Fundamentals of AML/CFT and the role of the MLRO in the AIFC

Day 1 — Introduction to the AML/CFT System

Module 1.1: Fundamentals and Risks of ML/TF

• What is money laundering and terrorist financing
• Mechanisms and stages of money laundering (placement, layering, integration)
• Cash-out methods, schemes, and high-risk sectors
• National and international threats (Kazakhstan, AIFC context)

Module 1.2: International Standards and Local Regulation

• FATF, EAG, UN, Basel Committee, Wolfsberg Group
• Standards and evaluations: Kazakhstan’s mutual evaluation, role of the FIU
• AIFC legal framework: AFSA’s approach to AML/CFT
• Licensing, liability, and AFSA’s inspection procedures

Practical Session

• Mini-case: “Client with an unusual structure — is there a risk?”
• Q&A: Understanding the structure of the international AML/CFT system

Day 2 — Building an AML/CFT System Within a Company

Module 2.1: Structuring the AML/CFT Program

• Roles of the MLRO, compliance officer, and internal control
• Mandatory policies and procedures (within AFSA context):
  • AML/CFT policies
  • Customer due diligence (CDD and enhanced due diligence)
  • Internal reporting and escalation procedures
  • Suspicious transaction reports (STRs)
• Obligations related to document retention, staff training, and ongoing monitoring

Module 2.2: Customer Due Diligence and Risk-Based Approach

• Identification and verification of individuals and legal entities
• Working with beneficial ownership structures
• PEPs, offshore entities, and sanctions lists
• Risk-based approach and risk scoring methodology

Practical Session

• Exercise: Developing a “client profile” and assessing risk level
• Discussion: What data is critical for CDD in the AIFC context?

Day 3 — MLRO Practice: STR Filing and Interaction with Authorities

Module 3.1: MLRO in Action

• MLRO responsibilities under AFSA regulations
• Handling alerts and suspicious transactions (STRs)
• Responding to red flags
• Preparing and submitting reports to competent authorities
• Role of internal investigations and cooperation with regulators

Module 3.2: Technologies and Tools in AML/CFT

• Overview of systems: screening, transaction monitoring, KYC tools (e.g., SumSub, Chainalysis, WorldCheck)
• Use of open-source intelligence (OSINT)
• Reporting, auditing, and compliance automation

Practical Session

• Scenario: Client linked to a sanctioned PEP
• Discussion: MLRO’s strategy for engagement with the Financial Monitoring Agency (FMA)
• Workshop: Designing an AML program structure aligned with AFSA requirements

• Online training sessions
• Questions and answers​
• Presentations and recommendations from the trainer​
• Electronic training certificate

Nurlan Adaliev

Expert with internationally recognized experience in AML/CFT, blockchain analytics, and digital asset regulation.

Currently serves in the AML/CFT Department of the Astana International Financial Centre (AIFC), and previously led divisions within the Financial Monitoring Agency of the Republic of Kazakhstan.
Holds several prestigious professional qualifications, including:

• CCAFCS – Certified in Combating Financial Crime Involving Cryptoassets
• Crystal Intelligence EVM Investigation – Specialized in blockchain and DeFi investigations
• Member of the international pool of evaluators for EAG/FATF, contributing to mutual evaluations of AML/CFT systems

Nuriya Erzhanova

Experienced legal and compliance professional with over 10 years of practice in legal support, financial monitoring, and anti-money laundering and counter-terrorist financing (AML/CFT).

Has worked in government agencies and international financial institutions, including the Financial Monitoring Agency of the Republic of Kazakhstan and Verum Payments Ltd.
Possesses deep knowledge of both national and international legislation, with proven expertise in developing internal policies, delivering training, and conducting risk assessments.
Recognized for her high level of responsibility, attention to detail, and ability to collaborate effectively with cross-functional teams.