Kazakhstan remains one of the most legible examples in Eurasia of a state trying to separate regulated digital-asset infrastructure from informal crypto trading. The interesting part is not that crypto is regulated, but the shape of the market that comes out of it.

What is already in place

Several layers operate at the national level.

  • AIFC and AFSA. A financial centre in Astana with its own legal system; AFSA licenses and supervises firms conducting regulated digital-asset activity inside the AIFC. A recent AFSA rulebook clarifies which digital-asset activities require which authorisation.
  • National Bank of Kazakhstan. Responsible for the broader national perimeter: what counts as a financial instrument, how digital-asset circulation interacts with banks and payment providers.
  • Mining and energy. A separate regulatory track tied to miner licensing and taxation of consumed energy.
  • Tokenized instruments. An emerging layer in which specific digital assets may qualify as financial instruments and inherit the corresponding requirements.

How we read this: two-tier supervision

We see Kazakhstan as a two-layer supervisory model. One layer is AIFC-based supervision: AFSA licenses and supervises entities inside the financial centre. The other is the national perimeter: how digital-asset services may be offered to residents and how they interact with banks, tax authorities, and payment rails.

We will call this lens two-tier supervision. It explains why the same factual activity — for example, providing platform access to residents — can simultaneously sit inside AFSA’s remit and inside the wider national supervision. The same lens reads the recent AFSA warning on unlicensed platforms: onshore vs. offshore, AIFC vs. national regulator.

For Silk DeFi, this is the baseline view of the region: licensing, mining, exchange rules, and the gradual move toward tokenized financial assets — each lives in its own layer while remaining coupled to the others.

What this changes for teams

For founders and investors, Kazakhstan matters not because “crypto is allowed”, but because it shows how a state can fold crypto activity into a formal perimeter without trying to make every token a bank product. A team entering the Kazakhstan market should determine from the start which of the two supervisory layers its activity actually lives in — not treat the AIFC as a general-purpose offshore wrapper.

When we work through a pre-licensing case for Kazakhstan at RiskOS Labs, the first two questions are always the same: which regulated activities under the AIFC rulebook is the team proposing to perform, and which of its user-facing channels — advertising, support, payment integrations — may qualify separately under national supervision. That is two-tier supervision applied in practice.

Kazakhstan is not the only jurisdiction moving in this direction, but it is one of the most worked-out examples in the region. That is why we return to it more often than to other markets.

Silk DeFi is a research project on crypto, DeFi, and regulation across Eurasia.

Need a regulatory or DeFi risk read on your jurisdiction? RiskOS Labs runs pre-licensing assessments and regulatory reviews for teams operating in Eurasian markets.