Plan of the Republic of Kazakhstan until 2025 defines the need to improve financial literacy of the population, this experience seems applicable in Kazakhstan.
A key factor in the effectiveness of the AML/CFT system is the high quality of analytical materials from the financial intelligence unit. In turn, this task cannot be solved without providing the financial intelligence unit with sufficient sources of information.
For example, financial intelligence units in the United Kingdom, the Federal Republic of Germany, and the Hellenic Republic have access to databases of law enforcement, tax authorities, and financial organizations, including registers of real estate, vehicles, land, and others. In addition, there is access to information from Europol, Interpol, Eurojust, as well as commercial databases (World Check, Dow Jones).
The use of IT tools also contributes to improving the quality of ML/FT risk analysis.
The results of the FATF study on the introduction of new technologies while ensuring compliance with AML/CFT standards have shown that artificial intelligence, application programming interfaces, and tools used by entities for customer due diligence purposes have the greatest potential.
The Central Bank of Brazil has approved a natural language processing project to improve regulatory efficiency. The project provides for the development of tools for scanning and analyzing social networks and other publicly available data in order to extract information related to suspected ML/FT.
The experience of countries applying a broader concept aimed at detecting suspicious activity is noteworthy.
For example, in New Zealand, suspicious transactions and suspicious activity are reported. Special guidelines have been created for accountable organizations to determine which type of report they need to send.
In turn, the application of such practices in Kazakhstan will significantly improve the effectiveness of analytical work.
Taking into account the constantly changing situation in the world, new ML/FT risks and vulnerabilities are emerging. In 2020, the FATF identified the misuse of budget funds allocated for state support of economic incentives as one of the threats associated with the COVID-19 pandemic.
In this regard, the experience of the Russian Federation in monitoring budget spending by the Federal Financial Monitoring Service (hereinafter referred to as Rosfinmonitoring) is interesting within the framework of the budget monitoring system, which includes treasury support, a cash flow traceability system, banking support and financial monitoring.
This practice in Kazakhstan will significantly increase the transparency of the contract execution process, eliminate unscrupulous performers and, most importantly, ensure the targeted use of budget funds.
Along with this, the experience of the Russian Federation in the remote format of interaction through the introduction of "personal accounts" for financial monitoring entities, government regulators and law enforcement agencies on the Rosfinmonitoring website is noteworthy. This made it possible to maintain the previously achieved level of interaction during the pandemic, and also reduced the burden on financial monitoring entities.
The application of this experience in Kazakhstan will be a logical continuation of the measures taken to register financial monitoring entities on the Agency's portal.
One of the risks of a global nature today is the use of digital assets. The FATF calls on all jurisdictions to take immediate legislative and practical steps to prevent their illegal use.
From June 2020 to June 2021, 27 countries were assessed for the implementation of FATF Recommendation 15, which provides for the assessment and management of risks related to digital assets. According to the results of the review, only three countries managed to improve their performance.
The need to regulate the sphere of digital asset turnover is evidenced by the increasing number of publications and statements by foreign regulators and international organizations. The Deputy Governor of the Bank of England in October 2021 said that the spread of cryptocurrencies could cause a financial crisis if strict regulatory measures were not introduced. To date, a unified approach to this issue has not been finalized. A number of countries (Vietnam, Bangladesh, Egypt, Indonesia, China, the United Arab Emirates, Turkey) have imposed a direct ban on the use of cryptocurrencies for payments, while in other countries this area is still in the "gray" zone.
Despite the unresolved issues, there are enough judicial precedents related to digital currencies in the law enforcement practice of foreign countries. Thus, the first bitcoin confiscation operation was the liquidation by US law enforcement agencies of one of the largest anonymous digital drug markets, SilkRoad, whose assets were sold at four bitcoin auctions for a total of 30 million US dollars. Further, the confiscation and sale of confiscated cryptocurrencies in the United States have become widespread.
In the Russian Federation, in 2019, the Plenum of the Supreme Court ruled that criminal liability for money laundering should also apply to cryptocurrencies.
In April 2022, the High Court of England and Wales recognized this type of digital asset as a "non-exchangeable token" property, which, accordingly, can be seized or which can be confiscated for legitimate purposes.
These practices seem to be applicable in Kazakhstan and will reduce the risks of using digital assets for criminal purposes.
It is also important to exclude the benefits of ML through the search and return of proceeds from crime during parallel financial investigations.
In the Czech Republic, specialized services have been established in the police and prosecutor's offices to conduct financial investigations. The top leadership of the police of this country has adopted the mandatory instruction "On Financial investigation", which regulates the procedure for financial investigation and seizure of income received as a result of any criminal offense committed in the country or abroad.
Taking into account the instructions of the Head of State on the implementation of the "follow the money" principle, it is proposed to apply this experience in Kazakhstan's realities.
In general, a reliable AML/CFT system should be provided with the following key elements:
continuous training of all participants of the system UNDER/ft;
applying a risk-based approach, awareness and understanding of the risks of money laundering and terrorist financing;
using a wide range of information resources and modern IT tools;
effective interaction of all participants in the AML/CFT system.
Section 4. Vision of financial monitoring development
The footnote. Section 4 as amended by Decree of the President of the Republic of Kazakhstan dated 03/19/2025 No. 823.
Kazakhstan aims to further strengthen its image as a responsible participant in the global financial community and achieve the FATF's high-level goal of strengthening the protection of the financial system and economy from the threats of money laundering and terrorist financing.
The FATF recommendations will continue to be implemented into national legislation and the level of effectiveness will be improved based on the 11 immediate FATF outcomes that define the main goals that a reliable AML/CFT system must achieve.
In general, the immediate results should contribute to:
reducing ML/FT risks;
preventing the penetration of criminal proceeds into the financial and other sectors of the economy;
timely detection and suppression of ML/FT threats with mandatory deprivation of criminals of illegal income and bringing them to justice.
This requires strong political will, the rule of law, the orientation of all participants in the system towards resolving AML/CFT issues, the maturity and development of the regulatory regime, the integrity of financial monitoring entities, stability and transparency of their activities, as well as the presence of other important factors.
To achieve this result, the coordinating role of the financial intelligence unit will be enhanced with its transformation into the information and analytical core of the entire AML/CFT system.
Taking into account that human resources play a significant role in this, conditions and opportunities for education, training and advanced training in the field of AML/CFT will be created.
Expanding information resources, improving the quality of suspicious transaction reports, automating business processes, and introducing modern technologies will make it possible to generate reliable and complete analytical materials.
In order to implement the instructions of the Head of State, given on July 1, 2021 at a meeting of the Supreme Council for Reforms under the President of the Republic of Kazakhstan, the Agency's potential will be focused on preventing inefficient spending of budget funds in the implementation of national projects.
In addition, pursuant to the Decree of the President of the Republic of Kazakhstan dated June 5, 2022 No. 908 "On the Interdepartmental Commission on Combating Illegal concentration of economic resources", comprehensive work will be carried out to return funds illegally withdrawn from the country to the Republic of Kazakhstan.
The introduction of a risk-based approach in all AML/CFT processes will allow the work of all participants in the system to be reoriented towards results and ensure a productive allocation of resources.
The search and recovery of criminally acquired assets will be identified as priority areas of development.
The intensive development of the national AML/CFT system will be a driver for the growth of competitiveness and investment attractiveness of Kazakhstan and will create opportunities for improving its status in the international arena and, as a result, further joining the FATF.
Section 5. Basic principles and approaches for the development of financial monitoring
The footnote. Section 5 as amended by Decree of the President of the Republic of Kazakhstan dated 03/19/2025 No. 823.
The AML/CFT system is based on the principles of:
1) equality of all before the law and justice;
2) protection of the rights, freedoms and legitimate interests of persons;
3) comprehensive use of measures UNDER/ft;
4) interaction between the state and financial monitoring entities;
5) Efficiency and effectiveness;
6) the inevitability of responsibility.
Approaches to the development of the AML/CFT system will consist in taking legal and institutional measures aimed at implementing FATF recommendations, taking into account Kazakhstan's realities, within the framework of obligations stipulated by the United Nations Security Council resolution of July 29, 2005.
The implementation of the vision for the development of the financial monitoring sector and the basic principles laid down in the Concept will be carried out in the following areas::
1) improving information work and increasing human resources;
2) improvement of legislation and regulations in the field of AML/ft;
3) improvement of the management system/ft;
4) monitoring and prevention of illegal activities of unsecured digital assets in the territory of the Republic of Kazakhstan;
5) increasing the importance of the search and return of proceeds from crime.
Direction 1. Improving information work and increasing human resources
In order to promote AML/CFT issues, systematic measures are needed to raise public awareness of the fundamentals of financial security and threats in this area.
During the educational process, open lectures and curatorial hours will be held in organizations of technical and vocational, post-secondary, higher and postgraduate education, revealing the basics of financial security.
National and international financial security Olympiads will be held on an ongoing basis.
Explanatory work on financial security issues will be conducted for citizens, and specialized training events will be continued for all participants in the AML/CFT system.
In order to ensure the consistency of training, the issue of organizing training and advanced training for all participants in the AML/CFT system on the basis of the International Academy of Economics and Finance will be worked out.
Training and advanced training of participants in the AML/CFT system will take place taking into account the level of responsibility and involvement in risk-prone activities (compliance services, credit officers, etc.), as well as current trends in the field of AML/CFT with the verification of acquired knowledge.
These measures will make it possible to form a pool of national experts to participate in mutual assessments of the EAG member states.
In order to further improve the skills of participants, they will take preparatory courses for certification, following the example of ACAMS (Certified Anti-money Laundering System Specialist), CFCS (Certified Financial Crimes Specialist) and others.
All this will lay the foundation for promoting the values of the AML/CFT system and building professional and competitive human resources.
Direction 2. Improvement of legislation and regulations in the field of AML/CFT
In order to ensure transparency and accessibility of the provisions of the AML/CFT Law, it is proposed to take the following measures.
First, it is necessary to provide for articles in the AML/CFT Law explaining the goals, grounds for adoption and the main tasks that it faces.
Secondly, given that public relations are in constant dynamics, it seems important to lay down principles in the AML/CFT Law that will form the basis for the formation of future norms, with specific mechanisms for their implementation.
Thirdly, it is necessary, to the extent possible, to consolidate in separate articles the norms establishing the legal status of financial monitoring entities, other organizations and citizens.
Taking into account the above, it seems necessary to introduce amendments and additions to the legislation of the Republic of Kazakhstan on AML/CFT.
Direction 3. AML/CFT system improvement
1. Improving the quality of risk assessment
The quality of primary information will be improved through the additional implementation of the practice of informing financial monitoring entities about suspicious activity.
The issue of introducing administrative responsibility for incorrect filling in of information on transactions subject to financial monitoring will be considered.
The requirements for the preparation of suspicious transaction reports will be optimized in order to efficiently allocate the resources of financial monitoring entities to a deeper analysis of transactions of the greatest interest to the financial intelligence unit and law enforcement agencies.
In order to create conditions for the subjects of financial monitoring to improve the effectiveness of the messages sent, feedback will be provided on the decisions taken, as well as the results of the analysis of the quality of messages subject to financial monitoring.
To improve the quality of AML/CFT measures in the activities of financial monitoring entities, a system for their assessment will be introduced.
Within the framework of which, compliance with the qualification requirements of those responsible for AML/CFT, the level of interaction with the state regulatory body, the completeness and quality of the organization of internal control, risk management systems, etc. will be analyzed.
Based on the results of the assessment, the Agency will make appropriate recommendations for improving the activities of financial monitoring entities.
These reforms will make it possible to reformat the work of those responsible for the implementation and observance of internal control rules (compliance services) from process activities to achieving the final result.
In order to improve the quality and completeness of the generated analytical materials, the issue of obtaining access to databases of foreign companies providing risk management and compliance services (Dow Jones, Thompson Reuters, World Check, etc.) will be worked out. This will allow analysts to monitor individuals and legal entities online for involvement in terrorist activities, the presence of regulatory sanctions in foreign countries, and other negative information.
2. Introduction of new areas of risk assessment
As part of the implementation of the legal framework for monitoring suspicious transactions of public officials, their spouses and close relatives, a mechanism for operational interaction with financial monitoring entities and the Anti-Corruption Agency of the Republic of Kazakhstan (Anti-Corruption Service) will be developed.
The areas of income laundering risk assessment will be expanded through the financial intelligence unit's monitoring of budget spending during the development period.
The analytical work will be aimed at identifying the involvement of unscrupulous performers and one-day firms and, as a result, the exclusion of criminal cashing out of budget funds and corruption schemes. Special attention will be paid to the implementation of national projects.
Measures will be developed to systematically assess the risks of money laundering and terrorist financing associated with the creation of new types of financial services.
3. Introduction of modern 1T tools
The speed of detection and suppression of offenses will be ensured through the automation of business processes and the development of information infrastructure.
In order to increase the effectiveness of analytical work, taking into account the introduction of new areas of risk assessment, the issue of expanding the list of EIAS integrations with databases of government and law enforcement agencies will be worked out.
At the same time, clear access grounds and control mechanisms for the information received will be established, eliminating the possibility of abuse, disclosure of the data received and their use for off-duty purposes.
The introduction of big data analysis tools will increase the efficiency of analytical work through mathematical data modeling and other statistical processing tools, including predictive and text analytics.
The capabilities of high and modern technologies will be used to maintain a huge amount of data, visualize it, and analyze it in retrospect and in real time. This will provide a better understanding and schematic representation of financial flows and the relationship between them and the participants in operations and, as a result, will improve the quality of analytical work.
The next step will be to work out the issue of creating a National ML/FT Risk Assessment Center in the Agency's structure. Its creation and functioning will make it possible to prioritize efforts to combat ML/FT and concentrate the main forces and resources of the national AML/CFT system on the most vulnerable areas.
The next step will be to work out the issue of creating a National ML/FT Risk Assessment Center in the Agency's structure. Its creation and functioning will make it possible to prioritize efforts to combat ML/FT and concentrate the main forces and resources of the national AML/CFT system on the most vulnerable areas.
In order to inform about the state and trends of the spread of ML/CFT risks at the international and national levels, as well as to develop proposals for improving the AML/CFT system, the issue of introducing at the legislative level the competence of the Agency to form an annual AML/CFT report and submit it to the President of the Republic of Kazakhstan will be considered.
4. Improving the mechanisms of interaction between participants in the AML/CFT system
The priority tasks in working with financial monitoring entities will be to determine their maximum coverage by the AML/CFT system using a remote monitoring mechanism.
A single portal for the subjects of the AML/CFT system will become a tool for implementing these tasks.
The operational exchange of information between financial monitoring entities and government regulatory authorities, including regarding risks in the relevant sectors of the financial and non-financial market, will be ensured through the introduction of a "Personal Account of the regulator."
Online, government regulatory authorities will be able to analyze the activity indicators of controlled entities, internal AML/CFT rules, and test results of those responsible for implementing AML/CFT functions.
In order to encourage government regulators to properly interact with controlled entities, an assessment of government regulators will be introduced. The share of controlled entities registered on the portal, the completeness and quality of measures to coordinate their activities will be assessed. Based on its results, recommendations will be made to government regulators on taking the necessary corrective measures.
To ensure the effectiveness of the portal, the issue of introducing mandatory registration of financial monitoring entities in it will be considered.
Along with this, "Personal accounts of law enforcement agencies" will be launched on the portal. This service will include accounting and monitoring of requests from law enforcement agencies to the financial intelligence unit, as well as to foreign countries through the Egmont channel, information from the financial intelligence unit about the possible commission of an illegal operation, etc.
As part of the further improvement of cooperation, the process of obtaining information from the financial intelligence unit by law enforcement and special government agencies will be automated after receiving the approval of the Prosecutor General of the Republic.
Kazakhstan, his deputies, regional prosecutors and equivalent prosecutors in accordance with the procedure established by law.
Direction 4. Monitoring and prevention of illegal activities of unsecured digital assets in the territory of the Republic of Kazakhstan
With the development of digital assets, the FATF's approaches, and then the regulatory framework of the jurisdictions, are undergoing significant changes. Fragmentation of regulation is disappearing, which helps to eliminate loopholes for criminal activities.
Thus, in accordance with paragraph 5 of Article 11 of the Law of the Republic of Kazakhstan "On Digital Assets in the Republic of Kazakhstan", the issuance and circulation of unsecured digital assets, as well as the activities of digital asset exchanges for unsecured digital assets, are prohibited on the territory of the Republic of Kazakhstan, with the exception of the territory of the Astana International Financial Center.
At the same time, according to experts, only 5% of Kazakhstani crypto investors use the AIFC platform, while the rest work in the "gray" zone.
This leads to a change in approaches to the turnover of digital assets. On behalf of the Head of State, an infrastructure for wider legal circulation of digital assets will be created.
At the same time, it is important to consider the risks of ML/FT when changing such approaches. Therefore, another sectoral assessment of the risks of using digital assets for ML/FT purposes will be carried out.
Along with this, with an active dialogue with the market, it is necessary to work out the issue of forming a new, dynamic approach adapted to the realities of Kazakhstan.
This will be facilitated by the development of fundamentally new methodological recommendations for financial monitoring entities, as well as an increase in the reporting regime on suspicious transactions related to the turnover of digital assets.
Trainings on tracking digital assets will be conducted on an ongoing basis for law enforcement and government agencies.
In addition, the issue of obtaining information about residents of the Republic of Kazakhstan related to ML/FT from international cryptocurrency trading platforms and financial intelligence units of foreign countries will be worked out.
The procedure for the seizure, accounting, storage, transfer and destruction of material evidence in criminal cases by courts, prosecutor's offices, criminal prosecution and forensic examination will be improved in terms of including features related to digital assets.
1T tools will be introduced into the work on tracking illegal financial transactions.
Taking into account the constantly changing trends in the development of the digital asset market, an analysis of the regulation of the digital asset sector will be carried out with the development of proposals for its further improvement.
Direction 5. Increasing the importance of finding and returning proceeds from crime
The return of proceeds from crime will become one of the key areas of AML/CFT development.
The FATF's 30th recommendation provides for parallel financial investigations by law enforcement and special government agencies into crimes related to money laundering, terrorist financing and the proliferation of weapons of mass destruction. Such investigations involve investigating the financial component of a crime in order to identify criminal connections and groups, search for criminal assets, sources of financing and other assets subject to confiscation, as well as collecting other evidence that can be used in court.
In order to implement this recommendation, persons responsible for the search and return of proceeds from crime will be identified in all criminal prosecution authorities.
They will receive regular training on the timely tracking, identification, seizure and confiscation of criminal assets.
Along with this, the issue of providing them with modern asset search tools, as well as the necessary databases and software products for modeling asset withdrawal schemes, including paid ones, will be worked out.
In order to strengthen cooperation with key jurisdictions, the legal framework will be expanded on an ongoing basis.
As part of strengthening asset recovery efforts, cooperation with international organizations such as the United Nations, the World Bank, the Basel Institute on Governance, the Camden Interagency Asset Recovery Network, and others will be expanded.
The positive results of the implementation of the approaches for the search and return of criminal proceeds provided for in this Concept will be used in the development by the responsible authorized bodies of the vision for the legislative regulation of the Institute of financial investigations.
Section 6. Target indicators and expected results
The footnote. Section 6 as amended by Decree of the President of the Republic of Kazakhstan dated 03/19/2025 No. 823.
6.1. Target indicators based on the results of 2026:
1) the share of universities where open lectures on financial security issues were held,%, in 2022 - 15%, in 2023 - 25%, in 2024 - 50%, in 2025 - 60%, in 2026 - 70%;
2) the number of persons who have completed AML/CFT training and testing at AML ACADEMY JSC, one, in 2023 - 150, in 2024 -200, in 2025 - 250, in 2026 - 300;
3) the number of ratings "significant compliance" and "compliance" based on the results of the assessment by EAG experts of the compliance of the legislation of the Republic of Kazakhstan with FATF recommendations, one, in 2022 - 25, in 2023 - 25, in 2024 - 33, in 2025 - 33, in 2026 - 35;
4) the share of financial intelligence unit materials used by law enforcement and special government agencies,%, in 2022 - 68%, in 2023 - 72%, in 2024 - 76%, in 2025 - 80%, in 2026 - 84%;
5) the share of financial monitoring entities registered in the Agency's information system,% in 2022 - 50%, in 2023 - 60%, in 2024 - 70%, in 2025 - 80%, in 2026 - 90%;
6) an increase in the number of customers from licensed virtual asset providers, %, in 2022 - 5%, in 2023 - 5%, in 2024 - 5%, in 2025 - 30%, in 2026 - 30%;
7) the share of identified and seized property from the amount of damage caused (including criminal proceeds), %, in 2022 - 13%, in 2023 - 17%, in 2024 - 21%, in 2025 - 25%, in 2026 - 29%.
6.2. Expected results by the end of 2026:
Kazakhstan's receipt based on the results of the EAG Mutual Assessment:
1) As a direct result, 1 (The risks of money laundering and terrorist financing are understood, and where necessary, actions to combat money laundering, terrorist financing and proliferation of weapons of mass destruction are coordinated at the national level) - a rating of "high level of effectiveness/significant level of effectiveness";
2) As a direct result 2 (International cooperation provides the necessary information, operational financial data, evidence and promotes activities against criminals and their assets) - a rating of "high level of efficiency/significant level of efficiency";
3) As a direct result 6 (Operational financial data and all other relevant information are used appropriately by competent authorities to conduct financial investigations of money laundering and terrorist financing) - rating "high level of efficiency/significant level of efficiency";
4) As a direct result of 9 (Investigations are underway into crimes and activities related to the financing of terrorism, and those who finance terrorism are prosecuted and subject to effective, proportionate and dissuasive sanctions) - a rating of "high level of effectiveness/significant level of effectiveness";
5) As a direct result, 10 (Terrorists, terrorist organizations and those who finance them are prevented from collecting, moving and using funds, as well as from maliciously using the sector of non-profit organizations) - rating "high level of efficiency/significant level of efficiency";
6) As a direct result 11 (Individuals and organizations involved in the proliferation of weapons of mass destruction are prohibited from collecting, moving and using funds in accordance with UN Security Council Resolutions) - a rating of "high level of effectiveness/significant level of effectiveness".
Application of the Financial Monitoring Development conception2022-2026
Action plan for the implementation of the Financial Monitoring Development Concept for 2022-2026
The footnote. Appendix as amended by Decrees of the President of the Republic of Kazakhstan dated 03/19/2025 No. 823; dated 08/26/2025 No. 975.
№ | Наименование реформ/основных мероприятий | Форма завершения | Срок завершения | Ответственные исполнители | ||||||
1 | 2 | 3 | 4 | 5 | ||||||
Стратегический показатель: отсутствует | ||||||||||
| Направление 1. Совершенствование информационной работы и повышение кадрового потенциалаЦелевые индикаторы:доля вузов, в которых проведены открытые лекции по вопросам финансовой безопасности, %, в 2022 году - 15%, в 2023 году - 25%, в 2024 году - 50%, в 2025 году - 60%, в 2026 году - 70%;количество лиц, прошедших обучение и тестирование по вопросам ПОД/ФТ в АО "AML ACADEMY", единица, в 2023 году - 150, в 2024 году - 200, в 2025 году - 250, в 2026 году - 300 | МНВО, АФМАФМ | |||||||||
1. | Внедрение тем по финансовой безопасности в учебно-воспитательный процесс организаций технического и профессионального, послесреднего, высшего и послевузовского образования | открытые лекции, кураторские часы, онлайн- курс ы | 2022- 2026 годы | МП, МНВО, АФМ | ||||||
2. | Проведение среди школьников и студентов национальной и международной олимпиад по финансовой безопасности | олимпиады | 2023-2026 годы | АФМ, МП, МНВО | ||||||
3. | Проведение для граждан и участников системы ПОД/ФТ информационной и разъяснительной работы по вопросам ПОД/ФТ | публикации в СМИ, график разъяснительных мероприятий, памятки, методические рекомендации | 2022-2026 годы | АФМ, АРРФР, НБ, МКИ, МТИ, МТС, МЮ, Комитет МФЦА (по согласованию), МЦРИАП, АЗРК | ||||||
4. | Обучение и тестирование участников системы ПОД/ФТ в АО "AML ACADEMY" для повышения квалификации в сфере ПОД/ФТ | сертификаты | 2023 - 2026 годы | АФМ | ||||||
5. | Секторальная оценка рисков в области цифровых активов | секторальная оценка рисков | IV квартал 2025 года | АФМ | ||||||
| 6. | Формирование пула национальных экспертов для участия в проведении взаимных оценок стран – членов ЕАГ | сертификаты | 2024 – 2026 годы | АФМ, МНЭ, МФ, МКИ, МТИ, МПС, МТС, МЦРИАП, МВД, МИД, МНВО, М3, МТСЗН, АЗРК, ГП, ВС, АРРФР, МП, БНС АСПР, НБ, КНБ | ||||||
| 7. | Организация прохождения участниками системы ПОД/ФТ/ФРОМУ подготовительных курсов для сертификации, по примеру, ACAMS (сертифицированный специалист антиотмывочной системы), CFCS (сертифицированный специалист по финансовым преступлениям) | подготовительные курсы | 2025 - 2026 годы | АФМ | ||||||
| Направление 2. Совершенствование законодательства и нормативных актов в сфере ПОД/ФТЦелевой индикатор:количество рейтингов "значительное соответствие" и "соответствие" по итогам оценки экспертами ЕАГ соответствия законодательства Республики Казахстан рекомендациям ФАТФ, единица, в 2022 году - 25, в 2023 году - 25, в 2024 году - 33, в 2025 году - 33, в 2026 году - 35 | АФМ | |||||||||
| 8. | Рассмотрение вопроса внесения изменений и дополнений в Закон о ПОД/ФТ, в т.ч. в части: определения целей, задач, принципов ПОД/ФТ; направления субъектами финансового мониторинга сообщений о подозрительной деятельности | проект закона | III квартал 2024 года | АФМ | ||||||
| 9. | Исключена указом Президента РК от 19.03.2025 № 823. | |||||||||
| Направление 3. Совершенствование системы ПОД/ФТ Целевые индикаторы: | ||||||||||
доля использования правоохранительными и специальными государственными органами материалов подразделения финансовой разведки, %, в 2022 году – 68%, в 2023 году – 72%, в 2024 году – 76%, в 2025 году – 80%, в 2026 году – 84%; доля субъектов финансового мониторинга, зарегистрированных в системе АФМ, %, в 2022 году – 50%, в 2023 году – 60%, в 2024 году – 70%, в 2025 году – 80%, в 2026 году – 90% | АФМ, ГП, КНБ, МВД, АФМ, АЗРК, М3, АРРФР, МКИ, МТС, НБ, МЮ, Комитет МФЦА (по согласованию) | |||||||||
10. | Внесение изменений в Правила представления субъектами финансового мониторинга сведений и информации об операциях, подлежащих финансовому мониторингу, в части оптимизации требований к подготовке сообщений о подозрительных операциях | приказ АФМ | IV квартал 2022 года | АФМ | ||||||
11. | Разработка механизма предоставления обратной связи субъектам финансового мониторинга по рисковым операциям, связанным с ОД/ФТ | приказ АФМ | I квартал 2023 года | АФМ | ||||||
12. | Проработка вопроса получения доступа к базам данных зарубежных компаний, оказывающих услуги в сфере управления рисками и комплаенса | договор | IV квартал 2025 года | АФМ | ||||||
13. | Разработка механизма по мониторингу расходования бюджетных средств в период освоения | приказ АФМ | IV квартал 2022 года | АФМ | ||||||
14. | Разработка механизма оперативного взаимодействия АФМ с субъектами финансового мониторинга и АПК по вопросам мониторинга подозрительных операций публичных должностных лиц, их супругов и близких родственников | приказ АФМ | IV квартал 2023 года | АФМ | ||||||
15. | Разработка механизма оценки новых видов финансовых услуг на предмет подверженности рискам отмывания доходов и финансирования терроризма | приказ АФМ | IV квартал 2023 года | АФМ, АРРФР | ||||||
16. | Проработка вопроса расширения перечня интеграций БД ЕИАС с базами государственных и правоохранительных органов с установлением четких оснований доступа, механизмов контроля за полученной информацией, исключающих возможности для злоупотреблений и разглашения полученных данных и использования их во внеслужебных целях | интеграция | IV квартал 2026 года | АФМ, КНБ, МЦРИАП, МЮ, ГП, МФ, АДГС, МВД, МТСЗН,М3, МНВО, МП | ||||||
17. | Развитие ЕИАС в части внедрения технологий по работе с большими данными для анализа рисков ОД/ФТ | согласование ГИП | I квартал 2023 года | АФМ, МЦРИАП, МНЭ | ||||||
18. | Проработка вопроса создания в структуре АФМ Национального центра оценки рисков ОД/ФТ | предложения в АП | IV квартал 2024 года | АФМ | ||||||
19. | Внедрение "Личного кабинета регулятора" | акт ввода в эксплуатацию | IV квартал 2022 года | АФМ | ||||||
20. | Внедрение системы оценки субъектов финансового мониторинга | приказ АФМ | IV квартал 2022 года | АФМ | ||||||
21. | Внедрение системы оценки государственных органов, регулирующих деятельность субъектов финансового мониторинга | приказ АФМ | IV квартал 2022 года | АФМ | ||||||
22. | Внедрение "Личного кабинета правоохранительного органа" | акт ввода в эксплуатацию | III квартал 2023 года | АФМ | ||||||
23. | Автоматизация процесса получения правоохранительными и специальными государственными органами информации от подразделения финансовой разведки, в соответствии с их запросами, санкционированными органами прокуратуры | акт ввода в эксплуатацию | III квартал 2025 года | АФМ, МЦРИАП, ГП, КНБ, МВД | ||||||
Направление 4. Мониторинг и предотвращение незаконной деятельности необеспеченных цифровых активов на территории Республики Казахстан Целевой индикатор: увеличение количества клиентов у лицензированных провайдеров виртуальных активов, %, в 2022 году - 5%, в 2023 году - 5%, в 2024 году - 5%, в 2025 году - 30%, в 2026 году - 30% | МЦРИАП, Комитет МФЦА (по согласованию), АФМ | |||||||||
24. | Проведение для правоохранительных и государственных органов тренингов по отслеживанию криптовалют и новым тенденциям в сфере виртуальных активов | тренинги | 2024 – 2026 годы | ГП, АФМ, КНБ, МЦРИАП, МВД | ||||||
| 25. | Разработка методических рекомендаций по выявлению незаконных операций с использованием цифровых активов | приказ АФМ | IV квартал 2022 года | АФМ | ||||||
| 26. | Утверждение дополнительных критериев подозрительных операций, связанных с использованием цифровых активов | приказ АФМ | III квартал 2023 года | АФМ | ||||||
| 27. | Проведение совместной работы с финансовыми регуляторами стран, в которых зарегистрированы криптобиржи, для получения информации об операциях казахстанских клиентов на зарубежных рынках криптовалют | международные соглашения | Ш квартал 2026 года | АФМ, МЦРИА п, Комитет МФЦА (по согласованию) | ||||||
| 28. | Внесение изменений в Правила изъятия, учета, хранения, передачи и уничтожения вещественных доказательств, изъятых документов, денег в национальной и иностранной валюте, наркотических средств, психотропных веществ по уголовным делам судом, органами прокуратуры, уголовного преследования и судебной экспертизы в части включения особенностей, связанных с цифровыми активами | проект постановления Правительства | IV квартал 2025 года | АФМ, ГП, КНБ, МВД, ВС | ||||||
| 29. | Внедрение в работу по отслеживанию незаконных финансовых операций IT-инструментов по проведению расследований о цифровых активах | акт ввода в эксплуатацию | IV квартал 2024 года | АФМ | ||||||
| 30. | Проведение анализа регулирования сферы цифровых активов с выработкой предложений по ее дальнейшему совершенствованию | предложения в АП | III квартал 2024 года | МЦРИАП, Комитет МФЦА (по согласованию), АФМ | ||||||
| Направление 5. Повышение важности вопросов поиска и возврата доходов, полученных преступным путемЦелевой индикатор:доля установленного и арестованного имущества от суммы причиненного ущерба (в том числе преступных доходов), %, в 2022 году – 13%, в 2023 году – 17%, в 2024 году – 21%, в 2025 году – 25%, в 2026 году – 29% | ГП, АФМ, КНБ, МВД | |||||||||
| 31. | Определение в органах уголовного преследования лиц, ответственных за поиск и возврат доходов, полученных преступным путем | приказы АФМ, ГП, АПК, КНБ, МВД | IV квартал 2022 года | АФМ, ГП, АПК, КНБ, МВД | ||||||
| 32. | Проработка вопроса обеспечения правоохранительных и специальных органов современными инструментами поиска активов, а также необходимыми базами данных программным обеспечением по моделированию схем вывода активов, в т.ч. платными | предложения в АП практическая реализация | I квартал 2023 года 2023-2024 годы | ГП, МФ, АФМ, АПК, КНБ, МЦРИАП, МВД | ||||||
| 33. | Заключение соглашений по взаимной правовой помощи с иностранными государствами, куда происходит отток капитала | международные соглашения | IV квартал 2024 года | ГП | ||||||
| 34. | Проработка вопроса присоединения Казахстана к Конвенции Совета Европы в области уголовного судопроизводства | информация в АП | III квартал 2026 года | ГП, МИД | ||||||
| 35. | Проработка вопроса подписания соглашения с Европолом о стратегическом партнерстве по обмену информацией по вопросам установления и возврата незаконно выведенных активов | информация в АП | I квартал 2023 года | ГП | ||||||
| 36. | Реализация проектов по вопросам возврата похищенных активов совместно с международными организациями | проекты | IV квартал 2025 года | ГП, МИД, АФМ, МВД, КНБ | ||||||
| 37. | Исключена указом Президента РК от 19.03.2025 № 823. | |||||||||
| 38. | Формирование в отчетах Комитета по правовой статистике и специальным учетам сведений о:первоначальной оценочной стоимости имущества и других активов, подлежащих конфискации, склассификацией на средства, орудия преступления и преступное имущество; количестве поступивших на исполнение исполнительных документов с разбивкой по сферам, органам и статьям; фактической стоимостиимущества и суммеденежных средств,обращенных и поступивших в доход государства | приказ ГП | IV квартал 2022 года | ГП, заинтересованные государственные органы | ||||||
Note: explanation of abbreviations:
AP -Administration of the President of the Republic of Kazakhstan
ADGS - Agency of the Republic of Kazakhstan for Civil Service Affairs
AZRK - Agency for Protection and Development of Competition of the Republic of Kazakhstan
APK - Anti-Corruption Agency of the Republic of Kazakhstan
(Anti-Corruption Service)
ARRFR - Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market
AFM - Agency of the Republic of Kazakhstan for Financial Monitoring
Supreme Court of the Republic of Kazakhstan
GP - General Prosecutor's Office of the Republic of Kazakhstan
KNB - National Security Committee of the Republic of Kazakhstan
NB - National Bank of the Republic of Kazakhstan
BNS ASPR - Bureau of National Statistics of the Agency for Strategic Planning and Reforms of the Republic of Kazakhstan
Ministry of Internal Affairs - Ministry of Internal Affairs of the Republic of Kazakhstan
M3 - Ministry of Health of the Republic of Kazakhstan
Ministry of Foreign Affairs - Ministry of Foreign Affairs of the Republic of Kazakhstan
MCI - Ministry of Culture and Information of the Republic of Kazakhstan
EOM - Ministry of Science and Higher Education of the Republic of Kazakhstan
MNE - Ministry of National Economy of the Republic of Kazakhstan
MP - Ministry of Education of the Republic of Kazakhstan
MPS - Ministry of Industry and Construction of the Republic of Kazakhstan
MIT - Ministry of Trade and Integration of the Republic of Kazakhstan
MTS - Ministry of Tourism and Sports of the Republic of Kazakhstan
Ministry of Labor and Social Protection of the Population of the Republic of Kazakhstan
MF - Ministry of Finance of the Republic of Kazakhstan
ICRIAP - Ministry of Digital Development, Innovation and Aerospace Industry of the Republic of Kazakhstan
Ministry of Justice - Ministry of Justice of the Republic of Kazakhstan
AIFC Committee - Committee of the Astana International Financial Center
AML ACADEMY JSC - AML ACADEMY Joint Stock Company
EAG - The Eurasian Group for Countering Money Laundering and Terrorist Financing
EIAS database - The "Unified Information Analytical System" database
GIP - State investment project
University - higher education institution
ML/FT - money laundering/terrorist financing
AML/CFT - countering the legalization (laundering) of proceeds from crime and the financing of terrorism
FATF - Financial Action Task Force on Money Laundering
FRMU - financing the proliferation of weapons of mass destruction
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