Compliance control

This is how we make our bank secure

What is compliance

It is an important part of bank's operations — examining whether the bank and its clients follow all the required laws, regulations, rules and policies, both internal and external (state and international).

Why we need compliance


Legislation requirement

All banks that have received a license from the Agency of the Republic of Kazakhstan for Regulation and Development of Financial Market, are required to create a system for examining their activities for compliance with the law.


Financial stability

We ensure the bank's financial stability by minimizing fines, sanctions and other control measures from the regulators. And most importantly, we do not allow the risk of losing a license.


International standard

This is an international standard that we must meet in order to build successful relationships with foreign banks and financial institutions. This is how we maintain our reputation.

What does compliance do



We monitor all transactions within the bank to identify suspicious ones

We check clients before providing service to them

We ensure compliance with international sanctions





How we check our clients

In the terrorists and suspicious persons lists, sanctions lists

Clients' participation in operations of prohibited or high-risk countries and territories

Suspicious transactions, purchases and sales of sanctioned goods and services

Automatic control

Bank checks

Opening bank accounts offline only at the bank branch

Only in person, prohibited by proxy

Required documents:

Required documents:

IIN of a non-resident (passes automatic verification at the State Revenue Committee of the Republic of Kazakhstan)

Application form with contact details, citizenship, residence, residential address

Mandatory compliance checks:

  1. International sanctions lists
  2. Analysis of counterparties
  3. History of relationship with the bank
  4. List of terrorists and suspicious persons
  5. Foreign politically exposed persons
  6. Verification of activities, business reputation
  7. Origin of funds
  8. List of people involved in arms proliferation
  9. Verification on prohibition on opening an account
  10. List of unreliable taxpayers, presence of tax debts

In regard to the residents of the Russian Federation and the Republic of Belarus screening of international transfers is carried out in order to prevent the purchase of sanctioned goods/services

Technologies that help us check

We use an AML (Anti Money Laundering) module by Prime Source.

This is an automatization software of financial monitoring and risk management in accordance with the legislation on combating the legalization (laundering) of proceeds from crime and the financing of terrorism.

In order to improve the quality of our checks, we are always improving the system in terms of enrichment with modules. For example, we are now implementing a module using machine learning to increase the speed and quality of checks for suspicious transactions.

The system allows us to:

  1. Conduct automatic checks by lists of international sanctions, terrorists and extremists
  2. Calculate risk levels and assign risk ratings to clients
  3. Detect and respond to threshold and suspicious transactions in a timely manner
  4. nteract via a secure communication channel — report suspicious transactions, exchange additional requests and files
  5. Form management and regulatory reporting

Bank audit

Government agency

Agency of the Republic of Kazakhstan for the Regulation and Development of the Financial Market (ARFRM).

Subject of inspection

  1. Compliance with international sanctions.
  2. Compliance with the legislation of the Republic of Kazakhstan on "The Law On Counteraction of Legitimization (Laundering) of Incomes Received by Illegal Means, and Financing of Terrorism"
  3. Capital adequacy and structure inspection.

Date of inspection

June-July, 2022

The verification processes

Customer identification

Selective screening of individuals which are under sanctions and other special lists

Risk management of money laundering and terrorism financing

Structure of the internal control system

Complete and timely reporting to the authorized body

Compliance of internal regulation documents according to the legal requirements

Preparation and training of bank employees

Conclusion of the inspection

As a result of the inspection regarding compliance with LCL/FT legislation and international sanctions, no violations were found. Hence, the regulatory authority did not impose any fines, sanctions, or other control measures on the bank.

Laws we follow

“The law on Banks and Banking activities in the Republic of Kazakhstan”

This is the main law which determines and regulates the banking system of the Republic of Kazakhstan as a whole, as well as individual banks.

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“The Law On Counteraction of Legitimization (Laundering) of Incomes Received by Illegal Means, and Financing of Terrorism”

In order to reduce the level of such criminal activities as money laundering, terrorist financing, weapons proliferation, the world community and all countries are developing and introducing special laws.

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“Foreign Account Tax Compliance Act” (FATCA)

Under this law, the US government is fighting American taxpayers who evade paying taxes.

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International sanctions

Our bank is not only a participant in international relations, but also part of a large international holding company Freedom Holding Corporation. Therefore, we strictly and fully comply with the prohibitions and restrictions of the sanctions of the United Nations, the European Union, the United States and other leading countries of the world.

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About SWIFT transfers

Notifications of violations

Freedom Bank adheres to high standards of corporate culture and principles of business ethics, and also complies with all requirements of the legislation of the Republic of Kazakhstan.

Our bank highly values the trust of its customers and makes every effort to be a conscientious, responsible and ethical business partner.

If you are aware of such cases as bribery or corruption, violation of ethical standards, abuse of office, complicity in money laundering, financing of terrorism, disclosure of insider information, violations of international economic sanctions and other violations of the legislation of the Republic of Kazakhstan, please inform us about it.Violations can be reported in any of the following ways, either openly or anonymously, according to your choice.

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What license does the bank have?

How often does the bank undergo ARFRM inspections?

Do auditors from other countries check the bank's work?

How does the verification of SWIFT transfers change depending on the geopolitical situation in the world?

What does the bank do if a client accidentally ends up on the list of terrorists?

Which clients undergo compliance control checks?