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10 questions to a lawyer about a director and THE ceo in the Astana International Financial Centre (information is valid as of 2 October 2024) AEQUITAS Partner Director of AEQUITAS AIFC Branch
Head of Registrations Senior Associate
This publication offers our answers to 10 most relevant questions about the directors and chief executive officers («CEO») of private companies in the Astana International Financial Centre («AIFC»). This organizational legal form of a legal entity is most commonly used in the AIFC. More than 2,600 organizations of the total number of 3,000 are registered in the form of private companies («Company»). We hope that our answers to the questions will help the business representatives deal with corporate issues relating to the status of the CEO and a director in the AIFC. 1. What are the rights and obligations of a director? The Company management structure may be conditionally divided into 3 levels: 1) supreme body - general meeting of shareholders or the sole shareholder; 2) governing body - Board of Directors or a director; 3) CEO - one of directors or another individual. The AIFC acts governing the issues of corporate structure of the Company are the AIFC Companies Regulations («CReg» [1]) and the AIFC Companies Rules («CRules»[2]). As a rule, shareholders rarely participate in the Company management. The said acts refer the most substantive issues, such as the Company winding up, changes in the articles of association, appointment of the members of the Board of Directors, to the competence of shareholders who, in turn, manage the business activities of the Company.
The company must have at least one director. The number of directors must be established by the articles of association.
According to Creg, directors must:
1) act within powers; 2) promote success of the Company; 3) exercise independent judgment; 4) exercise reasonable care, skill and diligence; 5) avoid conflicts of interest; 6) not accept benefits from third parties; 7) declare interest in proposed transaction or arrangement; 8) declare interest in existing transaction or arrangement (Articles 77-83 and Article 85 of CReg). The Constitutional Documents of the Company must not include any provision, the effect of which would be to weaken the above duties of the directors (Article 76(4) of CReg) [3]. Director's rights must be determined by the articles of association (Article 2.2.2 of CRules).
The key Director's functions include as follows: 1) to determine the strategic objectives and supervise over their implementation; 2) to make the key resolutions in the Company and determine internal policies and procedures; 3) to represent the Company before the shareholders, investors and other parties concerned. Obligations of the Board of Directors, which is the governing body for regulated Companies (holding a license) according to the Glossary [4], are set out in Article 5.3.3 of the AIFC General Rules [5]. 2. What is the difference between the CEO and a director, and what are the CEO's powers? The Company must be managed by the Directors or by another natural person appointed by the Shareholders or Directors and bearing the title of Chief Executive Officer. The Chief Executive Officer shall have the broadest powers to act in all circumstances in the name of the Company, within the limits of the corporate objects and subject to powers expressly reserved by law for Shareholders’ meetings and the Directors. The CEO shall represent the Company in its dealings with third parties (Articles 18.1 and 18.2 of the Standard Articles of Association [6]).
The key CEO's functions include as follows: 1) day-to-day Company management; 2) Company representation in relations with third parties, including entering into transactions on behalf of the Company (subject to restrictions established by the articles of association and the necessity to obtain approval for certain transactions from the directors or shareholders); 3) development of the Company's strategy and implementation of business plans; 4) liability for financial stability and risk control; 5) building of an effective corporate structure; 6) control over compliance of the Company's activities with legislation and the AIFC standards; 7) issuance of powers of attorney to individuals to act on behalf of the company in specific matters, which may arise from time to time; 8) hiring of other Company employees. The AIFC acts do not contain a detailed definition of the «CEO» or the issues referred to the CEO's competence. The Company may appoint the same person to the positions of a director and the CEO. However, if these are different persons, their obligations and responsibilities must be clearly distinguished in the articles of association. This is a crucial necessity, especially subject to extensive interaction with the governmental authorities and banking institutions, for which it is important to deal with an authorized person with the right to represent the Company.
According to the AIFC General Rules, the Company must ensure that the Company's senior management bears clear liability for the day-to-day management of the Company's business in accordance with the business objectives and strategies approved or established by the governing body.
3. How are the meetings of directors held? The AIFC acts do not contain any requirements to the procedure for convening, holding the meetings of directors, voting and resolving. These issues must be described in detail in the Company's articles of association. At the same time, the shareholders may use the Standard Articles of Association, which offer standard provisions on the above issues. 1) The directors may conduct their proceedings (including their meetings) as they consider appropriate, at the times and places that they decide. 2) The quorum for meeting of the directors may be fixed from time to time by a decision of the directors. 3) The questions are to be resolved by a majority of directors present, in person or by alternate. The meeting chair also has a second or a casting vote if the votes on any question are equal. 4) A resolution of the directors is taken when the directors indicate to each other by any means that they share a common view on the matter. Such a resolution may take the form of a resolution in writing, copies of which have been signed by each director or to which each director has otherwise indicated their agreement in writing. 5) Any director may validly participate in a directors meeting through any means that all the directors participating in the meeting are able to hear and speak to each other during such a meeting. 6) The directors must ensure that minutes are kept for: (a) all appointments of officers made by the directors; and (b) all proceedings at general meetings of shareholders and meetings of the directors. The Standard Articles of Association do not contain an option where the Company has one director; however, the issues of convocation, holding of meetings, and voting in such case will apparently be irrelevant. All resolutions are taken by the sole director independently, and it is not mandatory to execute a decision of the sole director by a resolution or any other formal document. The director grants approval of documents and transactions at his/her own option by way of: email correspondence; signing of a document (it is also allowed to use an electronic digital signature); or by any other means allowing to record and confirm the director's decision. However, for the purposes of recording a decision, the director may also give it the form of a resolution in writing. 4. How are the directors and CEOs elected / dismissed? According to the general rule, a director must be elected by the shareholders by an ordinary resolution [7], or as otherwise provided by the articles of association, for the term that the shareholders decide (Article 75 of CReg).
Termination of powers of a director occurs by the reason of the director’s earlier death, resignation or removal by an ordinary resolution or as otherwise provided by the articles of association of the Company. Furthermore, if the Registrar of the Astana Financial Services Authority («AFSA») considers that it is in the Company's interest that an individual should not be a director of, or in any way (whether directly or indirectly) take part in the management of, the Company, the AFSA Registrar may apply to court for an order on disqualification of the director (Articles 75 and 92 of CReg).
According to the definition of the «CEO» given in Article 1.1 of the Standard Articles of Association, CEO means the chief executive officer of the Company, who is a natural person and has an individual identification number (IIN). The CEO is appointed by the shareholders or directors.
Thus, if the CEO concurrently acts as a director, he/she is elected by the general meeting of shareholders or appointed by the sole shareholder. If the CEO is not a director, he/she is appointed to this office by the shareholders or directors (depending on what is specified in the articles of association). It is worth mentioning that the Company may have only 1 CEO (although it is possible to find Companies in the AIFC Public Register with several CEOs, we found out during a conversation with the Registrar that such situations occur because of technical errors in the system). 5. Is it necessary to pay salary to the directors and CEOs? The AIFC acts do not contain an express indication on whether the director's office is remunerable. According to the Standard Articles of Association, a director is entitled to be paid the remuneration and be reimbursed all expenses reasonably incurred in association with carrying out of the duties of a director (Article 23).
In our view, such approach is well founded and convenient in light of the fact that the directors may appoint the CEO and actually limit themselves to the most important strategic decisions while being located in different countries and gathering only if necessary, including by way of online meetings.
In turn, while being the Company head and representing its interests in the everyday life, the CEO must have an employment contract and mandatory salary. 6. Is it necessary for a director and the CEO to stay in the AIFC territory? We mentioned in our answer to the previous question that it is not mandatory for the Company directors to stay at the place of location of the Company.
It is not mandatory to stay at the registered address of the Company for the CEO either; however, if there is no Company representative at the registered address and the AIFC representatives fail several times to reach out the Company, the strike off procedure may be applied in accordance with Article 167 of CReg (similar rule is included in Article 49 of the Civil Code of Kazakhstan) [8]. In certain cases, the Kazakhstan companies use the option of a legal address provided, for example, by relevant service providers [9]; however, it is necessary to keep in mind certain peculiarities. For example, in case of an inspection conducted by a tax inspector, if failing to find the Company at the place of registration, this may result in the VAT de-registration and inclusion in the list of taxpayers absent at the place of location, which may, in turn, adversely affect its business relations with counterparties [10]. It is worth mentioning that opening of a bank account may require personal presence of the CEO to sign the specimen signature cards; however, in certain cases banks agree to accept the cards certified by foreign notaries.
At the same time, presence of the directors and the CEO at the registered address of the Company is mandatory for the Companies carrying out regulated activities (e.g. please see the Guidance on the Rules on the Substantial Presence) [11]. 7. Who may be a director and the CEO? According to the general rule, there are no specific requirements to the director's identity. However, a person may not be a director if such person: a) is not a natural person; or b) is under 18 years old; or c) is disqualified from being a director because of: (i) having been convicted of a criminal offence, involving dishonesty or moral turpitude, in any jurisdiction in the past 10 years; or (ii) having been found guilty of insider trading or the equivalent in any jurisdiction at any time; or (iii) having been judged disqualified by any court; or (iv) having been disqualified by AFSA; or (v) disqualification specified in the articles of association; or (vi) is an undischarged bankrupt (Article 74 of Creg). For the Companies carrying out regulated activities, a director and the CEO are referred to the senior managing employees performing the controlled functions. They are the Approved Individuals whose appointment requires a preliminary approval by AFSA (Articles 2.2.1 and 2.2.2 of the AIFC General Rules, Glossary).
These persons undergo an assessment as to be fit to be granted the contemplated role, demonstrating their competence, qualification, good faith attitude and financial stability. The assessment criteria are not exhaustive and depend on the AFSA's decision (Article 2.2.6 of the AIFC General Rules). Please note that there are similar requirements in the Kazakhstan legislation for banks and financial organizations [12].
More detailed requirements to the Approved Individuals are contained in Article 1.2.5 of the AIFC General Rules, Articles 21 and 25 of the AIFС Financial Services Framework Regulations [13], and the Regulatory Guidance on Fitness and Propriety [14].
Furthermore, prior to submitting the documents to AFSA it is necessary to conduct a preliminary assessment of a person as to absence in the sanctions lists, and for any negative information on the Internet or in the Refinitiv system, one of the largest world companies providing analytical data.
In case of a positive decision, AFSA issues a permit for appointment of the nominees to the said positions. The fee for considering the set of documents to get the status of an Approved Individual is USD 300. 8. What are the requirements for the directors and CEOs who are non-residents? 8.1. Qualification The list of documents confirming high qualification of a foreigner and a stateless person is determined by AFSA (Article 8 of the AIFC Constitutional Law). For example, the Employment Qualifications establish that a foreigner must satisfy the criteria in either Section A (Education) or Section B (Experience). Section A: Education 1) undergraduate degree directly relevant to the foreigner proposed employment in the AIFC; 2) qualification of equivalent standing to an undergraduate degree that is directly relevant to the foreigner proposed employment in the AIFC. Section B: Experience 1) service of at least three years in a managerial position directly relevant to the foreigner proposed employment; 2) service of at least five years in a non-managerial position directly relevant to the foreigner proposed employment [15]. 8.2. Obtainment of IIN, EDS, opening of a bank account We previously mentioned in our answer to question 4 that, according to the definition, «CEO» is a natural person and must have IIN.
First of all, IIN is required for the CEO to introduce information about the CEO into the National Register of Business Identification Numbers (certificate of registered legal entity obtained via the egov portal specifies such person as the head). Furthermore, all systems of governmental agencies are connected to the IIN database (without IIN it is impossible to obtain a corporate and personal EDS and, accordingly, use the electronic state services). Moreover, IIN is required to open both personal and, in most cases, corporate bank accounts.
Accordingly, if the CEO is a foreigner, he/she must obtain IIN, which is issued by the Ministry of Internal Affairs of Kazakhstan.
Please note that, starting 24 February 2024, IIN may be obtained only in case of a personal visit of a foreigner to the governmental agency of Kazakhstan [16]. An applicant must have a SIM card with a local number of the mobile services provider, to which SMS with IIN will be sent. State duty for IIN is paid at the Public Service Centre.
Starting 13 April 2024, Kazakhstan launched a pilot project involving issuance of IIN in all consulates of Kazakhstan [17]. Furthermore, according to the AIFC website, it is possible to obtain IIN by way of the electronic portal www.digitalresident.kz (section «New Application» > «Expat Centre Services» > «IIN»); however, at the stage of application, the system requests for a power of attorney. This may apparently be a deprecated function, since it is known that, starting 24 February 2024, IIN is issued in case of a personal visit. If an employment contract is entered into with a director, he/she must obtain IIN as well. 8.3. Work permit and work visa A foreign labor engagement permit («Labor Permit») in a Company registered in the AIFC is not required for all categories of employees [18]. However, if the period of a business trip in another region of Kazakhstan exceeds 90 days, it is necessary to obtain the Labor Permit in such region (Article 37-1.3 of the Migration Law [19], paragraph 38 of the Permit Issue Rules [20], [21]). Otherwise, an employer may be brought to administrative liability in the amount from 100 to 700 MCI [22] (Article 519.1 of the Administrative Code [23]).
At the same time, citizens of the EAEU member states fall under the provisions of the EAEU Treaty [24], which ensure free movement of citizens within the EAEU, pursuant to which employment of citizens of the EAEU member states in Kazakhstan does not require obtainment of the Labor Permit (Articles 28.2 and 97.1 of the EAEU Treaty and paragraph 9) of the Foreign Labor List).
Meanwhile, in order for a citizen of the EAEU member state to stay in the Kazakhstan territory for more than ninety (90) days it is necessary to obtain a temporary residence permit («TRP») (paragraph 6 of the Rules of Stay [25]). The TRP must be obtained within thirty (30) calendar days after the foreign employee's arrival (Article 97.6 of the EAEU Treaty). The full list of documents for obtainment of the TRP is set out in paragraph 8 of Schedule 1-1 of the TRP Issue Rules [26]. The TRP is issued for a term of up to one (1) year, but for no more than the term of an employment contract, with the possibility of annual extension.
To enter, stay and work in Kazakhstan, a foreign employee must obtain a C3 visa. Visa is issued based on an application (invitation) of an employer by the foreign establishments of Kazakhstan or in international airports after arrival in Kazakhstan [27]. Visa may also be obtained under the «one-stop» principle at the AIFC Expat Centre [28] (e.g. if a foreign employee arrived in Kazakhstan under another visa category) [29].
According to the general rule, work visas are issued on the basis of an employment contract and for the effective term of the Labor Permit, but for no more than three (3) years (Article 36.1 of the Migration Law, paragraph 49 of the Visa Issue Rules) [30]. Foreigners and stateless persons who are the employees of the participants or bodies of the AIFC, AIFC investment residents and their family members receive an entry visa with the term of up to five (5) years, and such visa is issued without the Labor Permit (Article 7.2 of the AIFC Constitutional Law) [31]. In case of obtaining a work visa, the authority issuing visas may request for submission of a copy of an employment contract. 8.4. Additional obligations of the employee and the host person Summarizing the information provided in the previous answers, we may say that in order to employ to the Company the foreign employee (including a director and/or CEO) needs to obtain IIN, EDS, С3 visa or TRP, depending on the country of citizenship and presence of agreement on visa-free entry to Kazakhstan between such country and Kazakhstan [32]. Furthermore, it is necessary to open a bank account to perform payroll transactions. According to Article 35 of the Migration Law, foreign employees additionally must: 1) have education, qualification and experience required to perform the upcoming work, including meet the qualification requirements (please see our answers to question 7 and clause 8.1); 2) submit confirmation of presence or absence of a criminal record (please see our answer to question 7); 3) submit a medical certificate confirming absence of diseases preventing from labor activities in the selected specialty [33]; 4) enter into a medical insurance contract covering primary medical care and specialized urgent inpatient medical care in the territory of Kazakhstan. Violation of the Kazakhstan legislation in the sphere of migration by a foreigner or a stateless person expressed in a failure to leave the country after expiration of the established term entails administrative liability: within 3 days - warning; above 3 days and up to 5 days - fine in the amount of 10 MCI; above 5 days and up to 10 days - fine in the amount of 15 MCI (Article 517.3 of the Administrative Code). Once a foreign employee arrives in Kazakhstan, the host person (hotel or owner of dwelling) must inform the internal affairs authority of the arrival and change of the place of residence of the foreigner within three (3) business days of the date of arrival/change of the place of residence (paragraph 9 of the Rules of Stay in Kazakhstan). Otherwise, such person may be brought to administrative liability in the amount from 10 to 20 MCI (Article 518.1 of the Administrative Code) [34]. 8.5. Employer's additional obligations The AIFC participants must keep available and store the documents on each engaged employee confirming their high qualification, and the engaged foreigner and a stateless person must submit them to the AIFC participant (Article 8.2 of the AIFC Constitutional Law). The AIFC participants must submit information on the engaged foreigners and stateless persons to the AIFC Authority (Article 8 of the AIFC Constitutional Law). The AIFC authority keeps records of the foreign labor engaged by the AIFC participants, structural subdivision or an AIFC organization (paragraph 2.1 of the AIFC Rules on Keeping Records [35]). To keep records of foreign labor engaged by the AIFC participants, a foreign employee or an employer or a proxy on his/her behalf must submit an application form of the foreign employee and a copy of his/her national passport to the AIFC (paragraph 2.3.1 of the AIFC Rules on Keeping Records). After entering into an employment contract with a foreign employee on the basis of the obtained Labor Permit, an employer must introduce information on the employment contract into the Unified Accounting System of Employment Contracts («UASEC») within five (5) business days of the date of signing [36]. Furthermore, the Government currently discusses the draft amendments to the Order No. 353 of the Minister of Labor and Social Protection of Population of Kazakhstan «On Approval of the Rules for Submission and Obtainment of Information on an Employment Contract in the Unified Accounting System of Employment Contracts» dated 3 September 2020, according to which an employer will have to send additional information regarding a foreign employee, such as the Labor Permit number or a ground for carrying out labor activities without the Labor Permit. Employers engaging foreign labor must submit primary statistical data to the local population employment authority in accordance with the procedure and within the timeline established by the Social Code of Kazakhstan (Article 37-1.8 of the Migration Law) [37]. 9. How can we change the director/CEO in the AIFC register and state register of legal entities?
According to Article 90 of CReg, every Company must keep a register of its directors at its registered office. The Company must ensure that the register is open to inspection during business hours and without charge by the AFSA registrar or any shareholder or director of the Company.
The Company may decide to record information in a register kept by the AFSA registrar, in which case the Company must submit any information to the AFSA registrar in accordance with the CRules, which the Company would have to introduce in its register of directors. Such information must be submitted not later than 14 days after any relevant changes (paragraphs 1, 2, 6, 16, 19 of CRules).
Violation of the said requirements is punished by a fine in the amount of up to USD 15,000 (Schedule 3 of CRules); however, the Guidance on Filing Obligations of the AIFC Participants to the Registrar specifies that the fine must be up to USD 2,000 [38].
A notice includes an application in accordance with the established form [39], which must be accompanied by the following documents: resolution on appointment, passport of the director/CEO, receipt confirming payment of the fee.
The notice must be made in writing (Articles 90.18 and 26-1(3)(с) of CReg) and may be filed on www.digitalresident.kz by two methods: (i) by using an automated service (Log in); (ii) on paper by sending scan copies (Submit paper forms). In the first case, the AFSA's fee is USD 50, in the second - USD 100 [40]. An invoice is generated online. The application must be signed by the EDS of a new or the old director/CEO, authorized person or authorized signatory, or the Company secretary. If the application is filed by a person on the basis of a power of attorney, it may only be filed on paper (option (ii) above).
If a director or the CEO is an Approved Individual (please see our answer to question 7), prior to filing the notice to the Registrar it is necessary to obtain the AFSA's approval. For this purpose, it is necessary to submit the following documents: application in accordance with the established form, CV, diplomas and certificates confirming qualification and experience for a respective position.
10. Which AIFC acts in the labor law spere apply to relations with the CEO? Labor relations in the AIFC are regulated by the AIFC Employment Regulations («Employment Regulations») [41] and the Qualification Requirements Act. The Employment Regulations apply to the employees of the AIFC bodies, organizations of the AIFC bodies and the AIFC participants. This act provides for the minimum standards of employment and regulation of labor relations, and an opportunity to include the conditions more favorable for the employees in the employment contracts. The AIFC participants must also comply with requirements of the Labor Code [42] and other effective laws of Kazakhstan with respect to the issues not regulated by the AIFC Constitutional Law and the AIFC Acts, including the Employment Regulations [43]. An employment contract must contain as follows: 1) name of an employer and full name of an employee; 2) date of commencement of labor relations; 3) employee's salary; 4) applicable pay period; 5) number of hours or days of work; 6) conditions relating to a labor leave, payment of labor leave, payment for work on holidays, payment of sick leave; 7) term of a notice to an employee/employer in case of termination of labor relations; 8) name of the employee's position or brief description of the employee's work; 9) term of the employment contract (if it is contemplated to enter into the employment contract for a certain period), or an indication that the contract is entered into for an indefinite term; 10) place of work; 11) disciplinary rules or procedure for considering the employee's complaints; and 12) other provisions stipulated by the AIFC acts. According to the Employment Regulations, an employee may be employed only under an employment contract made in the English language, signed by the employee and an employer. According to paragraph 11(2) of the Employment Regulations, an employer must provide an employee with a copy of an employment contract within 2 months after commencement of labor relations. However, in our view, in practice, it is preferable to provide an employee with 1 original copy of the employment contract immediately after signing by both parties, because the employee may wish, for example, to cancel the employment contract 1 month after employment or the employee may need to review again the text of the contract, which he/she signed. As compared with the Employment Regulations, the Labor Code of Kazakhstan stipulates that one (1) copy of an employment contract must be kept by an employee and an employer, i.e. immediately after signing an employment contract by both parties one (1) copy of the employment contract must be provided to the employee.
If an employee has insufficient knowledge of English to understand the conditions of an employment contract, an employer must explain to such employee all conditions of the employment contract before signing by the employee. In this case, we recommend the AIFC employers preparing a written translation of the employment contract into the language, which the employee speaks, in order to avoid labor disputes in the future.
-------------------------------------------------- [1] AIFC Companies Regulations No. 2 dated 20 December 2017 (amended as of 28 December 2022, in effect since 1 January 2023). [2] AIFC Companies Rules No. GR0004 dated 29 December 2017 (amended as of 17 October 2021, in effect since 1 January 2022). [3] Constitutional documents of the Company mean the articles of association of the Company and any other resolutions and agreements, to which Article 28 (Filing of special resolutions and certain other resolutions and agreements) (Schedule 1 to the AIFС Companies Regulations) applies. [4] AIFC Glossary, Act No. FR0017 dated 29 April 2018 (amended as of 9 December 2022, in effect since 1 January 2023). [5] AIFC General Rules No. FR0001 dated 17 October 2017 (amended as of 9 December 2022, in effect since 10 December 2022) («AIFC General Rules»). [6] Standard Articles of Association for private companies (Schedule 5 to the AIFС Companies Rules). [7] Ordinary resolution of the Company means a resolution passed by a simple majority of votes of the shareholders (or shareholders of a relevant class of shares) who vote personally (if entitled) or, if possible, through a representative at the general meeting, of which they have been properly notified with an indication of the intention to put this resolution for voting. An ordinary resolution of the Company includes an ordinary resolution in writing passed in accordance with Section 100 (Resolutions in writing of private companies) (Schedule 1 to the AIFС Companies Regulations). [8] Civil Code No. 268-XIII of the Republic of Kazakhstan (General Part) dated 27 December 1994 (amended as of 21 May 2024). [9] Company's registered office must be within the AIFC boundaries. This must be a «real office», co-working space with the possibility to receive correspondence, or an office of a firm rendering services on provision of a legal address and receipt of correspondence. Formally, from the legal standpoint, such services fall under a licensable type; however, in the absence of an express indication in the AIFC acts as to whether such firms must have a license of the AIFC on provision of the «Company Service Provider» services, they are provided without a license. [10] Search for unreliable taxpayers https://kgd.gov.kz/ru/services/taxpayer_search_unreliable/list. [11] Guidance on the Rules on the Substantial Presence of the Astana International Financial Centre Participants Applying Tax Exemptions for the Payment of Corporate Income Tax, Value Added Tax and the Rules on the Substantial Presence of the Astana International Financial Centre Participants Applying Tax Exemptions for the Payment of Corporate Income Tax, Value Added Tax, approved by the Order No. AFSA-P-OA-2021-0009 of AFSA dated 17 October 2012, approved by the Ministry of Finance of the Republic of Kazakhstan on 26 November 2021. [12] Please see the Resolution No. 81 of the Management Board of the Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market «On Approval of the Rules for Issuing Consent to Appointment (Election) of a Managing Employee of a Bank, Bank Holding, Branch of a Non-Resident Bank of the Republic of Kazakhstan, Including the Criteria for Absence of Flawless Business Reputation, Documents Required to Obtain the Consent, Specifics on Presence of Work History for Candidates Who Have Professional Qualification Confirmed by International Certificates, and the List of Such Certificates» dated 28 October 2022. [13] AIFC Financial Services Framework Regulations No. 18 dated 20 December 2017 (amended as of 28 December 2022, in effect since 1 January 2023). [14] Regulatory Guidance on Fitness and Propriety dated 14 June 2022. [15] Qualifications necessary for employment in the AIFC. AIFC Act No. GR0009 dated 10 December 2017 («Qualification Requirements Act»). [16] Law No. 50-VIII of the Republic of Kazakhstan «On Introduction of Amendments into Certain Legislative Acts of the Republic of Kazakhstan on the Issues of State Corporation «Government for Citizens», International Technological Park «Astana Hub», and Dactyloscopy Registration» dated 23 December 2023.
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