Yes, there are, and they are related to sanctions regulations, banking risks, and the internal procedures of the AIFC.
Formally, the AIFC is open to any foreign individuals and legal entities.
However, the AFSA/ROC requires applicants to provide a Legal Opinion with a sanctions analysis (sanctions screening) issued by accredited law firms or Big4-legal.
What is required:
A Legal Opinion (sanctions + EDD): a legal opinion prepared by a Kazakhstani firm recognized by Chambers/Legal 500/IFLR1000, or by an AFSA-licensed Ancillary Service Provider. It includes screening of the applicant/UBOs/directors against OFAC (USA), EU, UK, UN, Canada, Australia lists, negative news checks, as well as a conclusion confirming that the planned activity does not contradict applicable sanctions regimes. This is formalized by AFSA as an “Additional assessment” and published on the regulator’s website.
When this comes up: formally, “in certain cases” at the discretion of the Registrar of Companies (enhanced due diligence). In practice, during 2024–2025 it has been required in nearly all higher-risk cases (including redomiciliation/Transfer of Incorporation and for “sensitive” jurisdictions). Professional communities and law firm practice confirm that in registration and redomiciliation processes, a sanctions Legal Opinion is usually requested.
Package composition under additional assessment: in addition to the Legal Opinion, AFSA requests a Business Plan, Financial Plan, Employment Plan, and for redomiciliation — confirmation from the home jurisdiction that transfer/continuation is permitted.