Why route settlements through Kazakhstan
After 2022, ruble cross-border settlement fragmented. Western correspondents cut exposure to anything touching Russia, and many CIS and Gulf banks followed to protect their own dollar and euro lines. Payments that once cleared in a day began to fail at the compliance layer, often with no explanation. Kazakhstan became one of the few places where a clean, non-sanctioned flow could still move between the ruble market and hard currency.
The Astana International Financial Centre is what separates this from an ordinary Kazakhstani bank account. The AIFC runs on English common law, with its own court and an International Arbitration Centre that sit outside Kazakhstan's state judiciary, and with the Astana Financial Services Authority (AFSA) as financial regulator. For a payment rail that may have to survive a counterparty dispute or a compliance review, that legal wrapper matters as much as the currency list.
Concept
Collect & Pay — Kazakhstan neobank with authorization from Astana Financial Services Authority (AFSA) under the Providing Money Services (PMS) regime within Astana International Financial Centre (AIFC). AFSA's PMS regime was introduced in stages: definitions, capital and digital asset operations — from 13 October 2025; client protection and cyber resilience — from 13 January 2026. Main currencies — KZT, RUB, USD, EUR, CNH.
Private.law as Collect & Pay partner
Private.law — Collect & Pay partner. We submit applications through the partner channel. Often combined with opening an AIFC company — this gives the client both regulatory wrapper and payment rail in one jurisdiction (instead of assembling HK Ltd + UK neobank or similar structures). Through the partner channel we handle KYC matters directly with the onboarding manager.
What Collect & Pay does
- Multi-currency account in KZT, RUB, USD, EUR, CNH. Local details in Kazakhstan.
- Cross-border B2B payments. Russia, CIS, China, EU, US — through correspondent network.
- Corporate cards. Debit cards against client balance for operational expenses.
- Digital assets (from Oct 2025). Limited digital asset operations within AFSA PMS scope (not universal solution, specific use cases).
Application
Russian UBO with the operating model moved to Kazakhstan
The classic case: the owner moves operations to Kazakhstan, in full or in part, and registers an AIFC company. Collect & Pay then settles with non-sanctioned counterparties in rubles, while external flows run on USD, EUR and CNH lines. Where the activity itself qualifies as AIFC financial services, the participant pays no corporate income tax until 1 January 2066. An ordinary trading company does not automatically qualify, so the tax position should be checked against the real business model rather than assumed.
Business between CIS and China / EU
Trading business or service company with ties to the Russian and CIS markets and clients/suppliers in China or EU. Kazakhstan — rare "neutral" channel for such settlements, not blocked by correspondents and not raising sanctions flags at Western banks.
Multi-jurisdictional structure with Central Asian core
Company chooses AIFC as holding or operating jurisdiction due to tax benefits and English common law. Collect & Pay serves as the payment rail in the same jurisdiction, without need to route payments through second country (HK, SG, UK).
Mandatory requirements
- Jurisdiction. AIFC company — preferred option. Regular Kazakhstani TOO/LLC and neighboring CIS also accepted.
- Clear business model. Counterparties, payment flows, connection to Russia (if any) — state directly in KYC.
- Clean source of funds. AFSA checks connections to sanctioned sectors of the Russian economy (military-industrial complex, oil and gas, dual-use) — connections to these sectors lead to rejection.
- UBO documents.
Opening through private.law
- AIFC company registration (if needed). 2–3 weeks.
- Package preparation. Corporate documents, passports, business model description with explicit source of funds indication. 1–3 business days.
- Submission through partner channel.
- AFSA / Collect & Pay KYC review. 2–4 weeks.
- Account activation.
Total timeline for existing AIFC company — 3–6 weeks. From scratch — 6–8 weeks.
Russian and Belarusian clients: possible, but not automatic
Not suitable for
- Holding large balances. AFSA PMS — not a banking license, no KDIF deposit insurance.
- Banking products — trade finance, L/C, bank guarantees. For this in Kazakhstan — Halyk Bank, Kaspi, Forte. Or international banks.
- Bank reference letter at FCA/HKMA/MAS level. Not issued.
- Crypto outside AFSA-permitted operations. Arbitrary crypto flows outside PMS perimeter — rejection.
- Company without connection to CIS or Central Asia. No point in AIFC regime.
Regulation: a money-services licence, not a bank
Collect & Pay holds an AFSA authorisation under the Providing Money Services regime, not a banking licence, and the difference is practical. No KDIF deposit guarantee stands behind the balance, so the account is a settlement tool rather than a place to hold large reserves. What the AIFC adds is supervision and a forum: AFSA conduct rules, plus the English-common-law AIFC Court and International Arbitration Centre if a counterparty relationship breaks down. Onboarding runs to AFSA KYC standards, and beneficial ownership has to be documented properly (UBO registers).
Transparency, not secrecy
A Kazakhstan account is not a hiding place. Kazakhstan has exchanged financial-account data under the CRS since 2020, so the balance and the account holder are reported to the tax authority of the holder's residence. A UBO who is still a Russian tax resident also owes foreign-account notification and movement reporting, and the account may fall inside CFC rules if it sits under a foreign company. For many clients that is one more reason to settle residence first (exiting Russian tax residency). The route works because it is legal and documented, not because it is quiet.
Where this is heading
The PMS framework arrived in two stages: capital rules and the use of digital assets in money services from 13 October 2025, client-protection and cyber-resilience rules from 13 January 2026. AFSA has since begun licensing stablecoin activity inside the same perimeter, so on-chain settlement is turning into part of the toolkit rather than a workaround. The honest caveat is that correspondent access keeps moving, and a neutral channel stays neutral only while the flows through it stay clean. The durable version of this setup pairs the rail with real economic substance and a genuine reason to be in Central Asia, not a nameplate over a holding chain.
Q/A
Is Collect & Pay a Kazakh bank?
No. AFSA’s public register records Collect & Pay Ltd as a private company with an active permission for Providing Money Services, not banking business. A payment account therefore cannot be described as a bank account merely because the provider is authorised by AFSA.
Does the AFSA permission guarantee RUB, CNH or any advertised payment corridor?
No. The register confirms the broad regulated activity of Providing Money Services; it does not promise a particular currency, country, correspondent bank or counterparty. Availability must be checked against the current client agreement and compliance review for the transaction.
Does money held through Collect & Pay become an ordinary bank deposit?
No. An AFSA money service provider is subject to rules for safeguarding and segregating client money, but that does not turn the provider into a bank. Before funding, the client must check the agreement, where money is held, and the safeguarding and repayment arrangements.
Does AFSA authorisation remove sanctions and source-of-funds checks?
No. An authorised firm must identify the client, understand the purpose of the transaction and conduct continuing risk-based monitoring. The permission confirms AFSA supervision; it does not guarantee acceptance of a client, counterparty or individual payment.
Does Collect & Pay’s permission automatically cover digital-asset transactions?
No. The 2025–2026 AFSA framework brings specified digital-asset payment transactions into the money-services perimeter, but an actual product must fit the provider’s permission, the applicable rules and its client agreement. The generic register entry alone is not enough.