Legal & Regulatory Counsel, Payments (Kazakhstan)

Overview

The organization is exploring opportunities to expand its licensed payment business in Kazakhstan and the broader CIS region. This role will provide end-to-end legal and regulatory support to the local licensed payment business, covering licensing and regulatory dialogue with the NBK and AFSA, contract review, corporate matters, and ongoing compliance with the applicable legal framework.

Responsibilities

• Support the licensing process with the NBK and AFSA, including:
  • Preparation of application packages
  • Legal analysis
  • Internal documents
  • Responses to regulator queries
• Monitor and analyze Kazakhstan legislation and regulations covering payments, e-money, currency regulation, AML/CFT, and personal data, as well as the AIFC/AFSA framework; assess business impact and advise on implementation.
• Prepare formal regulatory correspondence, requests for clarification, and comments on draft regulations.
• Participate in meetings and discussions with the NBK, AFSA, and other authorities.
• Provide legal support for regulatory sandbox participation, including structuring pilot products and testing conditions.
• Draft, review, and negotiate agreements, including:
  • Partner bank and client fund safeguarding arrangements
  • Outsourcing and intragroup service agreements
  • Technology and vendor contracts
  • Client terms and conditions
• Conduct legal review of new products and services, including client documentation, disclosures, and compliance with consumer protection requirements.
• Provide corporate legal support for local licensed entities, including:
  • Incorporation
  • Constitutional documents
  • Board and shareholder resolutions
  • Corporate governance documentation
  • Regulatory approvals and notifications for senior appointments
• Develop and maintain internal policies and procedures required by the NBK and AFSA, in cooperation with compliance and risk functions.
• Support regulatory inspections, examinations, and audits, and ensure timely submission of regulatory notifications.
• Handle legal aspects of client complaints and disputes and coordinate the work of external counsel.
• Work closely with global legal, compliance, and payments teams to align local requirements with group practice.

Requirements

• Law degree from a recognized university.
• A master’s degree (LLM) or equivalent is an advantage.
• 5+ years of legal experience focused on financial services regulation at a bank, payment organization, fintech company, or law firm with a financial services practice.
• Hands-on experience with licensing and regulatory engagement with the NBK and/or the Agency for Regulation and Development of the Financial Market.
• Strong knowledge of the Law of the Republic of Kazakhstan "On Payments and Payment Systems," NBK regulations on payment organizations and e-money, currency regulation, AML/CFT, and personal data legislation.
• Knowledge of the AIFC/AFSA regulatory framework is a strong advantage.
• Proven experience drafting and negotiating commercial agreements, including banking, outsourcing, and technology contracts.
• Experience in corporate law and governance of regulated financial entities.
• Ability to translate complex regulatory requirements into practical business solutions.
• Experience in crypto, digital assets, or e-money is an advantage.
• Excellent drafting skills and ability to work effectively with global cross-functional teams in a fast-moving environment.
• Fluent Russian and English required; Kazakh strongly preferred.

Preferred Qualifications

• LLM or equivalent.
• Knowledge of the AIFC/AFSA regulatory framework.
• Experience in crypto, digital assets, or e-money.
• Kazakh language proficiency.

Compensation & Benefits

• Competitive salary and company benefits.

Location

• Kazakhstan and the broader CIS region.
• Remote-first, work-from-home arrangement (may vary depending on the nature of the role and team).