Exchange, brokerage, custody, wallet and OTC models
These models are not interchangeable, and AFSA will not treat them as one generic “virtual asset service provider Kazakhstan” activity.
Exchange / digital asset trading facility. This is the closest fit for what founders usually mean by crypto exchange license Kazakhstan. The regulator will focus on trading logic, client onboarding, custody arrangements, market abuse controls, order handling, and operational resilience. If fiat is involved, banking and payment infrastructure become central to the file.
Custody. Custody is not just wallet storage. It is about legal and technical control over client assets. AFSA will want to understand whether you hold keys directly, rely on third-party custodians, or use MPC/co-signing architecture. The strongest applications explain wallet segregation, withdrawal governance, reconciliation, and incident recovery in operational detail.
OTC / broker-style dealing. OTC desks often underestimate licensing complexity. The regulator will ask whether you act as principal or agent, how you price trades, who your liquidity providers are, and how you manage sanctions and source-of-funds risk on large tickets. A desk with institutional clients usually needs a more sophisticated onboarding and transaction-monitoring framework than a retail-only app.
Wallet services. The legal answer depends on whether the wallet is truly non-custodial or whether the operator retains practical control over transfer initiation, recovery, or key fragments. Many “non-custodial” marketing claims collapse under technical review once account recovery, omnibus settlement, or backend signing logic is examined.
A useful rule: if your operating model touches client assets, execution, intermediation, or price formation, assume a real regulatory mapping exercise is required before anyone can quote timeline or fees responsibly.