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

Day 1 – Introduction to the AML/CFT Framework

Module 1.1. Fundamentals and Risks of Money Laundering and Terrorist Financing

• Understanding Money Laundering (ML) and Terrorist Financing (TF)
• Stages of ML: Placement, Layering, and Integration
• Cash-out schemes, typologies, and high-risk sectors
• National and international ML/TF threats (Kazakhstan and AIFC)

Module 1.2. International Standards and Local Regulation

• FATF, EAG, UN, Basel Committee, and Wolfsberg Group standards
• Mutual Evaluation of Kazakhstan and the role of the FIU
• AIFC legal framework and AFSA’s AML/CFT approach
• Licensing requirements, supervisory procedures, and enforcement measures

Practical Session:

• Mini case study: “A client with an unusual ownership structure. Is there a risk?”
• Q&A on the international AML/CFT framework

Day 2 – Building an AML/CFT System within an Organization

Module 2.1. Establishing an AML/CFT Programme

• The role of the MLRO, Compliance Officer, and Internal Control Function
• Mandatory policies and procedures under AFSA requirements:

• AML/CFT Policies
• Customer Due Diligence (CDD and Enhanced Due Diligence)
• Internal reporting and escalation procedures
• Suspicious Activity Reports (SARs)
  • Record-keeping, staff training, and ongoing monitoring obligations

Module 2.2. Customer Due Diligence and Risk-Based Approach

• Identification and verification of individuals and legal entities
• Beneficial Ownership requirements
• PEPs, offshore structures, and sanctions/watch lists
• Risk-Based Approach and customer risk assessment methodology

Practical Session:

• Exercise: Developing a customer profile and assessing risk level
• Discussion: What information is essential for CDD within the AIFC framework?

Day 3 – MLRO Practice, SAR Reporting, and Cooperation with Competent Authorities

Module 3.1. MLRO in Action

• MLRO responsibilities under AFSA regulations
• Handling alerts and suspicious activities
• Identifying and responding to red flags
• Preparation and submission of reports to competent authorities
• Internal investigations and cooperation with regulators

Module 3.2. AML/CFT Technologies and Tools

• Overview of screening, transaction monitoring, and KYC solutions (SumSub, Chainalysis, WorldCheck, etc.)
• Use of open-source intelligence (OSINT)
• Reporting, audit processes, and compliance automation

Practical Session:

• Scenario: A client is linked to a sanctioned PEP
• Discussion: MLRO interaction strategy with the Financial Monitoring Agency
• Designing an AML programme 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