Yes, there are, and they relate 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 an accredited law firm or a Big Four law practice.
What is required:
A legal opinion (sanctions + EDD) prepared by a Kazakhstani firm recognized by Chambers, Legal 500 or IFLR1000, or by an AFSA-licensed Ancillary Service Provider. It includes screening of the applicant, UBOs and directors against the OFAC (US), EU, UK, UN, Canadian and Australian lists, adverse media checks, and a conclusion confirming that the planned activity does not contradict the applicable sanctions regimes. AFSA formalizes this as an "Additional assessment" and publishes it 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 "sensitive" jurisdictions). Practitioners confirm that a sanctions legal opinion is usually requested in registration and redomiciliation processes.
What the additional-assessment package includes: in addition to the legal opinion, AFSA requests a business plan, a financial plan, an employment plan and, for redomiciliation, confirmation from the home jurisdiction that the transfer/continuation is permitted.